Rochester Institute of Techology

2023-001 - Non-Compliance with Timely Student Enrollment Change Submissions to the National Student Loan Data System (NSLDS) Grantor: U.S. Department of Education Program Name: Student Financial Assistance Cluster Award Names: Federal Pell Grant Program and Federal Direct Loan Program Award Year: 7/1/2022 - 6/30/2023 Award Number: Not applicable Assistance Listing Numbers: 84.063 and 84.268 Criteria: In accordance with 34 CFR 690.83(b)(2) and 685.309, institutions are required to report enrollment information under the Federal Pell Grant and Federal Direct Loan programs through the NSLDS. The enrollment information, inclusive of Campus Level and Program Level data, must be reviewed, updated and validated by the institution in a timely manner. Furthermore, specific to the Federal Direct Loan program, for a student who received a Direct Loan and was enrolled or accepted for enrollment at the institution, and the student had 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 institution must report the change within 60 days from which the change was identified. Condition: We reviewed a sample of twenty-five students enrolled at the University who received either Pell and/or Direct Loans and had a change of enrollment status during the periods of time July 1, 2022 through July 18, 2022 and March 1, 2023 through June 30, 2023 of the fiscal year. Of the twenty-five students tested, nine students were not reported within the 60-day reporting timeframe. For seven of the students tested, the change in enrollment was reported to the NSLDS between 87 and 161 days from the date the change was identified. For two of the students tested, the change in enrollment was reported to the National Student Clearinghouse (NSC) for upload to the NSLDS however the student status has not yet been updated within the NSLDS records. Cause: There were three causes identified from the condition:  For four students, who each changed status during the spring semester and were not planning on returning in the fall semester, the University identified student status changes at the end of the spring semester, however waited until the beginning of the fall semester to communicate these changes to the NSC through their fall enrollment data submission rather than manually communicating them to the NSC upon identification;  For three students, who were each subject to a late degree certification, the University’s internal verification process was not adequately designed to meet the NSC’s two-step verification process to ensure that graduation status was timely updated to the NSC; and  For two students, the student status changes were timely reported to the NSC, however were not reported by NSC to the NSLDS. The University does not have an internal process in place to verify all student status changes communicated to the NSC are completely, accurately and timely communicated to the NSLDS. Effect: A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies all of which are impacted by late reporting. Recommendation: We recommend the University perform the following:  Increase the frequency in which it reports enrollment updates to the NSC throughout the summer semester to allow for enrollment changes to be received by the NSLDS in a timely manner;  Enhance the University’s degree verification process for late certifications to include the two steps now required by the NSC which will ensure the status change of all graduates are timely communicated to the NSC and ultimately reported to the NSLDS; and  Implement a periodic reconciliation process between the NSC and the NSLDS to verify that the NSLDS timely and completely received communication of all student status changes. Additionally, the University should discuss this matter with the NSC and the NSLDS to understand why the student status changes were not communicated to the NSLDS and determine if additional action can be taken by the University to ensure these status changes are updated.

Management Response and Corrective Action Plan OMB Uniform Guidance Audit for the fiscal year ended June 30, 2023 Finding 2023-001 - Non-Compliance with Timely Student Enrollment Change Submissions to the National Student Loan Data System (NSLDS) Management agrees with the finding and in concurrence with the recommendations has developed and is implementing the following corrective action plans: 1. RIT will implement a process for students who are not expected to return in the fall semester and were enrolled in spring to update the enrollment status with the NSC, the third party that reports to the NSLDS for the University. The manual update to the NSC will be completed within 30 days from the date that RIT is notified that the student is confirmed to no longer be expected to return in the upcoming fall semester. This process will be implemented for the start of summer term 2024. 2. As of November 1, 2023, RIT has enhanced its degree certification process for late certifications to include the two steps which are now required by the NSC. RIT has also added to this process an additional verification to validate that the degree record is subsequently and correctly updated with the NSLDS. 3. The University has communicated with the helpdesk at the NSLDS to determine the reasons why the two identified records for which the student status changes were timely reported to the NSC; however, the data was not correctly captured by the NSLDS. The NSLDS has not been able to identify the root cause of the issue and are continuing to research the problem. They indicate that there is nothing that RIT can do to update these records at this time. Management concurs with the recommendation and will implement a periodic reconciliation processes between the NSLDS and the NSC to verify that the NSLDS timely and completely received communication of student changes. This will include a confirmation process for manual transactions with the NSC to ensure they were received by the NSLDS, which will begin January 2024. Responsible Individual: Joseph Loffredo, Associate Vice President for Academic Affairs & Registrar

