Finding Text
2022-001 Enrollment Reporting U.S. Department of Education Program (ED) Student Financial Assistance Programs Cluster Federal Direct Student Loans (ALN 84.268) Federal Perkins Loan Program (ALN 84.038) Federal Award Year: 2021?2022 Condition: Three student?s enrollments changes were not reported to the National Student Loan Data System (NSLDS) within the 60 day timeframe for the School?s reporting on the roster file submissions. Criteria: Per 34 CFR 685.309, Schools are required to accurately report enrollment information under the Direct Loan program via the NSLDS. Enrollment status changes for students should 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 effective change in status or date of determination if the date of determination was determined after the withdrawal date. At a minimum, schools are required to certify enrollment every 60 days. Schools are also responsible for the accurate and timely reporting of high risk program-level record elements, which includes program type, length, and begin date; program enrollment status; and program enrollment effective date. Additionally, schools are required to accurately report enrollment information under the Direct Loan program to the NSLDS site. Cause: Management did not have effective internal controls in place to ensure that compliance with enrollment reporting requirements were followed. For one student?s status change, the National Student Clearinghouse did not submit the enrollment roster to NSLDS in a timely mater. For two students who graduated, the School did not report the students as withdrawn or graduated immediately after the end of the semester and within the required timeframe due to a delay in determining graduation requirements had been satisfied. The School ultimately reported the graduation status to the clearinghouse, but it was not early enough for the clearinghouse to report them on an enrollment roster to NSLDS to be in compliance with the 60 day reporting requirement. Effect: Inaccurate, late reporting may have an effect on timing of conversion to repayment status and/or the amount of repayment for students subject to an interest subsidy. In addition, inaccurate reporting could also cause an over-awarding issue if the student transfers to another school and award determination staff at the subsequent school are unable to accurately determine status and eligibility of the student. Prevalence: Three of the 61 status changes tested. Questioned costs: None. Repeat finding?: Yes. Recommendation: Management should review the controls and procedures in place to verify that accurate, timely and complete data is being submitted to NSLDS. This should include separation of preparation, review and completion, as well as methods to identify an accurate and complete reporting population. View of responsible officials of the auditee: Management agrees with this finding.