Finding Text
Finding 2022-001: Enrollment Reporting Submissions for Graduates U.S. Department of Education Student Financial Assistance Cluster Program Name(s): Federal Pell Grant Program, ALN 84.063 and Federal Direct Student Loans, ALN 84.268 Award Numbers: P063P216822 (Palo Alto College); P063P215081, P268K225081 (San Antonio College) Compliance Requirement: Special Tests and Provisions ? Enrollment Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: According to the Office of Management and Budget (OMB) 2022 Compliance Supplement, institutions are required to report enrollment status information under the Pell Grant and the Direct Student Loan programs via the National Student Loan Data System (NSLDS) in a timely and accurate manner. The Department of Education (ED) requires the enrollment information to be submitted at least every 60 days. Condition and Context: As part of our testing of the District?s compliance with enrollment reporting requirements, it was noted that for 4 students (all of whom were Pell Grant recipients and 1 was also a Direct Loan recipient; students were attendees of Palo Alto College and San Antonio College) out of the total of 40 students sampled, the District did not ensure that the students? enrollment status of ?Graduated? was reported to NSLDS. The sample size to be tested was not determined using a statistical sampling approach. Cause: The submission of enrollment information is a systemic process in which a report is generated in Banner, the District?s ERP system; the District sends that information to the National Student Clearinghouse (NSC), who then submits it to the NSLDS. For students who have graduated, the District uses a free service from NSC called DegreeVerify, through which NSC reviews the students on the District?s ?Graduate? file to determine whether it can create a ?Graduated? enrollment record. An exceptions report is then created within NSC listing those students whose status could not be updated to ?graduated?. The District is then required to review the exceptions report and resend the list to NSC indicating that the student?s status does in fact need to be updated to ?Graduated.? The District did not review the exception reports for the current year, which resulted in the 4 students noted above not having their ?Graduated? status reported to NSLDS by NSC. Effect or Potential Effect: The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Complete and accurate reporting of students? enrollment information to NSLDS is critical, as this information is used to determine the subsidy status of certain loans and for other purposes. The lack of timely enrollment reporting could result in either a lack of timely repayments by the borrower or the student being inappropriately moved into loan repayment status. See ?Condition? above for instances of noncompliance identified in the current period which were not identified as material noncompliance. Questioned Costs: There are no questioned costs. Repeat Finding: No Recommendation: We recommend that management implement a process to review the DegreeVerify exceptions report and indicate to NSC that student statuses need to be updated to ?Graduated.? This process should be performed with sufficient regularity to ensure that enrollment information reported to the NSLDS is complete and accurate. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan