Manhattanville UniversityHigher Education

Finding 2021-001 Special Tests and Provisions ? Enrollment Reporting Compliance and Internal Control (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Student Loans (ALN 84.268) Federal Award Number: P268K211861 Federal Pell Grant Program (ALN 84.063) Federal Award Number: P063P201861 Federal Award Year: 2020-2021 Criteria: Under the Federal Pell Grant Program and U.S. Department of Education (?ED?) loan programs, institutions are required to report student 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 website. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS maintains as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Required program-level data includes, but is not limited to: ? Program enrollment status; ? Program enrollment effective date; ? Program begin date; ? Published program length and measurement; and, ? Classification of Instructional Program (?CIP?) code. Context and Condition: From a selection of forty (40) students tested, we identified the following instances of noncompliance: 1) For 13 students, the program begin dates that were reported to the NSLDS did not reflect the first day of the earliest semester in which such students began attending the respective programs being reported. Cause: Due to the manner in which the College?s enrollment and financial aid system has been programmed to report such information, the identified students? program begin dates were inaccurately reported to the NSLDS. Effect: The program begin dates for thirteen (13) students were not properly reported to the NSLDS. Questioned Costs: None identified. Identified as a Repeat Finding: Yes. Recommendation: The College should implement procedures to ensure that students? program-level enrollment reporting data, such as the program begin date, are reported to the NSLDS accurately and in accordance with the NSLDS Enrollment Guide. Views of Responsible Officials: The College made changes in its processes on a go-forward basis in the fall of 2021 after the issue was identified during the June 30, 2020 audit. The College is seeking guidance from NSLDS to verify whether the data can and should be identified and remedied on a look-back period from the fall of 2021 to the start date of any continuing students so the issues will not reoccur. If it is determined by NSLDS that the data should be remedied on a look-back period, we will seek guidance from our third-party software provider.

Finding 2021-002 Reporting Compliance and Internal Control (Significant Deficiency) U.S. Department of Education ? Education Stabilization Fund (Assistance Listing Number 84.425E ? HEERF Student Aid Portion and 84.425F ? HEERF Institutional Portion) Federal Award Year: 2020-2021 Criteria: Per the sections CARES Act 18004(e) and the CRRSAA 341(e), there are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as appliable; and 3) the annual report. For Institutional Portion reporting, a new, separate, accurate form must be posted covering aggregate amounts spent for HEERF I, HEERF II, and HEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30). Institutions of higher education must post this quarterly report form no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, July 10) apart from the first report, which was due October 30, 2020, and the report covering the first quarter of 2021, which is due July 10, 2021. For CARES Act Student Aid Portion reporting, beginning on May 6, 2020, institutions that received a HEERF I Section 8004(a)(1) Student Aid Portion award were required to publicly post certain information on their website no later than 30 days after the award, and update that information every 45 days thereafter (by posting a new report). On August 31, 2020, ED revised the electronic announcement (?EA?) by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. On May 13, 2021, ED published an additional notice for student aid public reporting under the Coronavirus Response and Relief Supplemental Appropriations Act of 2021 (?CRRSAA?) and the American Rescue Plan Act of 2021 (?ARP?), which requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). Context and Condition: From a selection of three (3) Institutional Portion quarterly reports and one (1) Student Aid Portion quarterly report tested, we identified the following instances of noncompliance: 1) For one (1) Institutional Portion quarterly report, management did not post the report timely in accordance with the requirement of the Uniform Guidance. 2) For one (1) Student Aid Portion quarterly report, management was not able to provide evidence noting that this report was posted timely to the College?s public website. Cause: As a result of updates regarding the requirements of posting public reporting of HEERF funding, management did not maintain evidence to would allow the College to support the accuracy or timeliness of the required information posted to the website. Effect: Management is not able to support the accuracy or timeliness of the information previously posted on its website. Questioned Costs: None identified. Identified as a Repeat Finding: No. Recommendation: We recommend that the College maintain hard copy or electronic records of the information posted on its website as required by the Department of Education. Views of Responsible Officials: Management agrees with the findings noted above and is instituting practices to implement the recommendations noted.

Finding 2020-002 Special Tests and Provisions ? Enrollment Reporting Compliance and Internal Control (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Student Loans (ALN 84.268) Federal Award Number: P268K201861 Federal Pell Grant Program (ALN 84.063) Federal Award Number: P063P191861 Federal Award Year: 2019-2020 Criteria: Under the Federal Pell Grant Program and U.S. Department of Education (?ED?) loan programs, institutions are required to report student 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 website. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS maintains as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Required program-level data includes, but is not limited to: ? Program enrollment status; ? Program enrollment effective date; ? Program begin date; ? Published program length and measurement; and, ? Classification of Instructional Program (?CIP?) code. Context and Condition: From a selection of forty (40) students tested, we identified the following instances of noncompliance: 1) For five (5) students, the program begin dates that were reported to the NSLDS did not reflect the first day of the earliest semester in which such students began attending the respective programs being reported. 2) For three (3) students, the College did not report the enrollment status change to the NSLDS for students who graduated during fiscal year 2020. Cause: 1) Due to the manner in which the College?s enrollment and financial aid system has been programmed to report such information, the identified students? program begin dates were inaccurately reported to the NSLDS. 2) The NSLDS automatically removes students from enrollment reporting roster files after a school certifies a Graduated or Withdrawn status in two consecutive months. For a student who has graduated, schools that initially report a Withdrawn status must subsequently report the student as having graduated by certifying a Graduated status at the Campus-Level and/or Program-Level as appropriate. In this case, the school must add the student back to the enrollment reporting roster to report the Graduated status. The College initially reported a Withdrawn status for the identified students and did not subsequently add back the student to the enrollment roster file and report the student?s Graduated status. Effect: The program begin dates for five (5) students were not properly reported to the NSLDS. Furthermore, the Graduated enrollment status for three (3) students were not reported to the NSLDS. Questioned Costs: None identified. Identified as a Repeat Finding: No. Recommendation: The College should implement procedures to ensure that students? program-level enrollment reporting data, such as the program begin date, are reported to the NSLDS accurately and in accordance with the NSLDS Enrollment Guide. The College should also implement procedures to ensure that students for whom the College initially reported a Withdrawn status and then subsequently graduated have their Graduated statuses appropriately reported to the NSLDS. Views of Responsible Officials: Management agrees with the items noted above and is instituting practices to implement the recommendations noted.

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