Whitman College

FINDING 2021-001 Special Tests and Provisions ? Enrollment Reporting Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education CFDA Number: 84.063 Federal Program Name: Federal Pell Grant Federal Award Number: P063P195361 Award Year: 2020-21 CFDA Number: 84.268 Federal Program Name: Federal Direct Student Loans Federal Award Number: P268K205361 Award Year: 2020-21 Criteria: The National Student Loan Data System (?NSLDS?) is the Department of Education?s (?ED?) centralized database for students? enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. It is the College?s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR ? 685.309. Institutions are responsible for accurately reporting certain significant data elements under the Program-Level and Campus-Level Record that ED considers high risk, which includes the student's Enrollment Effective Date and Classification of Institutional Programs (?CIP?) Code. Condition and Context: We selected a sample of 45 students from the population of students who had received Federal aid and had withdrawn or graduated from the College during the 2020-2021 fiscal year. We compared the significant data elements under the Campus-Level and Program-Level Records that ED considers high risk as reported to NSLDS to the data included in the student's academic records, other institutional records, and the withdrawal or graduation date per the College?s records. We noted an exception with eight out of the 45 students tested (18%) when testing the student's Enrollment Effective Date and CIP Code. Five students were reported under a CIP code that is not accredited by the Northwest Commission on Colleges and Universities (?NWCCU?) and four students? enrollment effective date at either the campus-level or program-level did not agree with the College's academic records. Our sample was not, and was not intended to be, statistically valid. Questioned costs: None. Cause: This occurred because of a lack of controls and oversight of the process. Effect: This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status. NSLDS also uses the newly submitted enrollment data to recalculate a student?s 150% limit for direct subsidized loans to determine if loss or protection of the subsidy should occur. Therefore, this significant deficiency in enrollment reporting could result in incorrect future eligibility for undergraduate aid, as well as impact future subsidy loss or protection related to the 150% limit. Repeat finding: Yes. Recommendation: We recommend the College implement policies and procedures to ensure all CIP codes being used by the College are properly accredited by NWCCU. In addition, we recommend. the College implement policies and procedures to ensure all campus-level and program-level detail that ED considers high risk is accurately reported to NSLDS. Lastly, we recommend the College establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the information on NSLDS so to internally audit the National Student Clearinghouse (?NSC?) submissions not only for timeliness, but for accuracy as well. Views of responsible officials and planned corrective actions: The College agrees with the finding above. The College?s Registrar has worked with the NWCCU to update our UNDC (undeclared) CIP Code. The Registrar ran internal reports to ensure that all of the College?s CIP codes match a CIP code that the College is accredited for through the NWCCU and any errors discovered were immediately corrected in February 2022. The College has also instituted an annual meeting in May to review these CIP Codes, make changes, and assign new CIP Codes to new majors that were submitted throughout the year. These individuals include: the Registrar, Chair of the Faculty, NWCCU Accreditation Liaison, Financial Aid Director, IR Director, Curriculum Committee Chair, and IT Director. During these annual meetings, the College will run audits to ensure all programs and majors in Colleague (our SIS) are in alignment with reported CIP codes to the NWCCU. The Registrar?s Office has implemented a monthly reporting schedule to ensure timely and accurate reporting to NSLDS. In addition, the Registrar?s Office will notify the Office of Financial Aid when a report has been made to the NSC so that the Office of Financial Aid can verify that NSLDS accurately received and correctly reported the information provided to the NSC timely.

FINDING 2021-002 Special Tests and Provisions ? Enrollment Reporting Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education CFDA Number: 84.063 Federal Program Name: Federal Pell Grant Federal Award Number: P063P195361 Award Year: 2020-21 CFDA Number: 84.268 Federal Program Name: Federal Direct Student Loans Federal Award Number: P268K205361 Award Year: 2020-21 Criteria: Uniform Guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to the National Student Loan Data System (NSLDS) within at least 60 days of when the student attendance change occurs. It is the College's responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR section 685.309. Condition and Context: A sample of 45 students from the population of students who were borrowers of Federal Direct student loans and recipients of Pell Grants and had withdrawn or graduated from the College during the 2020-2021 fiscal year were selected. The enrollment information and withdrawal or graduation date per the College's records was compared to the information reported to the NSLDS. In our sample, we noted that 1 withdrawn student who was a Federal borrower was considered as withdrawn by the College, however this student's status change was not reported to NSLDS within the 60 day requirement. Our sample was not, and was not intended to be, statistically valid. Questioned costs: None. Cause: This occurred because of a lack of controls and oversight of the process. Effect: This resulted in late reporting of the information to NSLDS. The enrollment information reported to NSLDS is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status. Repeat finding: No. Recommendation: We recommend the College follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. We also recommend the College establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS to internally audit the submissions. Views of responsible officials and planned corrective actions: The College agrees with the finding above. This issue arose from high turnover in key personnel at the College during the COVID-19 pandemic. The College?s long-time Registrar retired in July of 2021 and the position was not filled with a new Registrar until September of 2021. Unfortunately, the Associate Registrar was not properly trained to ensure all tasks were completed during the transition period. Upon arrival, the new Registrar ran an NSC report, which caused the over sixty-day delay in reporting to NSLDS. The Registrar?s Office has implemented a monthly reporting schedule to ensure timely and accurate reporting to NSLDS. In addition, the Registrar?s Office will notify the Office of Financial Aid when a report has been made to the NSC so that the Office of Financial Aid can verify that NSLDS accurately received and correctly reported the information provided to the NSC timely.

FINDING 2020-001 Special Tests and Provisions ? Enrollment Reporting Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education CFDA Number: 84.063 Federal Program Name: Federal Pell Grant Federal Award Number: P063P195361 Award Year: 2019-20 CFDA Number: 84.268 Federal Program Name: Federal Direct Student Loans Federal Award Number: P268K205361 Award Year: 2019-20 Criteria: The National Student Loan Data System (?NSLDS?) is the Department of Education?s (?ED?) centralized database for students? enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. It is the College?s responsibility to update students? enrollment information timely and accurately as outlined in 34 CFR ? 685.309. Institutions are responsible for accurately reporting certain significant data elements under the Program-Level Record that ED considers high risk, which includes the student?s Program Enrollment Status. Condition and Context: A sample of 39 students who had received Federal aid and had withdrawn or graduated from the College during the 2019?2020 fiscal year was selected. The significant data elements under the Campus-Level and Program-Level Records that ED considers high risk as reported to NSLDS was compared to the data included in the student?s academic records, other institutional records, and the withdrawal or graduation date per the College?s records. We noted an exception with one of the 39 students selected (3%) when testing the student?s Program Enrollment Status. While this student was reported as graduated timely and accurately at the Campus-Level, their Program-Level enrollment status was showing as withdrawn; therefore, their conferred Bachelor's degree was not correctly reported at the Program-Level. The College has engaged the National Student Clearinghouse's (NSC) services to assist with the reporting of student's status changes and degrees to the NSLDS. Our sample was not, and was not intended to be, statistically valid. Questioned costs: None. Cause: This occurred because of lack of proper understanding of the NSC?s parameters in reporting a student?s program graduation when the student was previously reported as withdrawn. It is allowable and recommended to report a graduating student?s status as withdrawn until the degree is conferred. However, there was no internal requirement to update the student?s Program-Level information to be a "Graduated" status upon degree confer. Effect: This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status. NSLDS also uses the newly submitted enrollment data to recalculate a student?s 150% limit for direct subsidized loans to determine if loss or protection of the subsidy should occur. Therefore, this significant deficiency in enrollment reporting could result in incorrect future eligibility for undergraduate aid, as well as impact future subsidy loss or protection related to the 150% limit. Repeat finding: No. Recommendation: We recommend the College identify scenarios where student status changes can occur at the College and as a result of any newly identified scenarios, enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. The College should follow up on special cases to ensure accurate reporting. We also recommend that the roles and responsibilities surrounding this process be evaluated and, if deemed necessary, revised. Furthermore, we recommend the College further educate and train those involved in the process regarding their Enrollment Reporting compliance responsibilities and the consequences of inaccurate reporting to the NSLDS via the NSC, as well as the consequences of continued audit findings in this area. Lastly, we recommend the College establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the NSC submissions not only for timeliness, but for accuracy as well. Views of responsible officials and planned corrective actions: The student tested was enrolled for half-time in fall 2019. He then did not attend in the spring of 2020 and still had his senior assessment outstanding to complete his degree requirements. He was reported as withdrawn during this period. He completed his requirement in the spring and was awarded his degree on May 24, 2020. The student?s enrollment records were reported correctly in the National Student Clearinghouse (NSC) but that status was not transferred over to the NSLDS. The graduate status was posted on his enrollment record through the NSC at the Campus Level but did not post at the Program Level. For this reason, he did not appear as graduated in the NSLDS records but rather as withdrawn. The remediation for this is as follows: 1. The Registrar?s Office will flag all students who we report as graduated after having a previous withdrawal status to confirm that the graduate status has been posted on the program level. This is currently a very small cohort. 2. The Registrar?s Office will work with the Office of Financial Aid after each graduation date (May, September, and December) to confirm each graduate?s status in their NSLDS record to assure all program data is updated. This can be done from an NSLDS download of the appropriate graduates for a specific date. Any corrections will then be made immediately to the National Student Clearinghouse program data, which will transmit to the NSLDS.

