Finding Text
FINDING 2022-001 ? Special Tests and Provisions ? Enrollment Reporting ? Significant Deficiency in Internal Control over compliance "See Schedule of Findings and Questioned Costs for chart/table" Criteria: The National Student Loan Data System (NSLDS) is the Department of Education?s (ED) centralized database for students? enrollment information. It is University of Redlands? (the ?University?) responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes. The University is ultimately responsible for the timeliness and accuracy of this information even when a third-party servicer is used as an intermediary to report on the University?s behalf. The University currently contracts with a third-party servicer and has elected to receive an Enrollment Reporting roster file every 30 days from NSLDS. At a minimum, institutions must certify the enrollment status of all students included on the roster file within 15 days of receiving the roster file. If errors are identified, the University has 10 days to resubmit a corrected response. 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 federal aid either did not enroll or ceased to be enrolled on at least a half-time basis (34 CFR section 685.309). Condition/Context: We selected a sample of students identified by the University as having received some federal assistance and who either withdrew, took a leave of absence (LOA), or graduated from the University during the year ended June 30, 2022. Our sample consisted of 19 students out of a population of approximately 185 that withdrew or took an LOA during the year and a sample of 40 students out of a population of approximately 406 that graduated during the year. We then compared the enrollment information and withdrawal, LOA, or graduation date per the University?s records to the information reported to NSLDS. We believe this to be a representative sample of the population. We noted exceptions with 6 students whose status change was not reported within the required time frame. Questioned Costs: No questioned costs were identified as part of this finding. Effect: Enrollment status is utilized by students, ED, the Direct Loan program, lenders, and other institutions to determine in-school status. NSLDS also uses the newly submitted enrollment data to recalculate a student?s 150% limit for direct subsidized loans to determine if loss or protection of the subsidy should occur. Therefore, this significant deficiency in enrollment reporting could result in incorrect future eligibility for undergraduate aid, as well as impact future subsidy loss or protection related to the 150% limit. Cause: 1. Students? accounts were left active in the student information system during their LOA instead of modifying their status to an LOA. Traditionally, they would have been identified as on an LOA and not reactivated until confirmation of their return was made. While these students were not reported as enrolled, when the student did not return, their status was not changed to withdrawn. 2. Commencement dates on the academic calendar do not align with conferral dates. Specifically, the summer term has a conferral date that is more than 60 days after the end of the term. Additionally, students may be approved to take courses elsewhere and have those courses transferred to the University or may graduate mid-term due to additional sessions they elect to take. These scenarios all add to the complexity of identifying the graduation dates in relation to the student?s last day of attendance and can lead to error. 3. The University contracts with a third-party processor to transmit withdrawal information to NSLDS. If there are errors identified in how the third-party transmits this data, the University?s procedures are to correct the data with the third-party and does not currently have a process to identify if errors are reported to NSLDS directly. Repeat finding: This is a repeat finding of 2021-001. Recommendation: 1. The Registrar?s office use consistent coding in their student information system when identifying a student is on an LOA and that they use the last day to add a course as the deadline for these students to return, and if they do not, change their status to withdrawn. 2. The University update the Academic Catalog to reflect that degrees will be awarded the last date of the semester, not particular calendar dates. Second, students approved to take coursework elsewhere should be coded as such in the student information system. This status is the equivalent of a withdrawal and students should be reported as such. Upon receipt of the transferred credit back to the University, the student?s status should be updated in the student information system, the degree awarded, and, if outside the typical reporting window for degrees, the student?s status should be manually updated in the National Student Clearinghouse. Degrees will be awarded effective the most recent semester that has concluded. Additionally, for programs using sessions, the Registrar?s Office should ensure that degrees are awarded effective the last date of the semester and not the session. The Office should also ensure that the various student support bodies on campus understand this difference. 3. The University develop additional procedures to monitor the accuracy of information provided by its third-party servicer on behalf of the University to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate. Each institution has access to correct information directly within NSLDS at any time. Views of responsible officials and planned corrective actions: Management agrees with the findings and recommendation and has developed planned solutions to target the causes noted above.