Finding Text
Brigham Young University - Hawaii SCHEDULE OF FINDINGS AND QUESTIONED COSTS for the year ended December 31, 2022 Section III ? Federal Award Findings and Questioned Costs Finding 2022-001 - Non-Compliance with Timely and Accurate Student Enrollment Change Submissions to the National Student Loan Data System (Significant Deficiency) Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing #: 84.268, 84.063, 84.379 Title:Federal Direct Student Loan Program, Federal Pell Grant Program, Teacher Education Assistance for College and Higher Education Grant Program Award Years: 7/2021 ? 6/2023 Criteria 34 CFR 685.309(b): (1) Upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary - (i) In the manner and format prescribed by the Secretary; and (ii) Within the timeframe prescribed by the Secretary. (2) Unless 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. 34 CFR 690.83(b)(2): An institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Condition Of the population of students who had a status change and received Pell and/or Direct Loans during the fiscal year, 60 students were selected for enrollment reporting testing of the campus-level and program-level records. Of the 60 students selected, 22 instances were noted in which information was incorrectly or untimely reported to the National Student Loan Data System (NSLDS). Of the 22 students, two students were incorrectly reported as withdrawn when the students in fact had graduated and two students had graduation dates reported incorrectly. There were also six students that were reported with the incorrect status. Lastly, there were 12 students in which the program enrollment begin date information was reported incorrectly. This is a repeat of finding 2021-001. Cause In response to prior year finding 2021-001, management planned a corrective action plan that was intended to be completed by July 1, 2022. The U.S. Department of Education Federal Student Aid office issued multiple electronic announcements between June 2022 and April 2023, detailing enrollment functionality and identified issues. The April 2023 announcement indicated that institutions have not been able to comply with enrollment reporting requirements for the period July 19, 2022 through February 28, 2023 but are expected to comply with the enrollment reporting requirements beginning March 1, 2023. As a result, because of the system outage that was outside of the University?s control, we did not obtain evidence that the corrective action plan was implemented. Brigham Young University - Hawaii (the University) utilizes the National Student Clearinghouse (NSC) to report enrollment rosters, inclusive of student status changes, on a regular basis (i.e., every 60 days) to NSLDS. There were four instances related to human error in which management did not appropriately resolve data input errors communicated to them by the NSC or were input incorrectly into NSC. As a result of the data input errors two graduation status were incorrectly reported as withdrawn and two graduations status were reported with an incorrect graduation date. One of the exceptions related to the winter 2022 semester, three of the exceptions related to the spring 2022 semester. The next six instances were due to the University not appropriately adhering to their policy when determining the appropriate status to report based on the number of credits students were enrolled in during the semester. This resulted in four students being reported as full-time when their enrollment status was three quarter-time, one student being reported as three quarter-time when their enrollment status was half-time, and one student reported as less than half time when their enrollment status was half time. Five of these exceptions related to the winter 2022 semester, one related to the spring 2022 semester. The remaining 12 instances were related to a system error in which the system inappropriately codes student?s enrollment with the wrong program begin date. When students take a leave of absence or participate in an off-campus internship the functionality of PeopleSoft forces the University to create a new version of the program when the student returns. The new "start" date for the program is automatically entered when the "new" program begins. For the purposes of enrollment reporting this changes the program begin date being reported if the student had an interruption in enrollment at the same school location. Seven instances were noted in the Winter 2022 semester and five instances were noted in the spring 2022 semester. Effect A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for payment of interest subsidies all of which are impacted by inaccurate and untimely reporting. Questioned Costs None Recommendation We recommend that the University continue to execute its prior year corrective action plan, process improvements and information system enhancements, and to provide adequate training to the individuals responsible for updating students? electronic files to ensure status changes are reported accurately and timely to NSLDS. Management?s View and Corrective Action Plan Management?s response is reported in management?s view and corrective action plan included at the end of this report.