FINDING 2020-002 Special Tests and Provisions ? Enrollment Reporting Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education CFDA Number: 84.063 Federal Program Name: Federal Pell Grant Federal Award Number: P063P195361 Award Year: 2019-20 CFDA Number: 84.268 Federal Program Name: Federal Direct Student Loans Federal Award Number: P268K205361 Award Year: 2019-20 Criteria: The National Student Loan Data System (?NSLDS?) is the Department of Education?s (?ED?) centralized database for students? enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. It is the College?s responsibility to update students? enrollment information timely and accurately as outlined in 34 CFR ? 685.309. Institutions are responsible for accurately reporting certain significant data elements under the Program-Level Record that ED considers high risk, which includes the student?s Classification of Instructional Programs (CIP) code. Condition and Context: A sample of 39 students who had received Federal aid and had withdrawn or graduated from the College during the 2019?2020 fiscal year was selected. The significant data elements under the Campus-Level and Program-Level Records that ED considers high risk as reported to NSLDS were compared to the data included in the student?s academic records, other institutional records, and the withdrawal or graduation date per the College?s records. We noted exceptions with five out of the 39 students tested (13%) when it came to the program CIP Codes that were reported to the College?s accreditation body. Whether in error or by choice because the updated CIP Code was a better fit for the program, the College reported three CIP Codes that were not accredited: 54.0101, 11.0701, and 42.0101. While these five students were reported to NSLDS as having graduated timely, their respective Program CIP codes were not reported accurately. Subsequent updates to the students? reported CIP Codes have been made by the College. The College has engaged the National Student Clearinghouse?s (NSC) services to assist with the reporting of students? status changes and degrees to the NSLDS. Our sample was not, and was not intended to be, statistically valid. Questioned costs: None. Cause: This occurred because of lack of understanding of the ramifications of changing CIP Codes internally and not understanding the impact of such changes outside of the College with respect to users of the information reported. Effect: This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status. NSLDS also uses the newly submitted enrollment data to recalculate a student?s 150% limit for direct subsidized loans to determine if loss or protection of the subsidy should occur. Therefore, this significant deficiency in enrollment reporting could result in incorrect future eligibility for undergraduate aid, as well as impact future subsidy loss or protection related to the 150% limit. Repeat finding: No. Recommendation: We recommend the College evaluate all CIP Codes currently being used and whether 1) that CIP Code is currently accredited, and 2) whether it should be changed to better reflect where the particular department is concentrating the major. If a change is warranted, a policy should be created so that the affected persons at the College and/or accrediting bodies are notified and the appropriate steps taken to ensure the change is made (and saved). We also recommend the College establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the Campus-Level and Program-Level data elements ED considers high risk so to internally audit the NSC submissions. Views of responsible officials and planned corrective actions: Classification of Instructional Programs (CIP) codes as used by the US Department of Education to ?facilitate the organization, collection, and reporting of fields of study and program completions.? The Registrar?s Office and Institutional Research have previously used a shared CIP code spreadsheet to assign the codes to major programs. It was discovered that an incorrect code had been inserted in the History major (50.0101) in Colleague (the College?s system of records). The code had been posted correctly (54.0101) when the major converted to having multiple History tracks. The College also changed the Psychology CIP code from 42.0101 to 42.2799 at the request of the Psychology Department. The new CIP code better reflected the major emphasis currently in place. The shared CIP code list with the two incorrect codes was provided to the Associate Dean of Faculty for accreditation documentation. For that reason, when the audit pulled students with History or Psychology majors, the CIP codes did not match the institutional CIP code list in Colleague. The remediation for this is as follows: 1. The College has corrected all of the errors identified on a Technology Services report of all History and Psychology majors in the National Student Clearinghouse data. 2. The College will no longer use a static CIP code list but rather, when a request for a CIP code list is received, the College will download the data from the Colleague system. 3. The Registrar?s Office staff and Director of Institutional Research have agreed to communicate any need to change CIP codes prior to making a change and document those changes. Changes will then be communicated to the Associate Dean of Faculty for accreditation. 4. Technology Services has added an audit to the CIP code field in Colleague so the College is alerted when a change is made and it is documented.

