Finding 587327 (2023-001)

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education Pass-Through Entity: Direct Funded Criteria or Specific Requirements: OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct Loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: “Campus Level” and “Program Level”, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance – During testing over the NSLDS reporting requirements, the following deficiencies were noted: 20 of the 35 students we tested did not have their enrollment information for the Spring 2023 term reported to NSLDS. Questioned Costs There were no questioned costs associated with the noncompliance. Context The District disbursed federal financial aid to approximately 1,300 students in the 2022-2023 fiscal year that required student enrollment and program enrollment reporting to NSLDS. A sample of 35 students were selected for testing. Effect The District is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students under the Pell grant and Direct and FFEL loan programs via NSLDS timely and accurately. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Repeat Finding: (Yes or No) No Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. Views of Responsible Officials and Corrective Action Plan Gavilan’s current process in submitting enrollment files to NSC involves a collaboration between two departments: Admissions and Records and Information Technology. During this period, primarily in Spring 2023, the two parties experienced a miscommunication between which file contained the current enrollment data versus which file was being submitted to NSC. Admissions and Records mistakenly submitted 4 incorrect files. Since, Admissions and Records has worked with IT to update procedures and strengthen communication when collecting the current enrollment data. To further correct the deficiency, discussions circled around Admissions and records working with a Banner Ellucian Consultant to review our Banner capabilities and strengthen the user control to oversee and submit the enrollment reports independent of IT’ s assistance. Admissions and Records will also develop a written manual to cover the step-by-step process in submitting the School Enrollment Transmission to National Student Clearinghouse in order for the correct NSLDS monitoring. The written manual will document: • Banner pages and strokes, including screen shots. • Current IT process, point of contact and file name • Link to future transmission page on the National Student Clearinghouse user page • Link to NSDLS Reporting page to validate and confirm correct submissions have been reported. The Director of Admissions and Records will coordinate business practices with Admissions and Records, Financial Aid and IT to ensure the school enrollment transmissions are submitted on time and are correct. The business process will be documented by Admissions and Records and shared with Financial Aid, IT, and the VP of Student Services