Audit 291795

FY End
2023-06-30
Total Expended
$14.96M
Findings
10
Programs
6
Organization: Woodbury University (CA)
Year: 2023 Accepted: 2024-02-22
Auditor: Moss Adams LLP

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
370217 2023-002 Significant Deficiency - N
370218 2023-002 Significant Deficiency - N
370219 2023-002 Significant Deficiency - N
370220 2023-002 Significant Deficiency - N
370221 2023-002 Significant Deficiency - N
946659 2023-002 Significant Deficiency - N
946660 2023-002 Significant Deficiency - N
946661 2023-002 Significant Deficiency - N
946662 2023-002 Significant Deficiency - N
946663 2023-002 Significant Deficiency - N

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $10.35M Yes 1
84.063 Federal Pell Grant Program $2.26M Yes 1
84.031 Higher Education_institutional Aid $1.04M - 0
84.038 Federal Perkins Loan Program (beginning of the Year) $965,213 Yes 1
84.007 Federal Supplemental Educational Opportunity Grants $177,103 Yes 1
84.033 Federal Work-Study Program $169,449 Yes 1

Contacts

Name Title Type
KE1KF8PUSB29 Bradley Mitchell Auditee
8183943389 Melissa Harman Auditor
No contacts on file

Notes to SEFA

Title: Note 1 – Basis of Presentation Accounting Policies: Note 2 – Summary of Significant Accounting Policies Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The University has elected not to use the 10% de minimus indirect cost rate as allowed under Uniform Guidance. The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal grant activity of Woodbury University (the University) under programs of the federal government for the year ended June 30, 2023. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the University, it is not intended to, and does not, present the statement of financial position, activities, or cash flows of the University.
Title: Note 3 – Federal Student Loan Program Accounting Policies: Note 2 – Summary of Significant Accounting Policies Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The University has elected not to use the 10% de minimus indirect cost rate as allowed under Uniform Guidance. The federal student loan program listed subsequently is administered directly by the University, and balances and transactions relating to this program are included in the University’s financial statements. Loans made during the year are included in the federal expenditures presented in the Schedule. The balance of loans outstanding at June 30, 2023, consists of: (See Notes to SEFA - Note 3 - Federal Student Loan Program for included table)

