Audit 29630

Finding 2022-001: Federal Direct Student Loan Enrollment Reporting (Repeat Finding) Program: Federal Direct Loan Programs Assistance Listing Number (ALN): 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K22059 Federal Award Year: June 30, 2022 Repeat of prior year finding: 2021-001 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) 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, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) 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 institution, 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 or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: For 3 of 25 students included in our sample, the enrollment status was reported incorrectly. Two students were enrolled in Law Masters degree programs and were reported as less than full-time although should have been full time. Additionally, one GSEC Master?s student was reported correctly on the program level enrollment reporting as withdrawn on March 15, 2022, however, the campus level reporting included an incorrect status of less than half time and status date of March 16, 2022 before later being corrected to withdrawn status date of March 15, 2022. The sample was not a statistically valid sample. Cause: The College's procedures for reporting students? enrollment statuses for the Law Masters degree students, and the underlying system configurations driving report compilation did not consider the different enrollment statuses than the JD program. Further, the College?s procedures for reporting GSEC Masters enrollment status changes did not report withdrawn until the status was approved internally. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. 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. Questioned costs: Not applicable Context: Not applicable. Recommendation: It is recommended that policies and procedures are put in place to ensure that the correct enrollment status dates and enrollment statuses are reported to the NSLDS within the required time frames. Management's Response: Management agrees with the finding, and is committed to strengthening its procedures to avoid similar issues in the future. The College has reconfirmed the full and part time definitions for Law Masters students, and corrected the underlying technical issue that had interfered with the reporting of correct enrollment statuses for Law Master's students. The correction of the enrollment status for the two Law Masters students in NSLDS is in process. The College has also updated the procedures and documentation for enrollment reporting of GSEC Master?s students to ensure the scenario identified is handled correctly and consistently in the future. The College has corrected this student's program level withdrawal date in NSLDS.

Finding 2022-001: Federal Direct Student Loan Enrollment Reporting (Repeat Finding) Program: Federal Direct Loan Programs Assistance Listing Number (ALN): 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number: P268K22059 Federal Award Year: June 30, 2022 Repeat of prior year finding: 2021-001 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) 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, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) 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 institution, 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 or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: For 3 of 25 students included in our sample, the enrollment status was reported incorrectly. Two students were enrolled in Law Masters degree programs and were reported as less than full-time although should have been full time. Additionally, one GSEC Master?s student was reported correctly on the program level enrollment reporting as withdrawn on March 15, 2022, however, the campus level reporting included an incorrect status of less than half time and status date of March 16, 2022 before later being corrected to withdrawn status date of March 15, 2022. The sample was not a statistically valid sample. Cause: The College's procedures for reporting students? enrollment statuses for the Law Masters degree students, and the underlying system configurations driving report compilation did not consider the different enrollment statuses than the JD program. Further, the College?s procedures for reporting GSEC Masters enrollment status changes did not report withdrawn until the status was approved internally. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. 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. Questioned costs: Not applicable Context: Not applicable. Recommendation: It is recommended that policies and procedures are put in place to ensure that the correct enrollment status dates and enrollment statuses are reported to the NSLDS within the required time frames. Management's Response: Management agrees with the finding, and is committed to strengthening its procedures to avoid similar issues in the future. The College has reconfirmed the full and part time definitions for Law Masters students, and corrected the underlying technical issue that had interfered with the reporting of correct enrollment statuses for Law Master's students. The correction of the enrollment status for the two Law Masters students in NSLDS is in process. The College has also updated the procedures and documentation for enrollment reporting of GSEC Master?s students to ensure the scenario identified is handled correctly and consistently in the future. The College has corrected this student's program level withdrawal date in NSLDS.