Audit 15539

Student Financial Assistance Cluster 84.063 Federal Pell Grant Program, 84.268 Federal Direct Student Loans U.S. Department of Education Award Year 2022/2023 Criteria or Specific Requirement – Special Tests and Provisions - Enrollment Reporting 34 CFR 685.309(b) states that upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary in the manner and format prescribed by the Secretary and within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has 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. Condition – The Institute did not submit timely notification to the National Student Loan Data System (NSLDS) of student status changes. Questioned Costs – None noted Context – Out of a population of 39 student enrollment status changes requiring notification, a sample of four student status changes was selected for testing. Out of the four selected for testing, two students that had status changes were not communicated to NSLDS on a timely basis. Both students that were not reported timely were graduates in May 2023. The sampling methodology was not intended to be a statistically valid sample. Effect – The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Cause – The Institute uses an Enrollment Reporting Servicer (Servicer) to transmit student enrollment status changes to NSLDS. The enrollment reporting file was submitted timely by the Institute to the Servicer, however, there was a delay in the submission to NSLDS from the Servicer. Ultimately the Institute has primary responsibility for timely submission of enrollment status changes to NSLDS. Recommendation – We recommend that management review this area and establish procedures to ensure student status changes are reporting timely to NSLDS. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.

Student Financial Assistance Cluster 84.063 Federal Pell Grant Program, 84.268 Federal Direct Student Loans U.S. Department of Education Award Year 2022/2023 Criteria or Specific Requirement – Special Tests and Provisions - Enrollment Reporting 34 CFR 685.309(b) states that upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary in the manner and format prescribed by the Secretary and within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has 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. Condition – The Institute did not submit timely notification to the National Student Loan Data System (NSLDS) of student status changes. Questioned Costs – None noted Context – Out of a population of 39 student enrollment status changes requiring notification, a sample of four student status changes was selected for testing. Out of the four selected for testing, two students that had status changes were not communicated to NSLDS on a timely basis. Both students that were not reported timely were graduates in May 2023. The sampling methodology was not intended to be a statistically valid sample. Effect – The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Cause – The Institute uses an Enrollment Reporting Servicer (Servicer) to transmit student enrollment status changes to NSLDS. The enrollment reporting file was submitted timely by the Institute to the Servicer, however, there was a delay in the submission to NSLDS from the Servicer. Ultimately the Institute has primary responsibility for timely submission of enrollment status changes to NSLDS. Recommendation – We recommend that management review this area and establish procedures to ensure student status changes are reporting timely to NSLDS. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.

Student Financial Assistance Cluster 84.063 Federal Pell Grant Program, 84.268 Federal Direct Student Loans U.S. Department of Education Award Year 2022/2023 Criteria or Specific Requirement – Special Tests and Provisions - Enrollment Reporting 34 CFR 685.309(b) states that upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary in the manner and format prescribed by the Secretary and within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has 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. Condition – The Institute did not submit timely notification to the National Student Loan Data System (NSLDS) of student status changes. Questioned Costs – None noted Context – Out of a population of 39 student enrollment status changes requiring notification, a sample of four student status changes was selected for testing. Out of the four selected for testing, two students that had status changes were not communicated to NSLDS on a timely basis. Both students that were not reported timely were graduates in May 2023. The sampling methodology was not intended to be a statistically valid sample. Effect – The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Cause – The Institute uses an Enrollment Reporting Servicer (Servicer) to transmit student enrollment status changes to NSLDS. The enrollment reporting file was submitted timely by the Institute to the Servicer, however, there was a delay in the submission to NSLDS from the Servicer. Ultimately the Institute has primary responsibility for timely submission of enrollment status changes to NSLDS. Recommendation – We recommend that management review this area and establish procedures to ensure student status changes are reporting timely to NSLDS. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.

Student Financial Assistance Cluster 84.063 Federal Pell Grant Program, 84.268 Federal Direct Student Loans U.S. Department of Education Award Year 2022/2023 Criteria or Specific Requirement – Special Tests and Provisions - Enrollment Reporting 34 CFR 685.309(b) states that upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary in the manner and format prescribed by the Secretary and within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has 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. Condition – The Institute did not submit timely notification to the National Student Loan Data System (NSLDS) of student status changes. Questioned Costs – None noted Context – Out of a population of 39 student enrollment status changes requiring notification, a sample of four student status changes was selected for testing. Out of the four selected for testing, two students that had status changes were not communicated to NSLDS on a timely basis. Both students that were not reported timely were graduates in May 2023. The sampling methodology was not intended to be a statistically valid sample. Effect – The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Cause – The Institute uses an Enrollment Reporting Servicer (Servicer) to transmit student enrollment status changes to NSLDS. The enrollment reporting file was submitted timely by the Institute to the Servicer, however, there was a delay in the submission to NSLDS from the Servicer. Ultimately the Institute has primary responsibility for timely submission of enrollment status changes to NSLDS. Recommendation – We recommend that management review this area and establish procedures to ensure student status changes are reporting timely to NSLDS. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.