Finding Text
FINDING 2023-001- Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance
(See Section III - Finding 2023-001 for table included)
Criteria – Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that institution but has ceased to be enrolled on at least a half-time basis.
Condition/Context – A sample of 36 federal aid recipient students out of a population of approximately 150 were selected from system generated reports of students who had a reduction or increase in attendance levels, graduated, withdrew, dropped out, or enrolled but never attended during the 2022-2023 academic year. A comparison was made between each selected student’s National Student Loan Data System (NSLDS) enrollment detail to the student’s academic files and other institutional records to verify that the University was accurately reporting significant campus-level and program-level enrollment data within the required time frame. This was not a statistical sample. An exception was noted whereby the enrollment status change for 6 of the 36 students selected for testing were not reported within the timeframe set out in the guidance.
Questioned Costs – No questioned costs were identified as part of this finding.
Effect – Enrollment status is utilized by students, the U.S. Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school status. NSLDS also uses the newly submitted enrollment data to recalculate a student’s 150% limit for direct subsidized loans to determine if loss or protection of the subsidy should occur. Therefore, delays in enrollment reporting could result in incorrect future eligibility for undergraduate aid, as well as impact future subsidy loss or protection related to the 150% limit or impact the repayment period for withdrawn or graduated students.
Cause – Delays by study abroad faculty in submitting grades to the registrar resulted in delays in the conferral determination for these students. Therefore, they were still reported as enrolled until the grades were received, even though they were no longer receiving instruction from the University. For the six exceptions noted above, the University has since updated its records to reflect these status changes; however, the College’s intermediary failed to timely report each change within the required timeframe.
Repeat Finding – This is not a repeat finding.
Recommendation – We recommend the University implement a detective control by which a sample of student status changes are subsequently verified within the NSLDS for accurate and timely reporting. Even if there are delays in receiving grades from faculty, a student should be reported as withdrawn and then subsequently updated as graduated once conferral has been determined.
Views of Responsible Officials and Planned Corrective Actions – The Offices of the Registrar and Financial Aid will jointly review and implement additional control procedures to monitor submission of enrollment status changes. The Registrar and Financial Aid Offices will implement additional reviews of NSLDS data after updates have been submitted to NSLDS to ensure accurate and timely reporting of enrollment status changes.