Finding Details

Finding 2023-002 – Special Tests and Provisions – Enrollment Reporting – Significant Deficiency in Internal Control Over Compliance (See Section III - Federal Awards Findings - Finding 2023-002 for included table) Criteria: The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information. It is Woodbury University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes. Woodbury University is ultimately responsible for the timeliness and accuracy of this information even when a third-party servicer is used as an intermediary to report on the University’s behalf. Woodbury University currently contracts with a third-party servicer and has elected to receive an Enrollment Reporting roster file every 30 days from NSLDS. At a minimum, institutions must certify the enrollment status of all students included on the roster file within 15 days of receiving the roster file. If errors are identified, the University has 10 days to resubmit a corrected response. 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 federal aid either did not enroll or ceased to be enrolled on at least a half-time basis (34 CFR section 685.309). Condition/context: We selected a sample of students identified by Woodbury University as having received some federal assistance and who either withdrew, took a leave of absence (LOA), or graduated during the year ended June 30, 2023. Our sample consisted of 2 students out of a population of 3 that withdrew or took a LOA during the year and a sample of 13 students out of a population of approximately 122 that graduated during the year. We then compared the enrollment information and withdrawal, LOA, or graduation date per Woodbury University’s records to the information reported to NSLDS. We believe this to be a representative sample of the population. We noted exceptions with all Spring 2023 graduates, of which there were 11 in our sample, whose status change was not reported within the required time frame. Questioned Costs: No questioned costs were identified as part of this finding. Effect: Enrollment status is utilized by students, 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. Cause: The lack of timely reporting was caused by turnover in the Registrar’s office. Repeat finding: This is not a repeat finding. Recommendation: Woodbury University should develop additional procedures and controls to monitor the accuracy of information provided to its third-party servicer and to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate. Each institution has access to manually correct information directly within NSLDS at any time. Views of responsible officials and planned corrective actions: Management agrees with the finding and recommendation and plans to implement additional controls.
Finding 2023-002 – Special Tests and Provisions – Enrollment Reporting – Significant Deficiency in Internal Control Over Compliance (See Section III - Federal Awards Findings - Finding 2023-002 for included table) Criteria: The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information. It is Woodbury University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes. Woodbury University is ultimately responsible for the timeliness and accuracy of this information even when a third-party servicer is used as an intermediary to report on the University’s behalf. Woodbury University currently contracts with a third-party servicer and has elected to receive an Enrollment Reporting roster file every 30 days from NSLDS. At a minimum, institutions must certify the enrollment status of all students included on the roster file within 15 days of receiving the roster file. If errors are identified, the University has 10 days to resubmit a corrected response. 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 federal aid either did not enroll or ceased to be enrolled on at least a half-time basis (34 CFR section 685.309). Condition/context: We selected a sample of students identified by Woodbury University as having received some federal assistance and who either withdrew, took a leave of absence (LOA), or graduated during the year ended June 30, 2023. Our sample consisted of 2 students out of a population of 3 that withdrew or took a LOA during the year and a sample of 13 students out of a population of approximately 122 that graduated during the year. We then compared the enrollment information and withdrawal, LOA, or graduation date per Woodbury University’s records to the information reported to NSLDS. We believe this to be a representative sample of the population. We noted exceptions with all Spring 2023 graduates, of which there were 11 in our sample, whose status change was not reported within the required time frame. Questioned Costs: No questioned costs were identified as part of this finding. Effect: Enrollment status is utilized by students, 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. Cause: The lack of timely reporting was caused by turnover in the Registrar’s office. Repeat finding: This is not a repeat finding. Recommendation: Woodbury University should develop additional procedures and controls to monitor the accuracy of information provided to its third-party servicer and to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate. Each institution has access to manually correct information directly within NSLDS at any time. Views of responsible officials and planned corrective actions: Management agrees with the finding and recommendation and plans to implement additional controls.
Finding 2023-002 – Special Tests and Provisions – Enrollment Reporting – Significant Deficiency in Internal Control Over Compliance (See Section III - Federal Awards Findings - Finding 2023-002 for included table) Criteria: The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information. It is Woodbury University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes. Woodbury University is ultimately responsible for the timeliness and accuracy of this information even when a third-party servicer is used as an intermediary to report on the University’s behalf. Woodbury University currently contracts with a third-party servicer and has elected to receive an Enrollment Reporting roster file every 30 days from NSLDS. At a minimum, institutions must certify the enrollment status of all students included on the roster file within 15 days of receiving the roster file. If errors are identified, the University has 10 days to resubmit a corrected response. 