Finding Text
2023-001 Assistance Listing Number(s), Federal Agency and Program Name: 84.063, 84.007, 84.033, and 84.268; United States Department of Education (DOE), Student financial assistance cluster.
Finding Type: Noncompliance and material weakness in internal control over compliance relating to special tests.
Criteria: The Institute is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately and timely reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that DOE considers high risk.
Statement of Condition: Management implemented controls that specifically addressed the circumstances surrounding prior year finding 2022-001. Management's review of the enrollment reporting did not detect other errors on certain student data elements or timely reporting. Certain student records within the NSLDS were identified with inaccurate data elements and not timely reported.
Questioned Costs: Questioned costs could not be determined.
Context: 10 students were identified with inaccurate data elements and not timely reported out of a total of 25 students tested.
Cause: The Institute’s internal control over compliance did not detect and correct the errors. The preparer incorrectly input the student's effective date and status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment data elements that DOE considers high risk.
Effect: The Institute incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that DOE considers high risk and the Institute’s internal controls over compliance did not detect and correct the errors.
Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to DOE. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment reporting.
Management’s Response: Management agrees with the finding. Through internal investigation, it was determined that there was a procedural issue with the manual entry of two date fields which both need to be the same when submitted to National Student Clearinghouse (NSC). Human error during these manual checks caused one data field to be correct, and the other incorrect. This error has been fixed so that both fields will always be the same and accurate.
The Institute has also updated our enrollment reporting procedures to have the registrar log into NSLDS monthly to confirm that the prior month NSC status changes are properly recorded in NSLDS.