Finding 607057 (2022-004)

2022-004 ? Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2021-2022 Pass-through entity: Not applicable Criteria Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the NSLDS (OMB No. 1845-0035), (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. 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. The data on the institution?s 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. Under the Direct Loan programs, schools must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by the Department of Education via the National Student Loan Data System (NSLDS). The institution determines how often it receives the Enrollment Reporting roster file with the default set at every two months, but the minimum is twice a year. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis Direct Loan, 34 CFR section 685.309. Condition Through our testing of 100 enrollment reporting selections across 4 campuses, we noted the following at 2 campuses: ? For 3 of 25 selections at one campus, we noted that the effective date of the change per NSLDS did not agree to the effective date of the actual status change per the student file. In each of these instances, the student was changing from part-time to full-time . ? For 4 of 25 selections at a third campus, we noted that the students were reported as withdrawn when they should have been reported as graduated . Our understanding in each of the scenarios above, is that there would be no impact on repayment dates for students with loans, and thus these errors do not result in questioned costs or have an impact to the student or federal government. Cause ? The cause of the reporting finding at the first campus is that there was a system error that was backdating the campus-level enrollment effective date to the first date of the term when a student increased attendance, which is why the effective date per NSLDS did not agree to the effective date in the student file. ? Regarding the second campus, this finding relates to the sequence of reporting enrollment changes during the summer, and ultimately has a broader impact going back several years. During the summer, management noted they correctly reported graduated status more than once. However, in their final summer enrollment file, the status for these students was noted to be full-time status, which was true, but this full-time status overwrote their previously reported graduated status. Under standard practice, when these students did not appear in the fall enrollment file, the National Student Clearinghouse derived a withdrawn status, which was reported to NSLDS. There were also various error reports for which this campus was behind on fully resolving, resulting in this issue not being identified by management Effect The effective administration of Title IV loans could be impacted when changes in students? status are not reported timely and accurately. The accuracy of enrollment information is important as the student?s enrollment status determines eligibility for the in-school status, deferment, grace periods, and repayments, as well as the Government?s payment of interest subsidies. Questioned Costs None noted. Recommendation We recommend management implement controls to identify inconsistencies in enrollment reporting information and to ensure COD error reports are resolved in a timely manner. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.