2021-001 - Non-Compliance with Timely and Accurate Student Enrollment Change Submissions to the National Student Loan Data System (NSLDS) Grantor: U.S. Department of Education Program Name: Student Financial Assistance Cluster Award Names: Federal Pell Grant Program and Federal Direct Loan Program Award Year: 7/1/2020 - 6/30/2021 Award Number: Not applicable Assistance Listing Numbers: 84.063 and 84.268 Criteria: In accordance with 34 CFR 690.83(b)(2) and 685.309, institutions are required to report enrollment information under the Federal Pell Grant and Federal Direct Loan programs through NSLDS. The enrollment information, inclusive of Campus Level and Program Level data, must be reviewed, updated and validated by the institution in a timely manner. Furthermore, specific to the Federal Direct Loan program, for a student that received a Direct Loan and was enrolled or accepted for enrollment at the institution, and the student had 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 institution must report the change within 60 days from which the change was identified. Condition: We reviewed a sample of twenty-five students enrolled at the University who received either Pell and/or Direct Loans and had a change of enrollment status during the fiscal year. Of the twenty-five students tested, one student was reported to NSLDS untimely with an inaccurate enrollment change effective date, one student was reported to NSLDS untimely with an inaccurate enrollment status, and four students were reported to NSLDS accurately but untimely. Of the four students reported accurately, the change in enrollment was reported to NSLDS between 63 and 77 days from the date the change was identified. Questioned Costs: None Cause: There were three causes identified from the condition: ? For the one student who was reported with an untimely inaccurate enrollment change effective date, the academic advisor responsible for managing the student?s enrollment change did not notify the Registrar?s Office in a timely manner nor with the accurate effective date of the student enrollment change. As such, the student enrollment change was not reported to NSLDS accurately or in a timely manner. This was considered a singular isolated incident where the University?s existing policy was not followed. ? For the one student who was reported untimely with an inaccurate enrollment status, the student had not properly appeared on the subsequent enrollment report noting their updated graduation status. As the student was not enrolled in future terms, their status was updated to ?withdrawn? instead of being reported as graduated. This was driven by the University?s reliance on the existing enrollment roster data, that did not accurately capture the student?s graduation status, that was submitted to the National Student Clearinghouse (NSC). NSC is the University?s third-party servicer that processes enrollment rosters to NSLDS on a monthly basis. ? For the four students who were reported accurately but untimely, student enrollment changes were identified just subsequent to the University?s scheduled reporting to the NSC. Given the timing between the University reporting to NSC and NSC reporting to NSLDS, student status changes were not reported within 60 days. Rochester Institute of Technology Schedule of Findings and Questioned Costs For the fiscal year ended June 30, 2021 52 Effect: A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies all of which are impacted by inaccurate and late reporting. Recommendation: We recommend the University perform the following: ? Ensure all individuals involved in processing student enrollment changes are aware of the University?s policies and procedures to process that change accurately and timely; ? Update the data included in the roster detail that is submitted to NSC and ultimately to NSLDS to ensure enrollment reporting changes are accurately reported; and ? Increase the frequency in which it reports enrollment updates to NSC in order to allow for enrollment changes to be received by NSLDS in a timely manner.

