Audit 293151

Finding No.: 2023 001 – Enrollment Reporting Federal Agency: U.S. Department of Education Pass through Agency: Direct Program Name: Student Financial Assistance Cluster – Federal Direct Loan Program, Federal Pell Grant Program CFDA Numbers: 84.268, 84.063 Federal Award Year: July 1, 2022 – June 30, 2023 Criteria Institutions are required to report enrollment information under the Pell grant, Direct Loan, and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS) (OMB No. 1845 0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment 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 Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS web site, certifying through the NSLDS’s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non federal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal award. Condition Found The University generally certifies its enrollment information through rosters provided to the NSC. Of the 60 students with enrollment changes that we selected for test work, we identified 60 students whose changes in enrollment status were not timely transmitted to NSLDS, as follows: • For fifty five (55) students, the University was notified of each student’s enrollment status change from full time to graduated in May 2023. Accordingly, the students’ status changes should have been transmitted within 60 days of degree conferral. However, submission was not timely, as the final submission of change of status ranged from seven (7) days to eleven (11) days after the required submission date. • For five (5) students, the University was notified of each student’s enrollment status change as withdrawn in May or June 2023. Accordingly, the students’ status changes should have been transmitted after notification of transfer within the appropriate timeframe. However, submission was not timely, as the final submission of change of status ranged from thirty seven (37) days to seventy seven (77) days after the required submission date. Cause For the aforementioned (55) students, the change in enrollment status was not entered timely due to issues with accessing the NSC FTP site and the fact that resources were not available to submit the data timely after these issues were encountered. For the aforementioned five (5) transfer students, the University’s internal control processes did not operate consistently to ensure that all enrollment information, including transfers effective at the end of the semester, were submitted timely to NSLDS. Possible Asserted Effect Untimely submission of student enrollment status information affects the determinations that lenders and servicers of students’ loans make related to in school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Questioned Costs No questioned costs were identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding While not a repeat finding, a finding principally related to the accuracy of enrollment reporting was reported as finding 2021 001 in the University’s fiscal 2021 Uniform Guidance report. Recommendation We recommend the University update FTP users and include verification of FTP account users’ access with NSC on a periodic basis and implement a back up procedure to transmit data using another mechanism (i.e., Direct to NSLDS) in the event of technology issues. We also recommend that the University review and revise its processes and internal controls to ensure that all enrollment information and status changes, including those effective at the end of a semester, are reported in a timely manner. Views of Responsible Officials The University places significant importance on the accurate and timely reporting of enrollment status changes, recognizing its crucial role in facilitating lenders and servicers of student loans to determine in school status, deferments, grace periods, and repayment schedules. Additionally, it plays a pivotal role in ensuring the federal government’s payment of interest subsidies. The delay in reporting the graduation status of 55 students was, in part, due to the University’s inability to timely access NSC, the platform utilized to report enrollment changes to the NSLDS. In June 2023, NSC reported the MOVEit data breach, necessitating the University to reset its password to NSC. This complicated the process of timely submission. To address and prevent such issues in the future, the University has implemented enhanced controls. These measures include clearly defined procedures for contact management in enrollment reporting, outlining processes for removing or adding contacts. Additionally, the University commits to conducting an annual, or as personnel changes within the University necessitate, confirmation with NSC to ensure the accuracy and currency of contact information, thereby averting potential delays in the future. The delay in reporting the additional five students was due to the design of the University’s summer withdrawal reporting process. The five students communicated their intent to leave during the summer but were not included in the typical summer enrollment file for reporting withdrawals during the term. Rather, they were included in the first fall file that was processed. To prevent such delays, the University has revised its enrollment reporting process. Summer withdrawals will now be reported directly to NSC at the time of withdrawal, ensuring timely and accurate reporting. The Registrar’s Office will submit a manual enrollment status change to NSC. This proactive approach also enhances efficiency in reporting summer withdrawals.

