Finding 842 (2023-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2023-10-27
Audit: 1585
Organization: Missouri Baptist University (MO)
Auditor: Forvis

AI Summary

  • Core Issue: The University failed to report student enrollment changes to NSLDS on time, violating federal regulations.
  • Impacted Requirements: Enrollment reporting must occur within 30 days for changes and within 60 days on roster files.
  • Recommended Follow-Up: Evaluate and improve controls for monitoring enrollment reporting and ensure timely updates from the third-party servicer.

Finding Text

Information on the Federal Program: Student Financial Assistance Cluster, Assistance Listing Number 84.268 Federal Direct Student Loans, Assistance Listing Number 84.063 Federal Pell Grant Program, U.S. Department of Education Program Year 2022-2023 Criteria or Specific Requirement: Special Tests and Provisions - Enrollment Reporting Condition: Federal regulations provide that the University is responsible for notifying the National Student Loan Data System (“NSLDS”) of changes in enrollment within 30 days or on an Enrollment Reporting roster file within 60 days. The University’s internal control system did not prevent certain late or missed changes requiring reporting. Questioned Costs: None Context: Out of a population of 285 student enrollment status changes requiring NSLDS notification, a sample of 35 student enrollment changes were selected for testing. 33 of the status changes had deviations from reporting requirements. Our sample was not and was not intended to be statistically valid. Effect: The University may not be able to timely detect when students are not being included within the Enrollment Reporting roster file which could result in the NSLDS not being properly notified of student enrollment changes for Direct Loan and Pell recipients in accordance with federal regulations. Cause: During fiscal year 2023, 32 of the 33 exceptions related to graduates or withdrawn students where the status change was reported to the University’s third-party servicer within the 60 day period but was not reported by the third party servicer to NSLDS within the 60 day period. The remaining other exception related to a student with an improper effective date reported to NSLDS. Identification as a Repeat Finding, if Applicable: Not Applicable Recommendation: We recommend the University evaluate controls around monitoring enrollment reporting to determine changes, either on the electronic processes or review processes that should be made to properly capture enrollment status changes on a timely basis and to properly monitor its third-party service provider for timely reporting as necessary. Views of Responsible Officials and Planned Corrective Action: Management concurs with the finding and recommendation. See further information on the corrective action plan provided by management.

Corrective Action Plan

Regarding student status change reporting, we identified a primary issue as the cause of late reporting this year for 32 of the 33 issues identified by our auditors. Upon review, we have determined changes that will prevent future instances of late reporting. As would be known to the federal government, a website and database conversion of the National Student Loan Data System (NSLDS) made enrollment reporting unavailable to schools for most of the academic year. One consequence to this was that the National Student Clearinghouse (NSC), transitioned away from what they refer to as a mid-month roster response. It was not known to us that the NSC was not regularly submitting mid-month response files to NSLDS after enrollment reporting resumed in January of 2023. Our monthly enrollment SSCR file is scheduled to be sent to the NSC on the first of each month. Our scheduled graduation date is the end of April or start of May, so we typically send an updated graduated student list around the middle of May. We were delayed from submitting this until the first week of June. The data submission was too late to be caught by the June 1st SSCR sent by NSLDS, but we expected that it would be sent by the mid-month file sent by NSC to NSLDS around June 15th. This would have kept us within 60 days for reporting. However, since NSC did not conduct mid-month reporting in June, the data we submitted indicating graduations that occurred at the end of April/start of May sat until July 1st with NSC and it was not sent to NSLDS within 60 days. Conversations we have had with the NSC since this discovery assured us that they have resumed mid-month reporting as of July, 2023. Additionally, our analyst with the NSC assured us they would track our transmission schedule to know if data is refreshed and current at the time of their responses to the first of month SSCR files they receive from NSLDS. When the data we send comes through after a scheduled SSCR file has been processed, they will reach out to inform us of a mid-month roster being sent. To provide accountability toward this, we will make it our process to check with them on whether a mid-month roster will be sent also. When NSC does not expect to send mid-month files automatically, we will order an ad-hoc enrollment report from the NSLDS website. We experimented with this process in recent months when we became aware of this issue with mid-month reporting and found it successful. In discussion with NSC and NSLDS, we inquired as to whether we should simply increase the frequency of our NSLDS SSCR to twice per month. For the majority of the year, this is not necessary. It was a unique situation this year in that mid-month reporting had ceased following the NSLDS Enrollment Reporting being offline for half or our academic year. For one additional student in the sample, an error was found with our student information system not updating the effective date of their enrollment change. Our software vendor was asked about the conditions of this error. They had made a modification to the reporting logic early on this past year, and this logic has proven to be inaccurate. The issue was not apparent through most of the year because enrollment reporting was not being conducted because of the previously mentioned NSLDS website transitions. Upon learning of the error, our software vendor updated their logic and has issued a patch that will correctly update the enrollment status effective date. All corrective actions will be fully implemented by October 31, 2023.

Categories

Student Financial Aid Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking Special Tests & Provisions Internal Control / Segregation of Duties

Other Findings in this Audit

  • 843 2023-001
    Significant Deficiency
  • 577284 2023-001
    Significant Deficiency
  • 577285 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $16.58M
84.063 Federal Pell Grant Program $2.98M
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $210,289
84.007 Federal Supplemental Educational Opportunity Grants $209,900
84.033 Federal Work-Study Program $139,802