Finding 60992 (2022-003)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2022-11-28
Audit: 60987
Organization: Saint Leo University, INC (FL)

AI Summary

  • Core Issue: The institution failed to report and correct student enrollment information accurately and timely to the NSLDS, leading to significant compliance deficiencies.
  • Impacted Requirements: Institutions must report enrollment changes within 15 days and correct errors within 10 days, as outlined in 34 CFR 690.83(b)(2) and 34 CFR 685.309.
  • Recommended Follow-Up: Review and improve reporting procedures to ensure compliance with NSLDS requirements, and establish a process for timely correction of rejected records.

Finding Text

2022?003 ? NSLDS Enrollment Reporting Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster CFDA Numbers: 84.268 ? Federal Direct Student Loans Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Other Matters Finding related to Compliance and Significant Deficiency in Internal Controls over Compliance. Criteria or Specific Requirement: Institutions are required to report, certify, and correct enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). 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. Institutions must return the roster within 15 days of receipt, and correct errors within 10 days of receipt. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition: During our testing of the Direct Loan and Pell Grant programs, we selected the annual SCHER 1 report and a sample of 40 students to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted 11 instances of noncompliance related to the SCHER1 report, and 34 of 40 students tested had one or more instances of noncompliance, as noted below: I. Eleven instances where the Institution did not correct errors within the required ten days. When the errors were reported back to the servicer, the resubmission of the records were not corrected and ultimately rejected again. II. Thirty-one instances where the student's program begin date reported to NSLDS did not agree to the Institution's records. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) III. Twenty instances where the student?s program enrollment effective date was incorrectly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) IV. Three instances where the student's change in statuses were not certified and/or received by NSLDS within the required sixty days. 34 CFR 674.19(f)(2) Questioned Costs: None Context: Out of a sample of 40 students selected for testing, and 1 SCHER1 report for the requirements noted above, we noted the exceptions as described above. Cause: The University?s processes and controls did not ensure that student status changes were properly reported to NSLDS and errors corrected timely. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the Institution review its reporting procedures to ensure that students? statuses are accurately reported to NSLDS as required by regulations. In addition, we recommend the Institution work with its servicer to determine a procedure is in place to ensure all rejected records are properly reported to NSLDS within 10 days of the initial roster certification and upload. Views of responsible officials and planned corrective actions: See Corrective Action Pan prepared by the University.