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 federal aid either did not enroll or ceased to be enrolled on at least a half-time basis (34 CFR section 685.309). Condition/context: We selected a sample of students identified by Woodbury University as having received some federal assistance and who either withdrew, took a leave of absence (LOA), or graduated during the year ended June 30, 2023. Our sample consisted of 2 students out of a population of 3 that withdrew or took a LOA during the year and a sample of 13 students out of a population of approximately 122 that graduated during the year. We then compared the enrollment information and withdrawal, LOA, or graduation date per Woodbury University’s records to the information reported to NSLDS. We believe this to be a representative sample of the population. We noted exceptions with all Spring 2023 graduates, of which there were 11 in our sample, whose status change was not reported within the required time frame. Questioned Costs: No questioned costs were identified as part of this finding. Effect: Enrollment status is utilized by students, 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. Cause: The lack of timely reporting was caused by turnover in the Registrar’s office. Repeat finding: This is not a repeat finding. Recommendation: Woodbury University should develop additional procedures and controls to monitor the accuracy of information provided to its third-party servicer and to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate. Each institution has access to manually correct information directly within NSLDS at any time. Views of responsible officials and planned corrective actions: Management agrees with the finding and recommendation and plans to implement additional controls.
Finding 2023-002 – Special Tests and Provisions – Enrollment Reporting – Significant Deficiency in Internal Control Over Compliance (See Section III - Federal Awards Findings - Finding 2023-002 for included table) Criteria: The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information. It is Woodbury University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes. Woodbury University is ultimately responsible for the timeliness and accuracy of this information even when a third-party servicer is used as an intermediary to report on the University’s behalf. Woodbury University currently contracts with a third-party servicer and has elected to receive an Enrollment Reporting roster file every 30 days from NSLDS. At a minimum, institutions must certify the enrollment status of all students included on the roster file within 15 days of receiving the roster file. If errors are identified, the University has 10 days to resubmit a corrected response. 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 federal aid either did not enroll or ceased to be enrolled on at least a half-time basis (34 CFR section 685.309). Condition/context: We selected a sample of students identified by Woodbury University as having received some federal assistance and who either withdrew, took a leave of absence (LOA), or graduated during the year ended June 30, 2023. Our sample consisted of 2 students out of a population of 3 that withdrew or took a LOA during the year and a sample of 13 students out of a population of approximately 122 that graduated during the year. We then compared the enrollment information and withdrawal, LOA, or graduation date per Woodbury University’s records to the information reported to NSLDS. We believe this to be a representative sample of the population. We noted exceptions with all Spring 2023 graduates, of which there were 11 in our sample, whose status change was not reported within the required time frame. Questioned Costs: No questioned costs were identified as part of this finding. Effect: Enrollment status is utilized by students, 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. Cause: The lack of timely reporting was caused by turnover in the Registrar’s office. Repeat finding: This is not a repeat finding. Recommendation: Woodbury University should develop additional procedures and controls to monitor the accuracy of information provided to its third-party servicer and to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate. Each institution has access to manually correct information directly within NSLDS at any time. Views of responsible officials and planned corrective actions: Management agrees with the finding and recommendation and plans to implement additional controls.
Finding 2023-002 – Special Tests and Provisions – Enrollment Reporting – Significant Deficiency in Internal Control Over Compliance (See Section III - Federal Awards Findings - Finding 2023-002 for included table) Criteria: The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information. It is Woodbury University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes. Woodbury University is ultimately responsible for the timeliness and accuracy of this information even when a third-party servicer is used as an intermediary to report on the University’s behalf. Woodbury University currently contracts with a third-party servicer and has elected to receive an Enrollment Reporting roster file every 30 days from NSLDS. At a minimum, institutions must certify the enrollment status of all students included on the roster file within 15 days of receiving the roster file. If errors are identified, the University has 10 days to resubmit a corrected response. 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 federal aid either did not enroll or ceased to be enrolled on at least a half-time basis (34 CFR section 685.309). Condition/context: We selected a sample of students identified by Woodbury University as having received some federal assistance and who either withdrew, took a leave of absence (LOA), or graduated during the year ended June 30, 2023. Our sample consisted of 2 students out of a population of 3 that withdrew or took a LOA during the year and a sample of 13 students out of a population of approximately 122 that graduated during the year. We then compared the enrollment information and withdrawal, LOA, or graduation date per Woodbury University’s records to the information reported to NSLDS. We believe this to be a representative sample of the population. We noted exceptions with all Spring 2023 graduates, of which there were 11 in our sample, whose status change was not reported within the required time frame. Questioned Costs: No questioned costs were identified as part of this finding. Effect: Enrollment status is utilized by students, 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. Cause: The lack of timely reporting was caused by turnover in the Registrar’s office. Repeat finding: This is not a repeat finding. Recommendation: Woodbury University should develop additional procedures and controls to monitor the accuracy of information provided to its third-party servicer and to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate. Each institution has access to manually correct information directly within NSLDS at any time. Views of responsible officials and planned corrective actions: Management agrees with the finding and recommendation and plans to implement additional controls.
