Finding Text
Federal programs: Federal Pell Grant Program; Federal Direct Loan Program CFDA Number: 84.063 / 84.268 Federal award identification number: P063P214207 / P268K224207 Grant period: August 1, 2021, to July 31, 2022 Federal agency: U.S. Department of Education Pass-through entity: N/A Category: Compliance / Internal Control Finding Type: Significant Deficiency Compliance requirement: Special tests and provisions ? Enrollment reporting Condition and context During our enrollment reporting test, for a statistically valid sample of nine (9) students from a population of fifty-one (51) records that had a reduction or increase in attendance levels, graduated, withdrew, dropped out, or enrolled but never attended during the audit period, we noted the following deficiencies: a.) In one (1) case (11%) the information of enrollment reporting was not available for examination. The student withdrew and received Pell grant funds for the enrolled term. b.) In six (6) cases (67%), we noted that the Institution failed to report the enrollment status before the thirty (30) days deadline for NSLDS web reporting. The reporting was made between five (5) to nineteen (19) days after the required deadline. From this sample, three (3) students received Direct Loan for the 2021-22 award year. Additionally, the enrollment reporting requirement applicable to institutions under the Pell Grant and ED loan programs requires that institutions complete and return within 15 days the Enrollment Reporting roster file (formerly the Student Status Confirmation Report (SSCR) placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by ED via NSLDS. Regarding this, during our evaluation of compliance with the Roster File return requirement, we requested the NSLDS SCHER1 report. We noted one (1) instance where the roster was updated after the fifteen (15) days deadline (35 days) from which the Institution received a late letter on November 26, 2021. Criteria Dear College Letter (DCL) GEN-14-07, Subject: Changes to NSLDS Enrollment Reporting: Program - Level Reporting and More Frequent Reporting, states that, under the authority of these regulations, beginning July 1, 2014, we will request enrollment information from schools every 60 days and schools will be required to respond to those requests within 15 days of the date that we send the electronic enrollment reporting roster to the school or to its designated third-party servicer. Also, the section of the letter titled Program-Level Enrollment Reporting Required, states that if the student is or was enrolled in more than one program, the student?s enrollment information must be reported for each of the programs. The NSLDS enrollment reporting rosters include recipients of all Title IV loans and Federal Pell Grants. Including Pell Grant recipients will allow the Department to meet the Congressional reporting requirements noted earlier. Note that a student will only be included on the roster once, regardless of the number of different Title IV programs from which the student received funding. 34 CFR 690.83 (b) (2) establishes that 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. 34 CFR 690.83 (b) (2) establishes that 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. Cause The Institution?s internal controls for tracking and reporting the enrollment changes failed to identify the enrollment status changes performed manually by the Registrar?s office personnel. Effect A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to FFEL Program loan holders by ED. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Failure to report will likely result in the school being out of compliance with the regulatory requirements and possibly subject to sanctions. Also, failing to report completions at all may cause borrowers to lose interest subsidy when they should not. And, because such determinations are based on the student?s enrollment (and completion) at the program level, it is critically important that schools correctly and promptly report a student?s completion at the program level. Questioned costs None. Identification as a Repeat Finding A finding related to this compliance requirement was included in the prior year audit as Finding No. 2021-004. Recommendations We recommend the Institution to determine what parts of the manual processes for this requirement can be monitored electronically or using tools available in the USDE website with the assistance of the IT consultant to help the Institution to comply with the deadline of the roster reporting. Also, we recommend reinforcing the controls to report the enrollment status changes of the participant students of the Pell and Direct Loan programs. In addition, a compliance officer may assist in the reporting process. Views of Responsible Officials Refer to the Institutional comments included in the Corrective Action Plan.