Corrective Action Plan

2022-003 NSLDS Reporting Recommendation: We recommend the University review its reporting procedures to ensure that students? statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: please see below Name(s) of the contact person(s) responsible for corrective action: Elizabeth Vestal, Registrar. Planned completion date for corrective action plan: December 31, 2022 with continued auditing after. Four areas of deficiency have been identified within our current enrollment reporting process. Specifically, 1) the university did not correct errors within ten days, 2) the program begin date reported to NSLDS (National Student Loan Data System) does not match the university?s records, 3) the student?s program enrollment effective date is incorrectly reported to NSLDS and 4) status changes were not certified and/or received within sixty days. In response to your findings, the Registrar?s Office has created a plan of action to remedy the errors. The enrollment reporting process has new leadership at the university. The findings from the new audit team will be corrected. The corrections will require the university to change current behaviors, practices, and reports. Findings two and three are connected to the program start date entered into Colleague. Currently, when processing a program add or change in Colleague (student information system), the program start date defaults to the first day of the month of the start of the term. In the past admissions and advising have been instructed to enter the upcoming term date as the program start date in the SACP (Student Academic Program) screen of Colleague. Unfortunately, this is not being done consistently and several teams have reverted to using the default date and the issue was not identified prior to reporting. The following outlines the proposed corrective action plan: 1) New and re-entry/re-admit students, program changes, or change of residency a. Effective for student programs starting in Fall 2 2022, the program start date in Colleague will match the start date of the upcoming term or end date of prior term. The operator will manually correct the default date to mirror the first day of the start term or end date of prior term in Colleague. i. If there is a potential issue with the date of the upcoming term, the Registrar?s Office must be consulted prior to committing to an alternate date. 2) Active continuing students a. Phase 1: The Fall 1 2022 census report will be used to generate a list of all currently active students. Each student will be manually reviewed to verify the program effective start date reflects the start of term at the university or start of term for the next declared program/major. Although the start date of a program change is not required to match the start of term for enrollment reporting purposes, this will eliminate processing confusion and increase consistency. i. The first phase of corrections will be completed by October 24, 2022. b. Phase 2: Prior census reports will be used to capture students who had been active in terms from Summer 1 2021 to Fall 1 2022. The program effective start dates will be reviewed and corrected as needed. i. The second phase of corrections will be completed by December 31, 2022. 3) Communication a. Issue a Registrar Communication memorandum (RegCom) outlining the new expectations for assigning the program effective start date, auditing schedule, and implications of errors to the following within the university, by October 24, 2022. i. Registrar team ii. Admissions operations iii. Deans, Chairs, and Program Directors iv. Campus success coaches, faculty advisors, and coordinators v. Center directors and staff 4) Inactive students (have not attended since Summer 1 2021) a. The program effective start date of students who have not been active at the university since the Summer 1 2021 term will be reviewed and updated upon re-entry/re-admit to the university (See bullet 1 above). 5) Report/Audit a. Coordinate with the Department of Information Technology (DoIT) to create a SQL report to pull student information from Colleague, including the student?s start term and declared program effective start date. b. The Registrar?s Office will audit the report weekly to ensure all dates are compliant and accurate prior to generating the enrollment file. 6) Colleague functionality a. Explore the possibility of amending the default date assigned by Colleague. i. This is restricted by the capabilities of the SIS. If unable to amend, we would continue with manual process noted above. Findings one and four relate to the timing of file submission and correcting roster errors. The Registrar will review the university?s reporting procedures and schedule to ensure that student statuses are accurately reported through the servicer to NSLDS within sixty days and errors are corrected within ten days. To do so, the Registrar will: 1) Establish an annual schedule to report student statuses every thirty to sixty days. a. Attention will be given to term dates, withdraw deadlines, as well as weekends and calendar holidays. 2) Create a sub-schedule of timing for correcting errors. This schedule should account for days necessary for the servicer and NSLDS to process the data. 3) Audit the SCHER5 and other reports weekly to ensure any remaining errors are corrected within ten days. By taking the above actions, Saint Leo will have processes in place to establish and maintain procedures to reasonably achieve compliance with NSLDS regulations providing timely and accurate data and audit the effectiveness of our data collection and reporting procedures. The university, specifically the Registrar?s Office, is committed to submitting complete, accurate, and timely enrollment data for Saint Leo University students.

Categories

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

Other Findings in this Audit

  • 58295 2022-001
    Significant Deficiency
  • 58296 2022-001
    Significant Deficiency
  • 60990 2022-002
    Significant Deficiency
  • 60991 2022-002
    Significant Deficiency
  • 60993 2022-001
    Significant Deficiency
  • 634737 2022-001
    Significant Deficiency
  • 634738 2022-001
    Significant Deficiency
  • 637432 2022-002
    Significant Deficiency
  • 637433 2022-002
    Significant Deficiency
  • 637434 2022-003
    Significant Deficiency
  • 637435 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $67.07M
84.063 Federal Pell Grant Program $17.03M
84.425E Education Stabilization Fund Student Portion $11.15M
84.425F Education Stabilization Fund Institutional Portion $8.41M
84.007 Federal Supplemental Educational Opportunity Grants $897,321
84.033 Federal Work-Study Program $849,091
84.425M Education Stabilization Fund Strengthening $806,358
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $191,905
47.076 Education and Human Resources $138,982
16.525 Grants to Reduce Domestic Violence, Dating Violence, Sexual Assault, and Stalking on Campus $45,780