Finding 2023-002 – Special Tests and Provisions – Enrollment Reporting – Significant Deficiency in Internal Control Over Compliance (See Section III - Federal Awards Findings - Finding 2023-002 for included table) Criteria: The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information. It is Woodbury University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes. Woodbury University is ultimately responsible for the timeliness and accuracy of this information even when a third-party servicer is used as an intermediary to report on the University’s behalf. Woodbury University currently contracts with a third-party servicer and has elected to receive an Enrollment Reporting roster file every 30 days from NSLDS. At a minimum, institutions must certify the enrollment status of all students included on the roster file within 15 days of receiving the roster file. If errors are identified, the University has 10 days to resubmit a corrected response. 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 federal aid either did not enroll or ceased to be enrolled on at least a half-time basis (34 CFR section 685.309). Condition/context: We selected a sample of students identified by Woodbury University as having received some federal assistance and who either withdrew, took a leave of absence (LOA), or graduated during the year ended June 30, 2023. Our sample consisted of 2 students out of a population of 3 that withdrew or took a LOA during the year and a sample of 13 students out of a population of approximately 122 that graduated during the year. We then compared the enrollment information and withdrawal, LOA, or graduation date per Woodbury University’s records to the information reported to NSLDS. We believe this to be a representative sample of the population. We noted exceptions with all Spring 2023 graduates, of which there were 11 in our sample, whose status change was not reported within the required time frame. Questioned Costs: No questioned costs were identified as part of this finding. Effect: Enrollment status is utilized by students, 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. Cause: The lack of timely reporting was caused by turnover in the Registrar’s office. Repeat finding: This is not a repeat finding. Recommendation: Woodbury University should develop additional procedures and controls to monitor the accuracy of information provided to its third-party servicer and to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate. Each institution has access to manually correct information directly within NSLDS at any time. Views of responsible officials and planned corrective actions: Management agrees with the finding and recommendation and plans to implement additional controls.
Finding 2023-002 – Special Tests and Provisions – Enrollment Reporting – Significant Deficiency in Internal Control Over Compliance (See Section III - Federal Awards Findings - Finding 2023-002 for included table) Criteria: The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information. It is Woodbury University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes. Woodbury University is ultimately responsible for the timeliness and accuracy of this information even when a third-party servicer is used as an intermediary to report on the University’s behalf. Woodbury University currently contracts with a third-party servicer and has elected to receive an Enrollment Reporting roster file every 30 days from NSLDS. At a minimum, institutions must certify the enrollment status of all students included on the roster file within 15 days of receiving the roster file. If errors are identified, the University has 10 days to resubmit a corrected response. 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 federal aid either did not enroll or ceased to be enrolled on at least a half-time basis (34 CFR section 685.309). Condition/context: We selected a sample of students identified by Woodbury University as having received some federal assistance and who either withdrew, took a leave of absence (LOA), or graduated during the year ended June 30, 2023. Our sample consisted of 2 students out of a population of 3 that withdrew or took a LOA during the year and a sample of 13 students out of a population of approximately 122 that graduated during the year. We then compared the enrollment information and withdrawal, LOA, or graduation date per Woodbury University’s records to the information reported to NSLDS. We believe this to be a representative sample of the population. We noted exceptions with all Spring 2023 graduates, of which there were 11 in our sample, whose status change was not reported within the required time frame. Questioned Costs: No questioned costs were identified as part of this finding. Effect: Enrollment status is utilized by students, 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. Cause: The lack of timely reporting was caused by turnover in the Registrar’s office. Repeat finding: This is not a repeat finding. Recommendation: Woodbury University should develop additional procedures and controls to monitor the accuracy of information provided to its third-party servicer and to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate. Each institution has access to manually correct information directly within NSLDS at any time. Views of responsible officials and planned corrective actions: Management agrees with the finding and recommendation and plans to implement additional controls.
Finding 2023-002 – Special Tests and Provisions – Enrollment Reporting – Significant Deficiency in Internal Control Over Compliance (See Section III - Federal Awards Findings - Finding 2023-002 for included table) Criteria: The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information. It is Woodbury University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes. Woodbury University is ultimately responsible for the timeliness and accuracy of this information even when a third-party servicer is used as an intermediary to report on the University’s behalf. Woodbury University currently contracts with a third-party servicer and has elected to receive an Enrollment Reporting roster file every 30 days from NSLDS. At a minimum, institutions must certify the enrollment status of all students included on the roster file within 15 days of receiving the roster file. If errors are identified, the University has 10 days to resubmit a corrected response. 