Finding Text
2023-007 – Special Tests and Provisions - Enrollment Reporting – Significant Deficiency in Internal Controls over Compliance
Student Financial Assistance Cluster
Department of Education
Federal Assistance Listing Number: 84.063, 84.268
Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans
Federal Award Number: P063P222403, P268K232403
Award Year: 2022-23, 2021-22
Criteria – The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the University’s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR § 685.309.
Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk, which includes the student's program as per the Classification of Instructional Programs (CIP) code, and the student's status change Effective Date.
Condition/context – We selected a sample of 42 students out of a population of 626 who had received Federal aid and were reported to NSLDS during the fiscal year. We compared the significant data elements under the Campus-Level and Program-Level Records that ED considers high risk as reported to NSLDS to the data included in the student's academic records, other institutional records, and the withdrawal or graduation date per the University’s records.
We noted exceptions with 4 out of the 42 students tested. Two students were not reported as withdrawn to NSLDS. One student was not reported as graduated to NSLDS. One student was reported to NSLDS, however the dates did not match the institutional records.
Our sample was not, and was not intended to be, statistically valid.
Questioned costs – None.
Cause/effect – This occurred because of lack of controls and oversight of the process. This resulted in incomplete and inaccurate reporting of the information to NSLDS. The enrollment information reported to NSLDS is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status.
Repeat finding – Yes, 2022-010
Recommendation – We recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. We also recommend the University establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the National Student Clearinghouse submissions.
Views of responsible officials and planned corrective actions – The University will adhere to current regulations and improve them if necessary to guarantee that all student status changes are recognized promptly and filed correctly within the allotted period. In order to internally audit the National Student Clearinghouse submissions, the University established a formal internal monitoring system wherein a designated individual with NSLDS access, on a sample basis, spot-checks the status updates on NSLDS.