Finding Text
Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a halftime basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address.
Condition: Exceptions were noted for 11 out of the 25 students tested. The exceptions are as follows:
• For six students, the College failed to report enrollment updates to National Student Loan Data System (NSLDS) at the campus or program level within 30 days or included in a response to a roster file within 60 days.
• For four students, incorrect effective dates were reported at the program level.
• For one student, the College was unable to provide documentation for an address change.
The sample was not a statistically valid sample but was determined using Chapter 21 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Government Auditing Standards and the Single Audits Audit and Accounting Guide.
Cause: For the six students with enrollment updates not timely reported, it was due to the College's system not processing a status change when the status change occurred during the semester. For the four students with incorrect effective dates, it was due to the College reporting the withdrawal date as the last day of the semester instead of the effective date. The lack of documentation for the one student's address change was due to human error.
Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, anticipated completion dates, and address changes, then the Title IV student loan records will be inaccurate, impacting student loan repayments.
Questioned Costs: Not Applicable
Recommendation: We recommend the College adjust their procedures to correctly report all status changes in enrollment during the semester, work with the National Student Clearinghouse to understand the errors in program level reporting to NSLDS, and ensure that documentation regarding address changes are maintained.
Management's Response: Management acknowledges the finding. The registrar has been processing NSC files at least every 28 days during MCAD’s three academic terms. They will implement additional checks on enrollment to locate status changes within term. Also, they will begin reporting status changes that occur between terms, rather than at the beginning of the following term.