Finding Text
2022-001 ? National Student Loan Data System (NSLDS) Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.063, 84.268 Award Period: 7/1/2021 ? 6/30/2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student?s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). Condition: Certain students? enrollment information was not reported accurately or timely to the NSLDS. Questioned Costs: None Context: During our testing, we noted the following: ? 1 student out of a sample of 40 students tested was reported to the NSLDS with the incorrect enrollment status on both the campus-level and program-level records in the NSLDS. ? 3 students out of the sample of 40 students tested were reported to the NSLDS with the incorrect effective date on the campus-level in NSLDS. ? 3 students out of a sample of 40 students tested were not reported to the campus-level record in the NSLDS in a timely manner. ? 2 students out of a sample of 40 students tested were reported to the program-level record with the incorrect enrollment effective date per the University?s records. ? 1 student out of a sample of 40 students tested was reported to the NSLDS with the incorrect enrollment effective date per the University?s records on both the campus-level and program-level records in the NSLDS. Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. Occasionally, the third-party servicer incorrectly communicates information to the NSLDS which results in discrepancies between the University's system and the NSLDS. There are also times the University updates certain information on students after reports are sent to the third-party servicer and these changes are not being captured on the reporting to the third-party servicer to the NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students? grace period should begin. Repeat Finding: Yes, 2021-001. Auditors? Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Views of Responsible Officials: See the corrective action plan.