The New School

2021 001 Significant Deficiency and Noncompliance: Enrollment Reporting Federal Program Student Financial Assistance Cluster: Federal Pell Grant Program ALN 84.063 Federal Direct Student Loans, ALN 84.268 Federal Agency U.S. Department of Education Federal Award Year: July 1, 2020 to June 30, 2021 Statistically valid sample: No and it was not intended to be. Criteria In accordance with 34 CFR Section 685.309 and 690.83, under the Pell grant and Department of Education (ED) loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file [formerly the Student Status Confirmation Report (SSCR)] placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by ED via National Student Loan Data System (NSLDS). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. A student?s enrollment status determines eligibility for in school status, deferment, and grace periods, as well as for the payment of interest subsidies to the Federal Family Education Loan (FFEL) Program loan holders by ED. Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence. Further, the non Federal entity must establish and maintain an 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 (2 CFR 200.303). Condition and Context We tested a sample of 40 students whose status changed, including students who graduated, withdrew or went on an approved leave of absence. For 4 students in our sample who graduated during fiscal 2021, the university did not report the status change to the NSLDS within the required 60 days. The submissions for the four students were done 63, 117, 119 and 191 days after the university became aware of the students? change in status. Cause and Effect/Potential Effect The university uses a third party service provider to report enrollment information to the NSLDS. The service provider reviews the enrollment information submitted by the university and provides error reports for among other things, inconsistent enrollment data. The sampled students were captured in an error report; however, the individual responsible for reporting the enrollment status for graduates did not review the error report, correct the error and resubmit to the third party servicer in a timely manner. Questioned Costs There are no known questioned costs related to this finding. Repeat Finding This finding is a repeat of a finding in the immediately prior audit and the prior year finding number was 2020 002. Recommendation We recommend that the university reinforces its policies and procedures to ensure persons responsible for monitoring exception reports from the service provider, review these reports to ensure compliance with the requirement of submitting accurate and complete enrollment reports in a timely manner. We also recommend that management perform a formal review of enrollment reports to ensure the information is complete and accurate prior to submission to NSLDS.

2020 001 Significant Deficiency and Noncompliance: Reporting Federal Program Student Financial Assistance Cluster: Federal Pell Grant Program CFDA 84.063 Federal Agency U.S. Department of Education Federal Award Year: July 1, 2019 to June 30, 2020 Statistically valid sample: No and it was not intended to be. Criteria Schools submit Pell origination records and disbursement records to the Common Origination and Disbursement (COD). Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. A school follows up with a disbursement record for that student no earlier than (1) 7 calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 payment methods (see Department of Education (ED) Notice, June 27, 2017, Federal Register (82 FR 29061). 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 school. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student payment data within 15 calendar days after the school makes a payment or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Schools may do this by reporting once every 15 calendar days, bi weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition and Context We tested a sample of 40 students who received federal Pell grants in fiscal 2020. For 13 students in the sample, reporting to the COD were not performed within the required 15 calendar days. Cause and Effect/Potential Effect The university?s system used to transmit disbursement information experienced difficulties which caused it to go offline intermittently and prevented the reporting to COD accurately and on a timely basis. The university?s system of internal controls, although established, did not operate effectively to ensure compliance. Questioned Costs There are no known questioned costs related to this finding. Repeat Finding This finding is a repeat of a finding in the immediately prior audit and the prior year finding number was 2019 001. Recommendation We recommend that management review its current policies and procedures as it relates to reporting disbursements to the COD and incorporate a manual control to review that system transmissions are completed as scheduled and that the information transmitted is accurate. To ensure compliance with the 15 calendar day requirement for submission of disbursement information to COD, we recommend that management implement a more frequent reconciliation to ensure the submission are not only timely but also accurate.

2020 002 Significant Deficiency and Noncompliance: Enrollment Reporting Federal Program Student Financial Assistance Cluster: Federal Pell Grant Program CFDA 84.063 Federal Direct Student Loans, CFDA No. 84.268 Federal Agency U.S. Department of Education Federal Award Year: July 1, 2019 to June 30, 2020 Statistically valid sample: No and it was not intended to be. Criteria In accordance with 34 CFR Section 685.309 and 690.83, under the Pell grant and Department of Education (ED) loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file [formerly the Student Status Confirmation Report (SSCR)] placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by ED via National Student Loan Data System (NSLDS). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. A student?s enrollment status determines eligibility for in school status, deferment, and grace periods, as well as for the payment of interest subsidies to the Federal Family Education Loan (FFEL) Program loan holders by ED. Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence. Further, the non Federal entity must establish and maintain an 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 (2 CFR 200.303). Condition and Context We tested a sample of 40 students whose status changed, including students who graduated, withdrew or went on an approved leave of absence. For 2 students in our sample who graduated in May 2020, the university did not report the status change to the NSLDS. Cause and Effect/Potential Effect The university uses a third party service provider to report enrollment information to the NSLDS. The service provider reviews the enrollment information submitted by the university and provides error reports for among other things, inconsistent enrollment data. The sampled students were captured in an error report; however, the individual responsible for reporting the enrollment status for graduates did not review the error report, correct the error and resubmit to the third party servicer until it was identified during the audit. The university subsequently updated and reported the correct status of the students. However, the reporting was 221 days after the required 60 calendar day requirement. Questioned Costs There are no known questioned costs related to this finding. Repeat Finding This finding is not a repeat of a finding in the immediately prior audit Recommendation We recommend that the university reinforces its policies and procedures to ensure persons responsible for monitoring exception reports from the service provider, review these reports to ensure compliance with the requirement of submitting accurate and complete enrollment reports in a timely manner. We also recommend that management perform a formal review of enrollment reports to ensure the information is complete and accurate prior to submission to NSLDS.

2019 001 Significant Deficiency and Noncompliance: Reporting Federal Program Student Financial Assistance Cluster: Federal Pell Grant Program CFDA 84.063 Federal Agency U.S. Department of Education Federal Award Year: July 1, 2018 to June 30, 2019 Statistically valid sample: No and it was not intended to be Criteria Schools submit Pell origination records and disbursement records to the Common Origination and Disbursement (COD). Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. A school follows up with a disbursement record for that student no earlier than (1) 7 calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 payment methods (see Department of Education (ED) Notice, June 27, 2017, Federal Register (82 FR 29061). 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 school. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student payment data within 15 calendar days after the school makes a payment or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Schools may do this by reporting once every 15 calendar days, bi weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition and Context We tested a sample of 40 students who received federal Pell grants in fiscal 2019. For 6 students in the sample, reporting to the COD were not performed within the required 15 calendar days. We noted that the monthly reconciliation which is the university?s internal control to ensure its records matches the COD did not operate effectively in fiscal 2019. Cause and Effect/Potential Effect The university?s system used to transmit disbursement information experienced difficulties which caused it to go offline intermittently and prevented the reporting to COD accurately and on a timely basis. The university?s system of internal controls, although established, did not operate effectively to ensure compliance. Questioned Costs There are no known questioned costs related to this finding. Recommendation We recommend that management review its current policies and procedures as it relates to reporting disbursements to the COD and incorporate a manual control to review that system transmissions are completed as scheduled and that the information transmitted is accurate. To ensure compliance with the 15 calendar day requirement for submission of disbursement information to COD, we recommend that management implement a more frequent reconciliation to ensure the submission are not only timely but also accurate. Additionally, we recommend that the reconciliation is reviewed by someone in a supervisory role and the review is documented.

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION