Finding 60076 (2022-001)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2022-12-06

AI Summary

  • Core Issue: The University reported incorrect withdrawal dates to the National Student Loan Data System (NSLDS), leading to misrepresentation.
  • Impacted Requirements: Compliance with 34 CFR 668.22(c) regarding accurate withdrawal date reporting.
  • Recommended Follow-Up: Implement a supplemental enrollment reporting file to automate and improve accuracy in reporting unofficial withdrawals.

Finding Text

2022-001 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat Finding 2021-001) Criteria: In accordance with 34 CFR 668.22(c) a student's withdrawal date is: (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification, the mid-point of the payment period; (4) if the institution determines that a student did not begin the institution's withdrawal process or otherwise provide official notification to the institution of his or her intent to withdraw because of illness, accident, grievous personal loss, or other such circumstances beyond the student's control, the date that the institution determines is related to that circumstance; (5) If a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if a student takes a leave of absence that does not meet certain requirements, the date that the student began the leave of absence. Statement of Condition: During the 2022 audit, it was noted that the University reported the incorrect date to NSLDS for the withdrawal date. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The 2022 audit included a detailed testing of 40 student files, of which this significant deficiency applies to 4, indicating an error rate of 10.00%. Cause and Effect: The University used the incorrect withdrawal date in some instances, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct withdrawal date is reported to NSLDS. View of Responsible Officials: The University of the Cumberlands has reviewed the NSLDS reporting procedures surrounding unofficial withdrawals and recognizes a deficiency. The Registrar?s Office and Financial Aid Office have determined the need for a supplemental enrollment reporting file after the end of each semester to automate the reporting of unofficial withdrawals. This additional file will lessen the number of manual corrections to withdrawal dates in NSLDS, thus increasing the level of accuracy in reporting.

Corrective Action Plan

Corrective Action Plan Year Ended June 30, 2022 Findings from the 2021-2022 Audit The Auditor's Report on Compliance for Each Major Program and on Internal Control over Compliance required by the Uniform Guidance noted one finding from the 2021-2022 audit: Finding 2022-001. 2022-001 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, CFDA #84.268 and Federal Pell Grant Program, CFDA #84.063). The University reported the incorrect date to NSLDS for the withdrawal date. Name of Contact Person Management agrees with finding 2022-001. We acknowledge that the internal control over the details, procedures, communication, and language used in processing unofficial withdrawals needs to be strengthened to reduce the risk of errors. Kimberly Noe of Financial Aid, and Kathryn McCune, Registrar, are the responsible parties for the corrective action. Corrective Action Plan The prior corrective action plan was implemented and shown to be beneficial in reducing the number of errors in the enrollment reporting process. The plan proved to be effective in addressing the previous clerical errors surrounding official withdrawal dates. However, the University acknowledges the need to strengthen our procedures regarding unofficial withdrawal date reporting at the conclusion of each semester. The Registrar's Office and Financial Aid Office have determined the need for a supplemental enrollment reporting file after the end of each semester to automate the reporting of unofficial withdrawals. This additional file will lessen the number of manual corrections to withdrawal dates in NSLDS, thus increasing the level of accuracy in reporting. The date the supplemental enrollment reporting file should be processed after the conclusion of each term is by the 15th of the following month. The Financial Aid and Registrar's offices have identified additional reporting resources that will assist in the timely secondary review of the NSLDS data entered each semester to ensure compliance. The University of the Cumberlands will document the monthly secondary review of withdrawals and maintain our reconciliation records. The reconciliation process will be completed within 30 days of NSLDS certifying the submitted enrollment file. Anticipated Completion Date All records with errors noted during the 2021-2022 audit findings were corrected by October 13, 2022. The current Corrective Action Plan is anticipated to be fully implemented by January 31, 2023.

Categories

Student Financial Aid Reporting Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 60077 2022-001
    Significant Deficiency Repeat
  • 636518 2022-001
    Significant Deficiency Repeat
  • 636519 2022-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $70.07M
84.063 Federal Pell Grant Program $13.68M
84.038 Federal Perkins Loan Program $1.57M
84.033 Federal Work-Study Program $692,750
84.425 Covid-19 Education Stabilization Fund $249,000
84.007 Federal Supplemental Educational Opportunity Grants $199,682