University of Saint Joseph

Finding No. 2022-001 ? Enrollment reporting Federal Agency: U.S. Department of Education (DOE) Program: Student Financial Assistance Cluster ? Federal Direct Loan Program: ALN: 84.268, Federal Pell Grant Program: ALN: 84.063 Criteria: Institutions are required to report enrollment information under the Pell grant, Direct Loan, and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment 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. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS web site, certifying through the NSLDS?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: The University generally certifies its enrollment information through rosters provided to the NSC. Of the 40 students with enrollment changes that we selected for test work, we identified 1 student whose change in enrollment status was not timely and accurately transmitted to NSLDS. The University was notified of the student?s enrollment status change from full-time to ?Graduated? in February 2022. Accordingly, the students? status changes should have been transmitted after the semester to report both Campus Level and Program Level enrollment status as ?Graduated.? However, in submitting enrollment information through rosters provided to the NSC, both Campus Level and Program Level statuses were reported as ?Withdrawn.? Questioned Costs: None. Prevalence: Identified in 1 out of 40 students tested. Management evaluated the impacted enrollment roster noting that 64 students ?Graduated? status was not applied and they are improperly reported as ?Withdrawn.? The sample was not intended to be, and was not, a statistically valid sample. Effect: Inaccurate submission of student enrollment status information could affect the determinations that lenders and servicers of students? loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government?s payment of interest subsidies. As the University reported these students as withdrawn prior to reporting as graduated, the students loan subsidy and repayments schedules were not impacted. Cause: The University?s internal control processes did not operate consistently to ensure that all enrollment information, including status changes, were submitted accurately to NSLDS. When the February 2022 graduation roster was submitted to the NSC certain records were not applied as there was a mismatch in the information provided. An error file was received by the University, but the corrections were not made. Recommendation: We recommend that the University review its processes and internal controls to ensure that all enrollment information and status changes are reported completely, accurately, and in a timely manner. Additionally, we recommend a review of the submitted enrollment data to the NSLDS be performed to ensure current student information and status is properly reflected. View of Responsible Officials and Planned Corrective Actions: Management agrees with the finding, and corrective measures are being made.

Finding No. 2022-001 ? Enrollment Reporting The University is in the process of correcting the 64 students that were identified as withdrawn instead of graduated. The University is reviewing the data submitted for the May, July and August 2022 conferral dates for the same issue. It should be noted the NSLDS system cannot be updated at this time which is beyond the control of the University. The University has experienced turnover in the Registrar?s Office and will provide additional training to all staff to ensure the reporting requirements are fully understood. The University will review its processes and internal controls as recommended above and make revisions as needed. Sharon Brewer, Interim Registrar, and Michelle Kalis, Provost will be responsible for the implementation of the above process review and implementation of process enhancements, if any, as well as training all appropriate staff within the Registrar?s Office. This work will be completed no later than December 31, 2022. Sharon Brewer, Interim Registrar, will be responsible for ensuring NSLDS is updated within two weeks of the system accepting updates.

Finding No. 2022-002 ? Title IV Credit Balances Federal Agency: U.S. Department of Education (DOE) Program: Student Financial Assistance Cluster ? Federal Direct Loan Program: ALN: 84.268 Criteria: A Title IV credit balance must be paid directly to the student or parent as soon as possible but no later than (i) 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period (34 CFR 668.164(h)(2)). Condition: Of the 40 students with credit balances that we selected for test work, we identified 1 student whose credit balance was paid to the student 15 days after the credit balance was created. Questioned Costs: None. Prevalence: Identified in 1 out of 40 students tested. The sample was not intended to be, and was not, a statistically valid sample. Effect: Returning funds in a timely manner is one of the factors examined by the Department in evaluating a school?s financial responsibility. Cause: The University had new staff in the accounting department who misinterpreted the applicable guidance. One of the days within the 15-day period was a banking holiday and was not included in the day count. Recommendation: We recommend that the University review its processes around Title IV credit balances to ensure they are returned to students as soon as possible but no later than 14 days after the credit balance is generated. View of Responsible Officials and Planned Corrective Actions: Management agrees with the finding, and corrective measures are being made.

Finding No. 2022-002 - Title IV Credit Balances The missing of the fourteen-day deadline by one day was an outlier caused by new staff lacking an understanding of how to calculate the timeframe when a holiday is involved. All staff involved in the refund process have been retrained in the regulations that must be followed. Rogen Miller, Bursar, is responsible for this corrective action plan which has been implemented.

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2016-001

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2015-001

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