Finding Text
Assistance Listing, Federal Agency, and Program Name - Department of Education Federal Direct Student Loan Program ALN No. 84.268 and Federal Pell Grant Program ALN No. 84.063
Federal Award Identification Number and Year - Various
Pass through Entity - N/A
Finding Type - Material noncompliance with laws and regulations
Repeat Finding - No
Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)).
Condition - The University did not report certain students' status to NSLDS in an accurate and timely manner during the fiscal year.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context There were two errors identified that attributed to this finding:
1) Of the 40 students tested, there were 10 students who withdrew or graduated whose status changes were not reported accurately to the NSLDS. The students were reported timely but with an incorrect effective date.
2) Of the 40 students tested, there were 33 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days.
Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner.
Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS.
Views of Responsible Officials and Planned Corrective Actions - The College corrective action plan implemented as of the time of this communication has included integrated feedback from multiple campus constituencies received through a series of meetings led by our Academic Dean in order to define a process focused on managing this particular compliance obligation. The participating departments included; Academic Affairs, Enrollment, Financial Aid, Business Office, IT, Registrar, Student Life, Academic Services and the President’s Office. The result was development of an internal policy with clearly defined protocols, procedures and timelines (referred to as the “Adrian College Data Integrity Notification Guidelines” policy document). Assessment will be periodically evaluated via the College’s internal audit process.
Note:
• Regarding status change for withdrawn or graduating students: The College submitted its report to the National Student Clearinghouse (NSC) twenty eight (28) days prior to the sixty (60) day requirement to be received by the NSLDS. The College was subsequently notified by NSC that it had been the victim of a third party security breach. We believe this event contributed to delay for the NSC to review, certify and post to the NSLDS; contributing to this finding.
• Regarding student reporting with incorrect effective dates posted: It appears that the effective dates submitted by the College to NSC were subsequently modified within the NSC database. We believe a third party security breach identified to the College by NSC may have contributed to the posting of incorrect effective dates to NSLDS; contributing to this finding.
There were no questioned costs associated with the finding.