Finding 63664 (2022-001)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-03-06

AI Summary

  • Core Issue: Colleges failed to report student enrollment data accurately and on time to the National Student Loan Database, leading to noncompliance with federal regulations.
  • Impacted Requirements: Regulations require accurate reporting of enrollment status changes within 30 days, effective dates, and timely submission of enrollment rosters.
  • Recommended Follow-Up: Colleges should review and improve their reporting processes to ensure compliance with NSLDS requirements and prevent future issues.

Finding Text

Finding 2022-001: Enrollment Reporting Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance; Noncompliance Criteria The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to National Student Loan Database Student (NSLDS) through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Regulations require the status include an accurate effective date. There are two categories of enrollment information ?Campus Level? and ?Program Level? both of which need to be reported accurately. Regulations require the status include an accurate effective date. In addition, regulations require that an institution return the enrollment rosters within 15 days from receipt of the rosters and make necessary corrections and resubmit to NSLDS within 10 days. Condition Foothill College: Twenty students from a statistically valid sample identified the following conditions for 6 students: 1) The enrollment effective date reported to NSLDS did not match the College?s record - 6 students 2) The student?s enrollment status did not match the College?s Record - 1 student Condition (Continued) De Anza College: Twenty students from a statistically valid sample identified 5 students where the change in enrollment status reporting was not received by the NSLDS within the 60 days requirement. Questioned Costs None Context The Colleges disbursed $22,577,668 in Title IV awards during the year. Cause The College?s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect The case identified resulted in noncompliance with the Title IV regulation. Repeat Finding Similar conditions were noted at Foothill College and De Anza College in the 2019-20 (Finding 2020-005) and 2020-21 (Finding 2021-002). Recommendation We recommend that each College review their existing procedures and controls and identify necessary changes needed to ensure timely reporting of student status changes to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions Management concurs with the finding and has developed a plan to correct it.

Corrective Action Plan

2022-001 Student Financial Aid Cluster ? Enrollment Reporting ? Various Recommendation: We recommend that each College review their existing procedures and controls and identify necessary changes needed to ensure timely reporting of student status changes to NSLDS as required by regulations. Foothill College Response Explanation of disagreement with finding: There is no disagreement with the finding and the Foothill College will resolve it. Action taken in response to finding: Using the samples from the findings as an example, the Dean of Enrollment Services will contact with National Student Clearinghouse Audit support and request a review of the data received from the College by 3/1/2023. If the issue is with our data, the College with work our technical support team and request a specialist from Ellucian ? Banner that supports the enrollment reporting process. If the issue is merely additional training needed on how to handle the error report file, then additional training will be requested for appropriate Admissions & Records staff for one-on-one training with the National Student Clearinghouse. Name of the contact person responsible for corrective action: Anthony Cervantes, Dean of Enrollment Services Planned completion date for corrective action plan: April 1, 2023. De Anza College Response Explanation of disagreement with finding: De Anza College has reported all five students in question within 30 days of their status change to the National Clearing House. However, the NCH failed to report to the NSLDS the change of status within 30 days after we correctly reported the change in enrollment. The College has provided proof of our reporting to the NCH, but because the students were not reported by the NCH in a timely manner, we are responsible to take actions to correct this process and make sure that the NCH is reporting on time and with right reports. Action taken in response to finding: The College can see some improvement in numbers of unreported or misreported student records from the NCH to the NSLDS. The Dean of Enrollment Services will continue working with the National Clearing House on the reporting process to avoid discrepancies and delays in the future. Name of the contact person responsible for corrective action: Nazy Galoyan, Dean of Enrollment Services Planned completion date for corrective action plan: June 2023.

Categories

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

Other Findings in this Audit

  • 63665 2022-001
    Significant Deficiency Repeat
  • 63666 2022-001
    Significant Deficiency Repeat
  • 63667 2022-001
    Significant Deficiency Repeat
  • 640106 2022-001
    Significant Deficiency Repeat
  • 640107 2022-001
    Significant Deficiency Repeat
  • 640108 2022-001
    Significant Deficiency Repeat
  • 640109 2022-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Programs (pell) $17.15M
84.425 Covid-19 - Heerf Cares Act - Institutional $11.95M
84.425 Covid-19 - Heerf Cares Act - Student Aid $11.68M
84.268 Federal Direct Student Loan $4.32M
84.048 Career Technical Education Act Basic Grants to States (perkins Title I-C) $772,589
84.007 Federal Supplemental Educational Opportunity Grants (fseog) $535,918
84.033 Federal College Work Study (fws) $438,042
84.063 Federal Pell Administrative Allowance $127,739
93.558 Temporary Assistance for Needy Families (tanf) $34,811
93.859 National Institutes of Health $29,387
10.558 Child and Adult Care Food Program $27,020
94.006 Americorps State and National $20,180
84.031 Strengthening Institutions Program $11,823
17.258 Occupational Training Institute (oti) - General Grants $8,702
17.258 Wia - Adult Program $6,729
84.425 Covid-19 - Heerf Cares Act - Minority Serving Institutions $265