Finding 64467 (2022-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-03-27
Audit: 73870
Organization: Molloy College (NY)

AI Summary

  • Core Issue: The University failed to report accurate enrollment information for all tested students to the NSLDS, including missing certification dates and incorrect statuses.
  • Impacted Requirements: Compliance with federal reporting standards for the Federal Pell Grant and Direct Student Loan programs, specifically regarding enrollment data accuracy and timeliness.
  • Recommended Follow-Up: The University should collaborate with NSLDS to ensure accurate reporting and make necessary updates once system access is restored.

Finding Text

Finding 2022-001 Special Tests and Provisions ? Enrollment Reporting Compliance and Internal Control (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Student Loans (CFDA #84.268) Federal Award Number: P268K201866 Federal Pell Grant Program (CFDA #84.063) Federal Award Number: P063P191866 Federal Award Year: 2021-2022 Criteria: Under the Federal Pell Grant Program and U.S. Department of Education (?ED?) loan programs, institutions are required to report student enrollment information via the National Student Loan Data System (?NSLDS?) (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access website. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS maintains as the most recently certified enrollment information. There are two categories of enrollment information; ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Required program-level data includes, but is not limited to: * Program enrollment status; *Program enrollment effective date; *Program begin date; *Published program length and measurement; and, * Classification of Instructional Program (?CIP?) code. Context and Condition: From a selection of forty (40) students tested, we identified the following instances of noncompliance: 1) For all forty (40) students, the certification date in the campus-level record data was not submitted to the NSLDS. 2) For seven (7) students, the status recorded within NSLDS was reported incorrectly per the student records and internal documentation provided by the University. Cause: The Department of Education requested that the University correct all errors noted during the prior year audit during the current year. Management went through a process to identify errors, maintain contemporaneous document required changes necessary to NSLDS records, and attempt to update the information in the NSLDS records. Management has indicated that due to errors experienced within the NSLDS system, the University was not able to access the system to accurately report this information during the year or correct information relating to prior years. Effect: Certification dates for all forty (40) students and the enrollment status for seven (7) students were not properly reported to the NSLDS. Questioned Costs: None identified. Identified as a Repeat Finding: No. Recommendation: The University should continue to work with the NSLDS to identify a way to report the required changes in the NSLDS system so that the information included within the University?s systems is accurately reflected at NSLDS. Views of Responsible Officials: As soon as the suspension of the NSLDS Enrollment History Update functionality is lifted, Molloy will make the necessary updates. Molloy will run a separate report the day each enrollment submission is created to capture any student who withdraws the date the submission is run.

Corrective Action Plan

Corrective Action Plan Finding 2022-001 ? Special Tests and Provisions ? Enrollment Reporting Compliance and Internal Control (Significant Deficiency) University's response: We concur. Name of contact person responsible for corrective action: Linda Albanese, Vice President Enrollment Management Corrective action: In response to the Enrollment Reporting audit finding, Molloy University will continue to check the NSLDS homepage Announcement section multiple times per week for any notice that the Enrollment History Update page is functioning. We are also subscribed to email communications from Compliance & Data Ops Managing Director of the National Student Clearinghouse (NSC) and the New York State Financial Aid Administrators (NYSFAAA). The re opening of the Enrollment History page will be announced through any of these venues or by electronic announcement from the Federal Student Aid (FSA) Office of the U.S. Department of Education. While Molloy certification dates are correct in our student information system, Jenzabar, the certification date in the National Student Loan Data System (NSLDS) prints as MM/DD/YYYY or the current date because the new website is not working properly. This is an NSLDS issue, and the University was advised not to make any changes in the site at this time. As per guidance from FSA, Molloy has retained copies of all announcements as documentation for audit purposes. These electronic announcements highlight the issues relating to the retirement of the old NSLDS website and the launch of the new website. Electronic announcements between June and November 2022 identified enrollment functionality issues. And the update to the November announcement reported the enrollment roster dissemination delay. The latest electronic announcement in January 2023 confirmed that colleges were not able to comply with enrollment reporting requirements. While Molloy continues to monitor all updates regarding the site, the University has also proactively reached out to the NSLDS Customer Service Center. In Case #221208 000270 the reply, dated December 8, 2022, confirmed that the errors reflected in NSLDS were not the fault of Molloy, but rather due to the issues with the NSLDS website. As soon as the suspension of the NSLDS Enrollment History Update functionality is lifted, Molloy will make the necessary updates. Proposed Completion Date: As soon as the suspension of the NSLDS Enrollment History Update functionality is lifted, Molloy University will make the necessary updates.

Categories

Student Financial Aid Procurement, Suspension & Debarment Reporting Significant Deficiency Matching / Level of Effort / Earmarking Special Tests & Provisions Internal Control / Segregation of Duties

Other Findings in this Audit

  • 64468 2022-001
    Significant Deficiency
  • 640909 2022-001
    Significant Deficiency
  • 640910 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $37.53M
84.063 Federal Pell Grant Program $4.66M
84.038 Federal Perkins Loan Program $1.70M
93.264 Nurse Faculty Loan Program (nflp) $906,905
59.075 Shuttered Venue Operators Grant Program $792,868
84.007 Federal Supplemental Educational Opportunity Grants $628,955
84.425 Education Stabilization Fund $411,000
47.076 Education and Human Resources $397,969
84.033 Federal Work-Study Program $328,055
84.042 Trio_student Support Services $247,538
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $241,863
93.732 Mental and Behavioral Health Education and Training Grants $214,949
47.075 Social, Behavioral, and Economic Sciences $87,887
16.525 Grants to Reduce Domestic Violence, Dating Violence, Sexual Assault, and Stalking on Campus $75,690
47.079 Office of International Science and Engineering $24,886