Boston UniversityHigher Education

Finding No.: 2023-001 –Reporting Federal Agency: Department of Education Pass-through Agency: Direct Program Name: Student Financial Assistance Cluster – Federal Direct Loan Program, Federal Pell Grant Program CFDA Number: 84.268, 84.063 Federal Award Numbers: P268K230183, P063P220183 Federal Award Year: July 1, 2022 – June 30, 2023 Criteria Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD) system. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the institution. Key items to test on disbursement records are disbursement date and amount. Institutions must report all loan disbursements and submit required records to COD within 15 days of disbursement (OMB No. 1845-0021). Condition Found Of the fifty (50) student disbursements selected for testwork, we noted forty-five (45) students had differences in disbursement dates per the institution’s records than what was reported within the COD system. The disbursement date differences ranged from one (1) to five (5) days. Possible Asserted Effect Inaccurate reporting of disbursement dates in COD could impact timeliness of reporting payments within required timeframe. The University did not have an internal control process in place to ensure required information reported to COD was accurate to the institutions’ records. Questioned Costs No questioned costs identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding This was not a finding in the prior year. Recommendation We recommend that the University review its process for creating disbursement records to report to COD to ensure timely positing of disbursements. View of University Officials The University must improve our quality controls to ensure these dates match in the future and take steps to mitigate this reporting issue. As this issue was identified in a recent Department of Education Program review, a corrective action plan has already been implemented. That plan includes the following action steps: 1. Boston University has changed the COD disbursement schedule to only occur during defined business hours and only on defined days of the week (Monday and Wednesday). This change to the disbursement schedule will allow BU to make sure the COD disbursement date is the same date as the federal financial aid credits to the individual student account. 2. Beginning with the 2024/2025 academic year, Boston University will transition from a home-grown mainframe system to PeopleSoft Campus Solutions. This system will allow us to more easily schedule jobs that ensure that the disbursement date in COD reflects the date the funds actually credit to the student’s BU student account. 3. Boston University will better utilize the COD reconciliation reports to monitor COD disbursement date inconsistencies with student account credits and make updates to COD when inconsistencies occur

Finding No.: 2020-001 ? Enrollment Reporting Federal Agency: Department of Education Pass-through Agency: Direct Program Name: Student Financial Assistance Cluster ? Federal Direct Loan Program, Federal Pell Grant Program CFDA Number: 84.268, 84.063 Federal Award Numbers: P268K200183 Federal Award Year: July 1, 2019 ? June 30, 2020 Criteria or Requirement According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via the National Students Loan Data System (NSLDS) within 15 days of receipt. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school and the student has 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. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS web site, certifying through the NLSDS?s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal award. Condition Found, Including Perspective The University generally certifies its enrollment reports through rosters provided to the NSC. Of the forty(40) students with enrollment changes we selected for test work, we noted three students whose changes in enrollment status were not timely or accurately transmitted to NSLDS, as follows: ? For two students, the University was notified of each student?s enrollment status change from full-time to withdrawn in May 2020, as each student was either short credits to graduate or was pending grading of spring 2020 semester courses. Accordingly, their status changes should have been transmitted after the spring semester, within 60 days being notified of the changes. However, the University did not report the students as withdrawn until the submission of the fall 2020 enrollment roster, 135 days following notification of the status changes. ? For one student, the University was notified of the student?s status change from full-time to graduated in May 2020, when the student graduated with a dual degree. Accordingly, the status change should have been transmitted after the spring semester, within 60 days of being notified of the change. However, the University did not report status change until the submission of the fall 2020 enrollment roster, 135 days following notification of the change in status. In addition, the status change was reported to NSLDS as withdrawn instead of graduated due to reporting issues from NSC to NSLDS for dual-degree students. Possible Cause and Effect The University?s internal control processes did not operate consistently to ensure that all enrollment status changes are submitted timely and accurately to NSLDS. Possible Asserted Effect Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government?s payment of interest subsidies. Questioned Costs No questioned costs were identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding This was not a finding in the prior year. Recommendation We recommend that the University review its process to ensure that any enrollment changes are reported within the required 30 or 60 day time frame. The University should work with NSC as needed to ensure proper protocols of transmission to NSLDS occur. Additionally, a review of the submitted enrollment changes to the NSLDS should be performed to ensure current student status is properly reflected. View of University Officials Representing Enrollment and Student Administration (ENSA), the University?s Registrar met with NSC staff, to discuss the cause of any delays in updating student loan records for Boston University students at NSLDS, and to identify the steps NSC can take to resolve issues identified, to ensure that student status updates, including withdrawals and graduations, are recorded timely at NSLDS. NSC acknowledged that the NSC had changed their process and that the modified system used to complete the Student Status Confirmation Report for NSLDS did not work for data submitted from legacy student information systems. They volunteered to make the updates from a new file that ENSA staff will update and send each graduation cycle until Boston University transitions to Campus Solutions. The University will also request information about the internal controls in place to ensure the completeness and accuracy of the updates provided by the University in NSC?s records and at NSLDS, and how the NSC tests the effectiveness of these controls. ENSA will continue to work with the University?s internal audit function, to determine the best way to review these control environments periodically, to ensure they are continuing to function.