Finding Text
Finding 2022-001 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster ? Federal Direct Student Loans ALN: # 84.268 Compliance Requirement: Special Tests and Provisions - Enrollment Reporting Type of Finding: Compliance Finding, Material Weakness in Internal Controls over Compliance Repeat Finding: Yes ? 2021-001, 2020-001, 2019-002 CRITERIA: The Code of Federal Regulations, 34 CFR 685.309 (b) requires Schools to certify and report the enrollment status of students who receive Title IV aid to the National Student Loan Data System (?NSLDS?). Enrollment status changes for students must be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Enrollment information must be reported whenever a student?s attendance pattern changes. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. This enrollment information is merged to the NSLDS database and reported to the guarantors, lenders, and servicers of student loans. A student?s enrollment status determines deferment eligibility, grace periods, and repayment schedules, as well as the government?s payment of interest subsidies. As such, NSLDS records must be accurately matched with enrollment records. Schools must continually review, update, and verify student enrollment statuses and other information. CONDITION: From a sample of forty (40) students who received Pell and/or Direct loans during the year, a review of each sampled student?s Enrollment Data as updated to the NSLDS system per the NSLDS web-site noted the following: - Four (4) students withdrew from the School but were not reported to the NSLDS as withdrawn within the 60 days required. The students were not reported prior to the NSLDS outage beginning in July 2022. - Four (4) students graduated from the School but were not reported to the NSLDS as graduated with the 60 days required. The students were not reported prior to the NSLDS outage beginning in July 2022. - Twelve (12) began attending the School in 2022, but were not reported prior to the NSLDS outage beginning in July 2022. QUESTION COSTS: None noted. CAUSE: The School did not implement the corrective action plan from the prior year audit until February 2023. Further, the NSLDS was down from July 2022 to February 2023 and as such, the new policies did not fully take effect until after the year-end. EFFECTS: Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, grace periods, repayment schedules, and deferments. It also affects the federal government's payment of interest subsidies. RECOMMENDATIONS: The School should implement internal control procedures that will educate key process owners (including the registrar office) of the enrollment reporting compliance requirements per the Code of Federal Regulations, 34 CFR 685.309 (b). The School should then implement internal control procedures to first ensure that errors in the Registrar?s system are corrected in a timely manner, and second to ensure that changes in the student statuses are reported within the required timeframe. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. As noted by the auditors, a corrective action plan was established to ensure that timely enrollment data be coordinated between the Registrar?s Office and the Financial Aid Office. This plan was developed in August 2022 along with additional corrective actions efforts to ensure that admission and financial aid data was internally audited prior to enrolling a student. As the audit was conducted, it was evident that the corrective action could not be examined for effectiveness and accuracy as the students examined were from periods prior to the implementation of the corrective action plan and then, as noted by the auditors, the government?s NSLDS was not working from July 2022-February 2023, so records could not be shared. The corrective action plan was implemented when the NSLDS became available to submit reports in February 2023. Additionally, the Helms College Registrar, Director of Education and Compliance and Financial Aid Manager will complete free enrollment reporting training courses offered by the National Student Clearinghouse and continue to submit the enrollment status reports to the National Student Clearinghouse according to the required reporting schedule.