Finding 599124 (2022-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-03-19
Audit: 22748
Organization: Erikson Institute (IL)
Auditor: Rsm US LLP

AI Summary

  • Core Issue: The Institute did not report three students' withdrawals to the National Student Loan Data System (NSLDS) within the required 60 days.
  • Impacted Requirements: This failure violates federal regulations regarding timely enrollment reporting, which could jeopardize future federal financial aid funding.
  • Recommended Follow-Up: Implement ad hoc reporting in NSLDS to ensure timely updates and prevent future compliance issues.

Finding Text

Finding 2022-001: Timely Enrollment Reporting Major Federal Program Title: United States Department of Education, Student Financial Assistance Cluster, Direct Student Loans (AL 84.268) Criteria: 2 CFR Part 200.303(a) state that the auditee must establish and maintain effective internal control over the federal awards that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statues, regulations, and terms and conditions of the federal award. Specific criteria for enrollment reporting are established by the U.S. Department of Education within the 2021-2022 Federal Student Aid Handbook, Chapter 3, Sharing Information with NSLDS, Federal Loan Servicers, and Guarantors, including: (1) Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the NSLDS. (2) Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. (3) Institutions must report any enrollment status changes for students within 30 days; however, if a roster file is used, then the Institute may use the roster file to provide the update within 60 days. Condition: The Institute failed to notify the National Student Loan Data System for three selected students' withdrawals within the required 60 days. However, it was properly determined for the students to have earned 100% of the Title IV funds. Context: Three of 14 students tested from a population of 43 students with enrollment status changes were not reported in the required timeframe.Cause: These had occurred during the Registration and Records Department transitions with the Senior Director of Enrollment management leaving in July. Going forward it is practice for the Institute to notify NSLDS at the time of withdrawal determination to ensure timely submission. Effect: Noncompliance with federal regulations could result in the loss of future federal financial aid funding. In addition, not reporting enrollment status change within the required timeframe can impact an individual student?s loan deferment and repayment schedule. Questioned Costs: None Repeat finding: No Recommendation: We recommend that management consider the use of the ad hoc reporting option in NSLDS to prevent inadvertent late enrollment status updates for Return to Title IV Funds. Views of Responsible Official: Management agrees with this finding. Please see corrective action plan attached.

Categories

Student Financial Aid Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 22682 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $5.45M
93.434 Every Student Succeeds Act/preschool Development Grants $319,445
84.325 Special Education - Personnel Development to Improve Services and Results for Children with Disabilities $273,833
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $134,655
93.600 Head Start $91,568
84.033 Federal Work-Study Program $69,000
47.076 Education and Human Resources $62,673
84.305 Education Research, Development and Dissemination $49,962
93.505 Affordable Care Act (aca) Maternal, Infant, and Early Childhood Home Visiting Program $13,127
84.425 Education Stabilization Fund $5,091