Finding No.: 2023 001 – Enrollment Reporting Federal Agency: U.S. Department of Education Pass through Agency: Direct Program Name: Student Financial Assistance Cluster – Federal Direct Loan Program, Federal Pell Grant Program CFDA Numbers: 84.268, 84.063 Federal Award Year: July 1, 2022 – June 30, 2023 Criteria Institutions are required to report enrollment information under the Pell grant, Direct Loan, and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS) (OMB No. 1845 0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment 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 Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS web site, certifying through the NSLDS’s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non federal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal award. Condition Found The University generally certifies its enrollment information through rosters provided to the NSC. Of the 60 students with enrollment changes that we selected for test work, we identified 60 students whose changes in enrollment status were not timely transmitted to NSLDS, as follows: • For fifty five (55) students, the University was notified of each student’s enrollment status change from full time to graduated in May 2023. Accordingly, the students’ status changes should have been transmitted within 60 days of degree conferral. However, submission was not timely, as the final submission of change of status ranged from seven (7) days to eleven (11) days after the required submission date. • For five (5) students, the University was notified of each student’s enrollment status change as withdrawn in May or June 2023. Accordingly, the students’ status changes should have been transmitted after notification of transfer within the appropriate timeframe. However, submission was not timely, as the final submission of change of status ranged from thirty seven (37) days to seventy seven (77) days after the required submission date. Cause For the aforementioned (55) students, the change in enrollment status was not entered timely due to issues with accessing the NSC FTP site and the fact that resources were not available to submit the data timely after these issues were encountered. For the aforementioned five (5) transfer students, the University’s internal control processes did not operate consistently to ensure that all enrollment information, including transfers effective at the end of the semester, were submitted timely to NSLDS. Possible Asserted Effect Untimely submission of student enrollment status information affects the determinations that lenders and servicers of students’ loans make related to in school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Questioned Costs No questioned costs were identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding While not a repeat finding, a finding principally related to the accuracy of enrollment reporting was reported as finding 2021 001 in the University’s fiscal 2021 Uniform Guidance report. Recommendation We recommend the University update FTP users and include verification of FTP account users’ access with NSC on a periodic basis and implement a back up procedure to transmit data using another mechanism (i.e., Direct to NSLDS) in the event of technology issues. We also recommend that the University review and revise its processes and internal controls to ensure that all enrollment information and status changes, including those effective at the end of a semester, are reported in a timely manner. Views of Responsible Officials The University places significant importance on the accurate and timely reporting of enrollment status changes, recognizing its crucial role in facilitating lenders and servicers of student loans to determine in school status, deferments, grace periods, and repayment schedules. Additionally, it plays a pivotal role in ensuring the federal government’s payment of interest subsidies. The delay in reporting the graduation status of 55 students was, in part, due to the University’s inability to timely access NSC, the platform utilized to report enrollment changes to the NSLDS. In June 2023, NSC reported the MOVEit data breach, necessitating the University to reset its password to NSC. This complicated the process of timely submission. To address and prevent such issues in the future, the University has implemented enhanced controls. These measures include clearly defined procedures for contact management in enrollment reporting, outlining processes for removing or adding contacts. Additionally, the University commits to conducting an annual, or as personnel changes within the University necessitate, confirmation with NSC to ensure the accuracy and currency of contact information, thereby averting potential delays in the future. The delay in reporting the additional five students was due to the design of the University’s summer withdrawal reporting process. The five students communicated their intent to leave during the summer but were not included in the typical summer enrollment file for reporting withdrawals during the term. Rather, they were included in the first fall file that was processed. To prevent such delays, the University has revised its enrollment reporting process. Summer withdrawals will now be reported directly to NSC at the time of withdrawal, ensuring timely and accurate reporting. The Registrar’s Office will submit a manual enrollment status change to NSC. This proactive approach also enhances efficiency in reporting summer withdrawals.

