Finding Text
Findings and Questioned Costs Relating to Federal Awards
2023-001: Enrollment Reporting
Federal Program – Student Financial Assistance Cluster – Noncash assistance – Federal Direct Student
Loans Program (Assistance Listing No. 84.268)
Federal Agency – U.S. Department of Education
Federal Award Year – July 1, 2022 to June 30, 2023
Criteria Requirement
34 CFR 685.309 states that the administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. 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 National Student Loan Data System (NLSDS) Professional Access (NSLDSFAP) website.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by U.S. Department of Education (ED) via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for
changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website. (Note: The automated processes and required reporting are described in the NSLDS Enrollment Reporting Guide. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.)
When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change).
Condition Found
For 21 out of 40 enrollment status changes sampled, comparison of the institution’s records to that of NSLDS evidenced that enrollment reporting for these students were not accurately reflected within the NSLDS website. Therefore, Washington and Lee University did not report the accurate enrollment status to the NSLDS.
Possible Cause and Asserted Effect
Management’s review over its enrollment reporting requirements for SFA was not operating as designed to ensure accurate reporting of status changes. The personnel responsible for identifying and resolving edit checks noted by the National Student Clearinghouse (NSC) did not perform this step of the control implemented by management, thus, did not accurately communicate the students’ status changes Management determined that the personnel assigned these responsibilities were not adequately trained to complete this step of the control. As such, certain status changes were not reported accurately to NSLDS.
Questioned Costs
The questioned costs associated with this finding are not determinable as the finding is not of monetary nature.
Sampling Approach
The sample was not intended to be, and was not, a statistically valid sample.Identification of Repeat Finding
This finding is not a repeat of a finding in the immediately prior year.
Recommendation
We recommend that the Washington and Lee University reinforce and train those individuals in the compliance control ownership role to ensure controls are operating as designed in order to prevent or detect and correct noncompliance on a timely basis. Specifically, emphasizing the processes and controls around ensuring edit checks identified by the NSC are reviewed and resolved on a timely basis.
Views of Responsible Officials
The Washington and Lee University agrees with the findings and the recommendation. W&L has developed controls around the timeliness and accuracy of enrollment reporting. The instances of noncompliance were due to reliance on the NSC to identify and communicate potential errors in the accuracy of the student information uploaded to the NSC system instead of independently verifying there were no edit checks identified by the NSC as outlined in the design of the current internal controls implemented by the entity. As such, management has committed to reinforce and train the individuals in the compliance control ownership role with respect to the proper execution of the internal controls within the enrollment reporting.