Finding 2019-001 Special Tests and Provisions - Enrollment Reporting - Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education CFDA Number: 84.268 Federal Program Name: Federal Direct Student Loans Award Year: 2018-19 Criteria: The National Student Loan Data System (NSLDS) is the Department of Education?s (ED) centralized database for students? enrollment information. It is the College?s responsibility to update this information timely and accurately. The College determines how often it receives the Enrollment Reporting roster file with the default set at every 60 days. Under the loan programs, schools must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by ED via NSLDS. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis (34 CFR section 685.309). The College has engaged the National Student Clearinghouse's (NSC) services to assist with the reporting of student's status changes and degrees to the NSLDS. Condition and context: A sample of students who were borrowers of Federal Direct student loans or Federal Perkins loans and had graduated from the College during the 2018-19 fiscal year was selected. The enrollment information and graduation date per the College?s records was compared to the information reported to the NSLDS. In our sample, we noted that 4 graduates who were Federal borrowers were considered graduated by the College, however, their NSLDS Enrollment Detail report did not show the graduated status. These students had their degrees conferred by the College and were considered to be ?G Not Applied? errors on the NSC's Degree Reporting page. The College did not correct these, and 34 other "G Not Applied" errors and therefore, their degrees were not verified/posted through the NSC, nor was their enrollment status updated to show them as ?graduated?. The College Registrar was not aware that there were ?G Not Applied? errors needing to be addressed in order to apply the student?s degree and update the student's status to "Graduated" on the NSLDS. As such, this was discovered during the Single Audit and upon further investigation by the College and referred to above, there were 38 total students with "G Not Applied" errors affected. Random, not statistical, sampling was used. Questioned costs: None. Cause: This occurred because of lack of proper understanding of the NSC?s parameters in reporting graduated students' enrollment statuses as well as a lack of review of NSC graduate file submissions for accurate posting. Effect: This resulted in late reporting of the information to NSLDS. The enrollment information reported to NSLDS is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status. Repeat finding: No. Recommendation: We recommend the College follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. We also recommend a review of roles and responsibilities surrounding this process be evaluated and, if deemed necessary, revised. Furthermore, we recommend the College further educate and train those involved in the process regarding their Enrollment Reporting compliance responsibilities and the consequences of inaccurate reporting to the NSLDS via the NSC, as well as the consequences of continued audit findings in this area. Opportunities for additional NSC training in this area and others are available through the NSC?s Clearinghouse Academy page. Lastly, we recommend the College establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the NSC submissions. Views of responsible officials and planned corrective actions: The college agrees with the finding above. The college has corrected the graduate status of those 38 graduates and has successfully tested the coding which led to their omission. Going forward, the responsibility for reporting student status changes belongs solely to the registrar's office and it has incorporated this change in process into its policy. Those involved in this reporting process are aware of their responsibilities and are committed to continue training as recommended. College staff, with access to NSLDS, are committed to monitoring the registrar's reporting to ensure the status in NSLDS matches that of the student status at the college.

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