Finding 586940 (2023-001)

Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster ALN Numbers: 84.268 – Federal Direct Loan Program Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: During our testing, we noted 4 out of the 8 students tested where the student was not reported in a timely manner after the school determined the students change in status. Furthermore, 4 out of the 8 students effective date per the institution did not match the enrollment effective date. Questioned Costs: None Context: During our testing, it was noted the Seminary did properly report the effective date to NSLDS based on the Seminary’s records. Cause: The Seminary did not determine graduate students effective date correctly due to extenuating circumstance. Effect: The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By reporting an incorrect effective date, the grace period begin date for the student will be incorrect. Repeat Finding: Yes, 2022-001 Recommendation: We recommend the Seminary reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure timely reporting as well as put a process in place to ensure the enrollment effective date reported to NSLDS is aligning with the Seminary’s last date of attendance. Views of Responsible Officials: There is no disagreement with the audit finding.