Scripps CollegeHigher Education

FINDING 2021-001 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control over Compliance Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that institution but has ceased to be enrolled on at least a half-time basis. Condition/context ? A sample of 12 out of a population of approximately 109 federal aid recipient students were selected from system generated reports of students who had a reduction or increase in attendance levels, graduated, withdrew, dropped out, or enrolled but never attended during the 2020-2021 academic year. A comparison was made between each selected student?s National Student Loan Data System (NSLDS) enrollment detail to the student?s academic files and other institutional records to verify that the College was accurately reporting significant campus-level and program-level enrollment data within the required time frame. An exception was noted whereby the status change of 1 of the 12 students selected for testing was accurately reported, but not within the timeframe set out in the guidance. Questioned costs ? No questioned costs were identified as part of this finding. Effect ? Enrollment status is utilized by students, the U.S. Department of Education, 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. Cause ? The College contracts with a third-party intermediary to transmit enrollment information to NSLDS. Ultimately, the College is responsible for the accuracy and timeliness of its reporting, regardless of whether it uses a third party. For the exception noted above, the student status change was not reported within the required time frame due to the College not having effective internal controls established to prevent or detect and correct the non-compliance in a timely manner. Repeat finding ? This is not a repeat finding. Recommendation ? We recommend the College revise its policies to establish a requirement that students are reported to NSLDS within the required timeframe after withdrawing from classes. Views of responsible officials and planned corrective actions ? Management concurs with this finding. Management continues to review leave of absence functionality to ensure timely and accurate reporting when a student effects a leave of absence. The Registrar will continue to send enrollment files to the National Student Clearinghouse (NSC) twice per month and manually update if a student?s enrollment level changes in between reporting periods as a backup measure. The Registrar has updated the College?s reporting schedule to NSC to include an additional enrollment file to capture any student whose enrollment level change is reported/captured after the last day of the semester. Management believes these enhancements will be sufficient to prevent future errors.

FINDING 2021-002 ? Reporting ?Significant Deficiency in Internal Control over Compliance Criteria ? 86 FR 26213 requires Education Stabilization Fund recipients to post the Institutional Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Additionally, for each student grant disbursement made, the College is required to report quarterly to their website a summary of how the funds were allocated and disbursed. Condition/context ? For one quarter during the year ended June 30, 2021, the College did not report its required quarterly information to its website within the required timeframe. Questioned costs ? No questioned costs were identified as part of this finding. Effect or potential effect ? The required quarter report was not posted to the College?s website within the required timeframe under the conditions of the grant. Cause ? The exception occurred as a result of internal controls not being properly designed to accommodate absences of key personnel. Recommendation ? We recommend that the College continue to review guidance provided by grant agreements and establish timetables and responsible parties to complete respective compliance requirements. Views of responsible officials and planned corrective actions ? Management concurs with this finding. The late posting to the College?s website was due to the absence of key personnel, without a clear internal control designed to ensure posting in their absence. Management has recently created and filled a new position, post-award grant specialist, to oversee all compliance requirements, and will specifically be responsible for monitoring all reporting requirements. This position is establishing timetables and protocols to ensure future compliance requirements are met. Management believes these enhancements will be sufficient to prevent future errors.