Finding Text
2023 – 003
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Numbers: 84.063 and 84.268
Federal Award Identification Number and Year: E-P268K90313, grants were awarded within the 2021-22 and 2022-23 award years.
Award Period: September 1, 2022, through August 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement:
Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309).
Changes in enrollment status must be reported within 30 days or with the next roster file if such file is due within 60 days. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610).
Condition:
Certain students’ enrollment information was not reported accurately or timely to the NSLDS.
Questioned Costs:
N/A
Context:
1.) During our testing of NSLDS Enrollment Reporting, we noted status change was received by NSLDS was outside of the 60 day timeframe for 20 of the 40 students sampled.
2.) During our testing of NSLDS Enrollment Reporting, we noted incorrect enrollment effective dates were reported to NSLDS for 4 of the 40 students tested and 2 of 40 students had the wrong enrollment status reported. During our testing of NSLDS Program Enrollment reporting, we noted incorrect program effective dates were reported to NSLDS for 1 of the 40 students tested and 1 of the 40 students tested had the incorrect status reported.
Cause:
The College policies and procedures did not ensure that student status changes were timely reported to NSLDS.
Effect:
The NSLDS system is not updated with the student information which can cause over-awarding should the student transfer to another institution and the student may not properly enter the repayment period.
Repeat Finding:
Yes - Finding 2022-004
Recommendation:
The College should review their reporting internal controls and procedures to ensure that they require students' statuses to be reported timely to NSLDS as required by federal regulations. The College should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS aligns with the College’s last date of attendance.
Views of Responsible Officials:
Management agrees with the finding and has developed a plan to correct the finding.