Finding No.: 2023 001 – Enrollment Reporting Federal Agency: U.S. Department of Education Pass through Agency: Direct Program Name: Student Financial Assistance Cluster – Federal Direct Loan Program, Federal Pell Grant Program CFDA Numbers: 84.268, 84.063 Federal Award Year: July 1, 2022 – June 30, 2023 Criteria Institutions are required to report enrollment information under the Pell grant, Direct Loan, and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS) (OMB No. 1845 0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment 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 Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS web site, certifying through the NSLDS’s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non federal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal award. Condition Found The University generally certifies its enrollment information through rosters provided to the NSC. Of the 60 students with enrollment changes that we selected for test work, we identified 60 students whose changes in enrollment status were not timely transmitted to NSLDS, as follows: • For fifty five (55) students, the University was notified of each student’s enrollment status change from full time to graduated in May 2023. Accordingly, the students’ status changes should have been transmitted within 60 days of degree conferral. However, submission was not timely, as the final submission of change of status ranged from seven (7) days to eleven (11) days after the required submission date. • For five (5) students, the University was notified of each student’s enrollment status change as withdrawn in May or June 2023. Accordingly, the students’ status changes should have been transmitted after notification of transfer within the appropriate timeframe. However, submission was not timely, as the final submission of change of status ranged from thirty seven (37) days to seventy seven (77) days after the required submission date. Cause For the aforementioned (55) students, the change in enrollment status was not entered timely due to issues with accessing the NSC FTP site and the fact that resources were not available to submit the data timely after these issues were encountered. For the aforementioned five (5) transfer students, the University’s internal control processes did not operate consistently to ensure that all enrollment information, including transfers effective at the end of the semester, were submitted timely to NSLDS. Possible Asserted Effect Untimely submission of student enrollment status information affects the determinations that lenders and servicers of students’ loans make related to in school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Questioned Costs No questioned costs were identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding While not a repeat finding, a finding principally related to the accuracy of enrollment reporting was reported as finding 2021 001 in the University’s fiscal 2021 Uniform Guidance report. Recommendation We recommend the University update FTP users and include verification of FTP account users’ access with NSC on a periodic basis and implement a back up procedure to transmit data using another mechanism (i.e., Direct to NSLDS) in the event of technology issues. We also recommend that the University review and revise its processes and internal controls to ensure that all enrollment information and status changes, including those effective at the end of a semester, are reported in a timely manner. Views of Responsible Officials The University places significant importance on the accurate and timely reporting of enrollment status changes, recognizing its crucial role in facilitating lenders and servicers of student loans to determine in school status, deferments, grace periods, and repayment schedules. Additionally, it plays a pivotal role in ensuring the federal government’s payment of interest subsidies. The delay in reporting the graduation status of 55 students was, in part, due to the University’s inability to timely access NSC, the platform utilized to report enrollment changes to the NSLDS. In June 2023, NSC reported the MOVEit data breach, necessitating the University to reset its password to NSC. This complicated the process of timely submission. To address and prevent such issues in the future, the University has implemented enhanced controls. These measures include clearly defined procedures for contact management in enrollment reporting, outlining processes for removing or adding contacts. Additionally, the University commits to conducting an annual, or as personnel changes within the University necessitate, confirmation with NSC to ensure the accuracy and currency of contact information, thereby averting potential delays in the future. The delay in reporting the additional five students was due to the design of the University’s summer withdrawal reporting process. The five students communicated their intent to leave during the summer but were not included in the typical summer enrollment file for reporting withdrawals during the term. Rather, they were included in the first fall file that was processed. To prevent such delays, the University has revised its enrollment reporting process. Summer withdrawals will now be reported directly to NSC at the time of withdrawal, ensuring timely and accurate reporting. The Registrar’s Office will submit a manual enrollment status change to NSC. This proactive approach also enhances efficiency in reporting summer withdrawals.

