Finding number: 2022-002
Federal agency: U.S. Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing #’s 84.063, 84.268
Award year: 2022
Criteria
According to 34 CFR 685.309(b)(2):
Unless [the institution] it 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 July 2021:
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 College to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, we noted three students, out of a sample of twenty, that were not reported to NSLDS within the required timeframe.
Cause
Human error mistakenly resulted in lack of reporting of three students.
Effect
The College did not report three students’ status changes to NSLDS within the required timeframe which could impact the students’ loan grace periods.
Questioned Costs
N/A
Perspective
Our sample was not, and was not intended to be, statistically valid. Of twenty students selected for testing, three students, or 15% of our sample, had a status change that was not reported to NSLDS within the required timeframe.
Recommendation
The College should provide training to employees responsible for processing information for the NSLDS to ensure that they have adequate knowledge of the related rules and regulations. This training should include an explanation of the College’s date of determination, the importance of timely reporting, and the consequences of late reporting. Additionally, submission of additional rosters and a more formalized review and approval process will reduce the likelihood of such findings in the future.
Identification as a Repeat Finding, if applicable
See finding 2021-001 included in Management’s Summary Schedule of Prior Audit Findings.
Views of Responsible Officials
Management concurs with the auditor’s finding.
Finding number: 2022-002
Federal agency: U.S. Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing #’s 84.063, 84.268
Award year: 2022
Criteria
According to 34 CFR 685.309(b)(2):
Unless [the institution] it 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 July 2021:
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 College to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, we noted three students, out of a sample of twenty, that were not reported to NSLDS within the required timeframe.
Cause
Human error mistakenly resulted in lack of reporting of three students.
Effect
The College did not report three students’ status changes to NSLDS within the required timeframe which could impact the students’ loan grace periods.
Questioned Costs
N/A
Perspective
Our sample was not, and was not intended to be, statistically valid. Of twenty students selected for testing, three students, or 15% of our sample, had a status change that was not reported to NSLDS within the required timeframe.
Recommendation
The College should provide training to employees responsible for processing information for the NSLDS to ensure that they have adequate knowledge of the related rules and regulations. This training should include an explanation of the College’s date of determination, the importance of timely reporting, and the consequences of late reporting. Additionally, submission of additional rosters and a more formalized review and approval process will reduce the likelihood of such findings in the future.
Identification as a Repeat Finding, if applicable
See finding 2021-001 included in Management’s Summary Schedule of Prior Audit Findings.
Views of Responsible Officials
Management concurs with the auditor’s finding.