Bloomfield College of Montclair State UniversityHigher Education

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 (Federal Assistance Listing #84.268) Federal Award Number: P268K231804 Federal Pell Grant Program (Federal Assistance Listing #84.063) Federal Award Number: P063P221804 Federal Award Year: 2022-2023 Criteria and Context: Under the Pell grant and U.S. Department of Education (“ED”) direct loan programs, institutions are required to report enrollment information via the National Students Loan Data System (“NSLDS”) (OMB No.18450035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends 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 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. 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 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). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods. 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. Institutions are also 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. Condition and Sample Method: From a non-statistical sample of forty (40) students tested who graduated or withdrew during the year, we identified three (3) students whose withdrawal statuses were reported to the NSLDS more than 60 days after the students’ respective withdrawal dates (ranging from 75 to 78 days late). In addition, due to an inconsistency between the College’s and NSLDS’s approach to calculating program lengths, we identified all forty (40) students had Published Program Length Measurements and Published Program Lengths that were inaccurately reported. Cause: While the College has established policies and procedures to ensure that the required reports are accurately completed and submitted on a timely basis to the NSLDS, we noted oversight on the timely reporting for three (3) withdrawn students. This resulted in the College missing the 60-day timing requirement for NSLDS reporting and resulted in the non-compliance noted. The NSLDS Enrollment Reporting Guide provides a caution that institutions should report associate and bachelor degree programs in years and not months. When program length is reported in months or weeks, NSLDS uses this value along with the Weeks in Title IV Academic Year value to calculate a length in years. This resulted in program lengths that are shown in the NSLDS system as being longer in years than the actual program length. Effect: There is a delay in the NSLDS obtaining the required information regarding the enrollment status changes of students. The accuracy of the Published Program Length Measurement and Published Program Length in Years were inaccurately reported to the NSLDS for the forty (40) students selected for testing. Questioned Costs: None identified. Identified as a Repeat Finding: Yes. Recommendation: The College should strengthen policies and procedures to ensure that student status transmission reports are submitted accurately to the NSLDS at least every 60 days, or more often, as determined to be appropriate. The College should also ensure that student Published Program Length Measurements are listed in years and that the Published Program Lengths are calculated in years as recommended by the NSLDS Enrollment Reporting Guide so that the Published Program Length calculation is accurate to the true length of the program for each student.

Reporting - Direct Loan and Pell Common Origination and Disbursement (“COD”) Compliance and Internal Control (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Student Loans (Federal Assistance Listing #84.268) Federal Award Number: P268K231804 Federal Pell Grant Program (Federal Assistance Listing #84.063) Federal Award Number: P063P221804 Federal Award Year: 2022-2023 Criteria and Context: Pursuant to Federal Register Volume 87, Number 105, an institution must submit Pell Grant and Direct Loan disbursement records to the Common Origination and Disbursement (“COD”) system no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), Title IV program funds are disbursed on the date that the institution: (a) credits those funds to a student’s account in the institution’s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department of Education. Condition and Sample Method: From a non-statistical sample of forty (40) students selected for COD reporting testing, we identified one (1) student whose Direct Loans or Pell disbursement record was submitted to the COD more than 15 days after the award was disbursed to the student. Cause and Effect: While the College had certain procedures in place to monitor the submission of the disbursement records, such procedures were not consistently performed on a timely basis, and therefore were not adequate to ensure that each record was submitted within the required timeframe, causing the late submission of certain disbursement records. Questioned Costs: None identified. Identified as a Repeat Finding: No. Recommendation: We recommend that the College strengthen its policies and procedures to ensure that student disbursement records are submitted accurately to the COD within 15 days of disbursements being made to students’ accounts, and that the College maintain clear evidence that a secondary review is performed to verify that the submission was made timely.

Criteria: Per 34 CFR 690.83(b)(2) and 34 CFR 685.309, 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). 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 which the financial aid administrator can access for the auditor. Cause: The College?s monitoring control over enrollment reporting was not operating effectively during fiscal year 2022 as it relates to students who are unofficially withdrawing. Context: For one out of 40 samples tested, the student?s status was not accurately reflected to the NSLDS. The student unofficially withdrew from class by continuously not attending the class. However, the professor did not update the student?s status until after the end of the semester. Effect or potential effect: The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Inaccurate reporting or not timely reporting student status changes to NSLDS will have an impact on the timeliness of the student entering repayment. Recommendation: We recommend that the College enhance its review and monitoring of the enrollment reporting to NSLDS to ascertain accuracy and timeliness of the submission.

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