Finding No.: 2023 001 – Enrollment Reporting Federal Agency: U.S. Department of Education Pass through Agency: Direct Program Name: Student Financial Assistance Cluster – Federal Direct Loan Program, Federal Pell Grant Program CFDA Numbers: 84.268, 84.063 Federal Award Year: July 1, 2022 – June 30, 2023 Criteria Institutions are required to report enrollment information under the Pell grant, Direct Loan, and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS) (OMB No. 1845 0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment 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 Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS web site, certifying through the NSLDS’s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a non federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non federal entity is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the federal award. Condition Found The University generally certifies its enrollment information through rosters provided to the NSC. Of the 60 students with enrollment changes that we selected for test work, we identified 60 students whose changes in enrollment status were not timely transmitted to NSLDS, as follows: • For fifty five (55) students, the University was notified of each student’s enrollment status change from full time to graduated in May 2023. Accordingly, the students’ status changes should have been transmitted within 60 days of degree conferral. However, submission was not timely, as the final submission of change of status ranged from seven (7) days to eleven (11) days after the required submission date. • For five (5) students, the University was notified of each student’s enrollment status change as withdrawn in May or June 2023. Accordingly, the students’ status changes should have been transmitted after notification of transfer within the appropriate timeframe. However, submission was not timely, as the final submission of change of status ranged from thirty seven (37) days to seventy seven (77) days after the required submission date. Cause For the aforementioned (55) students, the change in enrollment status was not entered timely due to issues with accessing the NSC FTP site and the fact that resources were not available to submit the data timely after these issues were encountered. For the aforementioned five (5) transfer students, the University’s internal control processes did not operate consistently to ensure that all enrollment information, including transfers effective at the end of the semester, were submitted timely to NSLDS. Possible Asserted Effect Untimely submission of student enrollment status information affects the determinations that lenders and servicers of students’ loans make related to in school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Questioned Costs No questioned costs were identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding While not a repeat finding, a finding principally related to the accuracy of enrollment reporting was reported as finding 2021 001 in the University’s fiscal 2021 Uniform Guidance report. Recommendation We recommend the University update FTP users and include verification of FTP account users’ access with NSC on a periodic basis and implement a back up procedure to transmit data using another mechanism (i.e., Direct to NSLDS) in the event of technology issues. We also recommend that the University review and revise its processes and internal controls to ensure that all enrollment information and status changes, including those effective at the end of a semester, are reported in a timely manner. Views of Responsible Officials The University places significant importance on the accurate and timely reporting of enrollment status changes, recognizing its crucial role in facilitating lenders and servicers of student loans to determine in school status, deferments, grace periods, and repayment schedules. Additionally, it plays a pivotal role in ensuring the federal government’s payment of interest subsidies. The delay in reporting the graduation status of 55 students was, in part, due to the University’s inability to timely access NSC, the platform utilized to report enrollment changes to the NSLDS. In June 2023, NSC reported the MOVEit data breach, necessitating the University to reset its password to NSC. This complicated the process of timely submission. To address and prevent such issues in the future, the University has implemented enhanced controls. These measures include clearly defined procedures for contact management in enrollment reporting, outlining processes for removing or adding contacts. Additionally, the University commits to conducting an annual, or as personnel changes within the University necessitate, confirmation with NSC to ensure the accuracy and currency of contact information, thereby averting potential delays in the future. The delay in reporting the additional five students was due to the design of the University’s summer withdrawal reporting process. The five students communicated their intent to leave during the summer but were not included in the typical summer enrollment file for reporting withdrawals during the term. Rather, they were included in the first fall file that was processed. To prevent such delays, the University has revised its enrollment reporting process. Summer withdrawals will now be reported directly to NSC at the time of withdrawal, ensuring timely and accurate reporting. The Registrar’s Office will submit a manual enrollment status change to NSC. This proactive approach also enhances efficiency in reporting summer withdrawals.