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 federal aid either did not enroll or ceased to be enrolled on at least a half-time basis (34 CFR section 685.309). Condition/context: We selected a sample of students identified by Woodbury University as having received some federal assistance and who either withdrew, took a leave of absence (LOA), or graduated during the year ended June 30, 2023. Our sample consisted of 2 students out of a population of 3 that withdrew or took a LOA during the year and a sample of 13 students out of a population of approximately 122 that graduated during the year. We then compared the enrollment information and withdrawal, LOA, or graduation date per Woodbury University’s records to the information reported to NSLDS. We believe this to be a representative sample of the population. We noted exceptions with all Spring 2023 graduates, of which there were 11 in our sample, whose status change was not reported within the required time frame. Questioned Costs: No questioned costs were identified as part of this finding. Effect: Enrollment status is utilized by students, 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. Cause: The lack of timely reporting was caused by turnover in the Registrar’s office. Repeat finding: This is not a repeat finding. Recommendation: Woodbury University should develop additional procedures and controls to monitor the accuracy of information provided to its third-party servicer and to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate. Each institution has access to manually correct information directly within NSLDS at any time. Views of responsible officials and planned corrective actions: Management agrees with the finding and recommendation and plans to implement additional controls.
Finding 2023-002 – Special Tests and Provisions – Enrollment Reporting – Significant Deficiency in Internal Control Over Compliance (See Section III - Federal Awards Findings - Finding 2023-002 for included table) Criteria: The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information. It is Woodbury University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes. Woodbury University is ultimately responsible for the timeliness and accuracy of this information even when a third-party servicer is used as an intermediary to report on the University’s behalf. Woodbury University currently contracts with a third-party servicer and has elected to receive an Enrollment Reporting roster file every 30 days from NSLDS. At a minimum, institutions must certify the enrollment status of all students included on the roster file within 15 days of receiving the roster file. If errors are identified, the University has 10 days to resubmit a corrected response. 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 federal aid either did not enroll or ceased to be enrolled on at least a half-time basis (34 CFR section 685.309). Condition/context: We selected a sample of students identified by Woodbury University as having received some federal assistance and who either withdrew, took a leave of absence (LOA), or graduated during the year ended June 30, 2023. Our sample consisted of 2 students out of a population of 3 that withdrew or took a LOA during the year and a sample of 13 students out of a population of approximately 122 that graduated during the year. We then compared the enrollment information and withdrawal, LOA, or graduation date per Woodbury University’s records to the information reported to NSLDS. We believe this to be a representative sample of the population. We noted exceptions with all Spring 2023 graduates, of which there were 11 in our sample, whose status change was not reported within the required time frame. Questioned Costs: No questioned costs were identified as part of this finding. Effect: Enrollment status is utilized by students, 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. Cause: The lack of timely reporting was caused by turnover in the Registrar’s office. Repeat finding: This is not a repeat finding. Recommendation: Woodbury University should develop additional procedures and controls to monitor the accuracy of information provided to its third-party servicer and to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate. Each institution has access to manually correct information directly within NSLDS at any time. Views of responsible officials and planned corrective actions: Management agrees with the finding and recommendation and plans to implement additional controls.
Finding 2023-002 – Special Tests and Provisions – Enrollment Reporting – Significant Deficiency in Internal Control Over Compliance (See Section III - Federal Awards Findings - Finding 2023-002 for included table) Criteria: The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information. It is Woodbury University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes. Woodbury University is ultimately responsible for the timeliness and accuracy of this information even when a third-party servicer is used as an intermediary to report on the University’s behalf. Woodbury University currently contracts with a third-party servicer and has elected to receive an Enrollment Reporting roster file every 30 days from NSLDS. At a minimum, institutions must certify the enrollment status of all students included on the roster file within 15 days of receiving the roster file. If errors are identified, the University has 10 days to resubmit a corrected response. 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 federal aid either did not enroll or ceased to be enrolled on at least a half-time basis (34 CFR section 685.309). Condition/context: We selected a sample of students identified by Woodbury University as having received some federal assistance and who either withdrew, took a leave of absence (LOA), or graduated during the year ended June 30, 2023. Our sample consisted of 2 students out of a population of 3 that withdrew or took a LOA during the year and a sample of 13 students out of a population of approximately 122 that graduated during the year. We then compared the enrollment information and withdrawal, LOA, or graduation date per Woodbury University’s records to the information reported to NSLDS. We believe this to be a representative sample of the population. We noted exceptions with all Spring 2023 graduates, of which there were 11 in our sample, whose status change was not reported within the required time frame. Questioned Costs: No questioned costs were identified as part of this finding. Effect: Enrollment status is utilized by students, 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. Cause: The lack of timely reporting was caused by turnover in the Registrar’s office. Repeat finding: This is not a repeat finding. Recommendation: Woodbury University should develop additional procedures and controls to monitor the accuracy of information provided to its third-party servicer and to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate. Each institution has access to manually correct information directly within NSLDS at any time. Views of responsible officials and planned corrective actions: Management agrees with the finding and recommendation and plans to implement additional controls.