Finding 618701 (2022-003)

Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Federal Award Number: 84.063 Federal Pell Grant Program and 84.268 Federal Direct Student Loans Federal Award Year: July 1, 2021 through June 30, 2022 Compliance Requirement Special Tests and Provisions (N) ? Enrollment Reporting Criteria or Requirement Per Title 2, U.S. Code of Federal Regulations Part 200 (2 CRF 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award, (Subpart D, Section 200.303), the nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Under the Pell grant and direct loan programs, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return the enrollment reporting roster file within 15 days of receipt. An institution determines how often it receives the enrollment reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal, or the National Student Loan Data System (NSLDS) website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The institution must report the status change in its next updated enrollment reporting roster file (due within 60 days of the change). Condition Found, Including Perspective During our procedures for enrollment reporting, we identified 2 out of 40 student samples from Mercy College of Ohio in which enrollment status changes were not reported to NSLDS within the timeframe required. Cause and Possible Asserted Effect Managements? control to ensure that all reports of student status changes are submitted to NSLDS on a timely basis was not operating effectively to identify instances of student enrollments not being reported correctly on a timely basis. Questioned Costs There are no questioned costs associated with this finding. Statistical Validity The sample was not intended to be, and was not, a statistically valid sample. Identification of whether the audit finding is a repeat of a finding in the immediately prior audit and if so, the applicable prior year finding number The audit finding is not a repeat finding. Recommendation We recommend that the University strengthen its processes and control regarding the configuration and timing of enrollment reporting to the National Student Clearinghouse to ensure that all student status changes are communicated timely to NSLDS. Views of Responsible Officials Management agrees with the findings and recommendations. BSMH has developed controls around the timeliness of enrollment reporting as indicated in our Corrective Action Plan. BSMH?s enhanced processes and procedures includes additional safeguards around submissions to the National Student Loan Database Systems (NSLDS). The instances related to timeliness of reporting of certain students was due to an error in the data pulled from the Student Information System. The system failed to include newly registered spring 2022 students. BSMH makes note that this system failure was detected internally and corrected in the spring 2022 semester, prior to the independent audit of this program.