Finding Text
Special Tests – Enrollment Reporting
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
ASSISTANCE LISTING Number:
84.268 – Federal Direct Student Loans
84.063 – Federal Pell Grant Program
Federal Award Identification Number and Year: P063P220362, 2023 AND P268K230362, 2023
Award Period: June 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter
Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information; “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file. The University must also have an adequate process to internally review submissions to either the third-party servicer or directly to NSLDS. Additionally, Institutions are required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR
200.303.
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 student enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). Our testing resulted in the following items of noncompliance.
1. 1 individual student where a student's campus-level enrollment status was not correctly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2)
2. 7 individual students where a student's campus-level enrollment effective date was not correctly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2)
3. 34 instances where a student’s enrollment status change was not reported timely to NSLDS. 34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2)
4. 1 instance where a student’s program-level enrollment effective date did not match the institutions records. 34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2)
Questioned costs: N/A
Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 40 students with exceptions as described above. 5 students had multiple instances of noncompliance.
Cause: The University was unaware of the errors which were caused by the transmission of data between there student information system and the third-party servicer.
Effect: The NSLDS system could not be updated accurately or timely with student enrollment information.
Repeat finding: No
Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that
reporting is completed accurately and timely.
View of responsible official: The University agrees with the finding.