Finding 2021-001 - Non-Compliance with Timely and Accurate Student Enrollment Change Submissions to the National Student Loan Data System (NSLDS) Management agrees with the finding and in concurrence with the recommendations has developed and is implementing the following corrective action plans: ? With regard to the isolated student who was reported with an untimely enrollment change and effective date, we agree the academic advisor responsible for managing the student?s enrollment change did not notify the Registrar?s Office in a timely manner. The University will reinforce the critical importance of timely reporting of all university withdrawals and leave of absences by reminding the community with an updated announcement about these processes and critical timelines. A communication will be distributed this semester (Spring 2021-22) and an ongoing announcement will be made each semester thereafter. Further, we will update, revise and deliver training for advisors and academic leadership about the withdrawal and leave of absence processes. These trainings will be in place no later than summer 2022. In addition, the University is procuring software that will allow the implementation of an electronic workflow system to be integrated with our Student Information System to further streamline and automate the University?s withdrawal and leave of absence processes. We expect to make a purchasing decision in the Spring 2021-22 with a target implementation date of academic year 2022-23. ? The University will update the data included in the roster detail that is submitted to National Student Clearinghouse (NSC) and ultimately to NSLDS to ensure enrollment reporting changes are accurately reported. The University implemented an upgrade in December 2021, which includes a new enrollment file created within our Student Information System to allow for accurate graduated student reporting via the NSC enrollment file directly. This new file has been run on all of 2020-2021 degrees and will be used on 2021-2022 degrees and going forward. * The University will increase the frequency in which RIT reports enrollment updates to NSC in order to allow for enrollment changes to be received by NSLDS in a timely manner. The Registrar's Office, after in-depth conversations with NSC and their Audit Resource team, has agreed to run NSC enrollment files every 30 days within a term. Due to NSLDS getting data from NSC at the beginning of the month, RIT will provide the data to NSC between the 15th and the 25th of each month to ensure the enrollments are recorded prior to the NSLDS data pull. For Spring 2021-2022 the following schedule will be implemented: a. Early- Certified on 1/11/22 b. First ofTerm - Certified on 1/18/22 c. Subsequent- Certified on 2/17/22 d. Subsequent- Certified on 3/17/22 e. Subsequent - Certified on 4/18/22 f. End of Term - Certified on 5/4/22 Similar schedules will be used for each term going forward. Responsible Individual: Joseph Loffredo, Associate Vice President for Academic Affairs & Registrar

2019 - 001 ? Non-Compliance with Eligibility Requirements Grantor: U.S. Department of Education Program Name: Trio Cluster Award Name: McNair Post Baccalaureate Achievement Award Year: Fiscal Year 2019 Award Number: P217A170242 CFDA Number: 84.217 Criteria: Per CFR 647.32(a)(1), ?A grantee shall determine the eligibility of each student before the student is selected to participate.? Further, in accordance with CFR 647.32(b), ?For each student, a grantee shall maintain a record of - (1) The basis for the grantee?s determination that the student is eligible to participate in the project...? Condition: We reviewed a sample of 13 participants in the McNair program to verify eligibility during the fiscal year. We found that the Unviersity did not maintain documentation evidencing there was a control process in place to verify the eligibility of the participants prior to acceptance into the program for the 13 program participants selected. However, we also found that all 13 program participants selected met the elgibility requirements. Questioned Costs: None Cause: Individuals involved in the process did not maintain documentation evidencing that management verified participant eligibility prior to acceptance into the program. Effect: Program participants accepted into the program may be ineligible and the University may not be able to demonstrate eligibility of the participants. Recommendation: The University should ensure that all individuals involved in the process are aware that documentation is required to be maintained to support the University?s process of verifying program participant eligibility prior to acceptance. Management?s Response: Management?s views and corrective action plan is included at the end of this report.

Rochester Institute of Technology Management?s Corrective Action Plan Uniform Guidance Audit for the year ending June 30, 2019 Finding 2019-001: Management concurs with the recommendation. In response to the audit finding, all individuals administering the McNair program have been made aware of the requirements to maintain documentation to verify eligibility of each participant. In December 2019, the University developed and implemented a checklist that will serve as supporting documentation for the process of verifying program eligibility prior to acceptance and will be included in each participant?s file. Additionally, in December 2019, all students currently in the program were reviewed and found to be eligible to participate and the checklist has been completed, reviewed and retained within each file. Responsible Official: Lyn S. Kelly, Controller & Assistant Treasurer

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