FAC Explorer

Finding 578710 (2023-005)

- Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2023-11-21
Audit: 3911
Organization: Vermont State Colleges (VT)
Auditor: Withumsmith+brown PC

AI Summary

  • Core Issue: Colleges failed to report student enrollment changes to NSLDS on time, with delays ranging from 3 to 168 days.
  • Impacted Requirements: Non-compliance with 34 CFR 685.309(b)(2) and 2 CFR Part 200, leading to incorrect effective dates and statuses reported.
  • Recommended Follow-Up: Strengthen review procedures for NSLDS reporting to ensure compliance with federal regulations.

Finding Text

Criteria According to 34 CFR 685.309(b)(2): Unless the Colleges expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that – (i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated June 2019: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the Colleges to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, 5 out of 40 students were reported late to the NSLDS by 3 to 168 days. During our testing, 2 out of 40 students reported incorrect effective dates, and 1 out of 40 students had an incorrect status reported to the NSLDS. Cause The Colleges did not have the proper review procedures in place to ensure enrollment status changes were being reported to NSLDS timely and correctly. Effect The Colleges did not report the students' correct effective dates to NSLDS or were not reported within the required timeframe, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 7 students, or 17.5% of our sample, did not report the correct effective dates to NSLDS or were not reported within the required timeframe. Identification as a Repeat Finding, if applicable See prior year finding 2022-001 Recommendation The Colleges should strengthen their controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials The Colleges agree with the finding.

Categories

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $26.17M
84.063 Federal Pell Grant Program $13.10M
84.042 Trio_student Support Services $1.50M
84.047 Trio_upward Bound $1.31M
93.575 Child Care and Development Block Grant $1.30M
84.033 Federal Work-Study Program $1.27M
59.077 Community Navigator Pilot Program $1.16M
84.007 Federal Supplemental Educational Opportunity Grants $1.11M
59.037 Small Business Development Centers $1.01M
90.601 Northern Border Regional Development $810,690
84.031 Higher Education_institutional Aid $797,633
84.116 Fund for the Improvement of Postsecondary Education $333,171
84.425 Education Stabilization Fund $329,611
94.006 Americorps $308,447
84.048 Career and Technical Education -- Basic Grants to States $292,268
84.217 Trio_mcnair Post-Baccalaureate Achievement $246,016
21.027 Coronavirus State and Local Fiscal Recovery Funds $238,154
16.753 Congressionally Recommended Awards $224,446
93.236 Grants to States to Support Oral Health Workforce Activities $210,251
45.162 Promotion of the Humanities_teaching and Learning Resources and Curriculum Development $175,896
17.285 Apprenticeship USA Grants $169,186
93.859 Biomedical Research and Research Training $150,474
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $146,104
47.073 National Science Foundation/uvm/ns $123,509
93.959 Block Grants for Prevention and Treatment of Substance Abuse $90,548
93.778 Medical Assistance Program $77,868
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $75,721
11.611 Manufacturing Extension Partnership $67,504
93.958 Block Grants for Community Mental Health Services $64,295
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $62,000
59.059 Congressional Community Project $58,847
47.050 Geosciences $52,669
20.205 Highway Planning and Construction $48,093
93.855 Allergy, Immunology and Transplantation Research $47,906
11.307 Economic Adjustment Assistance $41,778
93.084 Prevention of Disease, Disability, and Death by Infectious Diseases $38,305
84.181 Special Education-Grants for Infants and Families $33,910
10.575 Farm to School Grant Program $20,408
17.720 Disability Employment Policy Development $19,364
10.500 Cooperative Extension Service $17,899
43.001 Science $7,008
93.434 Every Student Succeeds Act/preschool Development Grants $7,000
45.025 Promotion of the Arts_partnership Agreements $3,122
11.467 Meteorologic and Hydrologic Modernization Development $1,066
93.888 Specially Selected Health Projects $944