Marymount Manhattan CollegeHigher Education

Finding 2024-001 - Special Tests and Provisions - Enrollment Reporting (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Loan Program (84.268) Federal Award Year: 2023-2024 Criteria: Under the Federal Pell Grant and William D. Ford Federal Direct Loan (“Direct Loan”) programs, institutions are required to report enrollment information via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035). 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 NSLDS Professional Access (“NSLDSFAP”) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus-Level” and “Program-Level,” both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. When a Direct Loan is made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceases to be enrolled on at least a half- time basis or fails to enroll on at least a half-time basis for the period for which the loan is intended, or a student who is enrolled at the institution and who receives a loan under Title IV has changes 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). Enrollment information is used to determine the borrower’s eligibility for in-school status, deferment, interest subsidy, and grace period. Enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported. The enrollment information is merged into the NSLDS database and reported to guarantors, lenders, and servicers of student loans. Context: The College distributes Direct Loans and Pell grants to students and is thus required to report the Campus-Level and Program-Level enrollment information of these students to NSLDS both timely and accurately. Condition: We identified the following instances of noncompliance from a selection of eighteen (18) graduated students and two (2) withdrawn students selected for enrollment reporting testing. In total, the instances of noncompliance pertained to five (5) students selected. • One (1) student whose CIP code for one program and whose program begin date for a second program were reported inaccurately. Additionally, the College could not provide supporting documentation for the program begin date of the first program; • One (1) student whose published program lengths for two programs and program begin date for one program were reported inaccurately; and • Three (3) students whose program begin dates were reported inaccurately. Cause: The College believes the current software product used has system limitations that are hindering its ability to extract the necessary information for uploading to the National Student Clearinghouse (“NSC”), who in turn transmits the information to NSLDS. Effect: The College did not accurately report published program lengths for one (1) student, program begin dates for five (5) students, and a CIP code for one (1) student. Additionally, the College could not provide supporting documentation for one (1) student’s program begin date. Questioned Costs: None noted. Identified as a Repeat Finding: Yes. Recommendation: The College should strengthen policies and procedures to ensure that Program-Level enrollment information is reviewed and submitted accurately to NSLDS.

Finding 2023-001 - Special Tests and Provisions - Enrollment Reporting (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Loan Program (84.268) Federal Award Year: 2022-2023 Criteria: Under the Federal Pell Grant Program and U.S. Department of Education (“ED”) loan programs, institutions are required to report enrollment information via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035). 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 NSLDS Professional Access (“NSLDSFAP”) website. There are two categories of enrollment information, “Campus-Level” and “Program-Level,” both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. 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 the 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 (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Enrollment information is used to determine the borrower’s eligibility for in-school status, deferment, interest subsidy, and grace period. Enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported. The enrollment information is merged into the NSLDS database and reported to guarantors, lenders, and servicers of student loans. Context: The College distributes Direct Loans and Pell grants to students and is thus required to report the Campus-Level and Program-Level enrollment information of these students to NSLDS both timely and accurately. Condition: We identified the following instances of noncompliance from a selection of twelve (12) graduated students and one (1) withdrawn student selected for enrollment reporting testing: • Three (3) students whose published program lengths were reported incorrectly; and • Eight (8) students with program begin dates for which the College could not provide supporting documentation. Cause: Based on discussions with management, the College experienced staffing changes in the Office of Academic Advisement. Effect: The College did not accurately report published program lengths for three (3) students tested and could not provide supporting documentation for program begin dates for eight (8) students tested. Questioned Costs: None noted Identified as a Repeat Finding: Yes Recommendation: The College should strengthen policies and procedures to ensure that Program-Level enrollment information is reviewed and submitted accurately to NSLDS.

Finding 2022-003 - Special Tests and Provisions - Enrollment Reporting (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Loan Program (84.268) Federal Award Year: 2021-2022 Criteria: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (?NSLDS?) (OMB No. 1845-0035). 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 NSLDS Professional Access (?NSLDSFAP?) website. There are two categories of enrollment information, ?Campus-Level? and ?Program-Level,? both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. 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 the 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 (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Enrollment information is used to determine the borrower?s eligibility for in-school status, deferment, interest subsidy, and grace period. Enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported. The enrollment information is merged into the NSLDS database and reported to guarantors, lenders, and servicers of student loans. Context: The College distributes Direct Loans and Pell grants to students and is thus required to report the Campus-Level and Program-Level enrollment information of these students to NSLDS both timely and accurately. Condition: We identified the following instances of noncompliance from a selection of sixteen (16) graduated students and four (4) withdrawn students selected for enrollment reporting testing: ? Nine (9) students with program begin dates for which the College could not provide supporting documentation; and ? Two (2) students whose published program lengths were reported incorrectly. Cause: Based on discussions with management, the College experienced staffing changes in the Office of Academic Advisement, as well as unforeseen challenges to record retention, including flooding in the area in which student records were stored. Effect: The College did not accurately report published program length for two (2) students tested and could not provide supporting documentation for program begin dates for nine (9) students tested. Questioned Costs: None noted Identified as a Repeat Finding: No Recommendation: The College should strengthen policies and procedures to ensure that Program-Level enrollment information is reviewed and submitted accurately to NSLDS.