Finding 2023-001 - Non-Compliance with Accurate Student Enrollment Change Submissions to
the National Student Loan Data System (Significant Deficiency)
Grantor: U.S. Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing #: 84.268, 84.063
Award Titles: Federal Direct Student Loan Program, Federal Pell Grant Program
Award Years: 7/2022 – 6/2024
Criteria
34 CFR 685.309(b):
(1) 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 -
(i) In the manner and format prescribed by the Secretary; and
(ii) Within the timeframe prescribed by the Secretary.
(2) 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 -
(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 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; or
(ii) A student who is enrolled at the school and who received a loan under title IV of the Act has
changed his or her permanent address.
34 CFR 690.83(b)(2): An institution shall submit, in accordance with deadline dates established by the
Secretary, through publication in the Federal Register, other reports and information the Secretary requires
and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.
Condition
Of the population of students who had a status change and received Pell Grants and/or Direct Loans during
the period February 28, 2023 through December 31, 2023, 60 students were selected for enrollment
reporting testing of the campus-level and program-level records. Of the 60 students selected, 12 instances
were noted in which the program begin date was incorrectly reported to the National Student Loan Data
System (NSLDS). Two instances were noted in the Winter 2023 semester and five instances were noted in
the Spring 2023 and Fall 2023 semesters, respectively. This is a repeat of finding 2022-001.
Cause
The 12 instances related to a system error within the University’s student information system, PeopleSoft,
in which the system inappropriately codes certain students’ enrollment with the wrong program begin
date. Specifically, when a student returns from a leave of absence, PeopleSoft creates a new version of the
program. The new version of the program resets the program begin date to when the student returned
instead of when the student originally began the program.
Effect
A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as
well as for payment of interest subsidies all of which are impacted by inaccurate and untimely reporting.
Questioned Costs
None
Recommendation
We recommend that the University continue to execute its prior year corrective action plan, process
improvements and information system enhancements, and to provide adequate training to the individuals
responsible for updating students’ electronic files to ensure status changes are reported accurately to NSLDS.
Management’s Views and Corrective Action Plan
Management’s response is reported in management’s view and corrective action plan included at the end of
this report.
Finding 2023-001 - Non-Compliance with Accurate Student Enrollment Change Submissions to
the National Student Loan Data System (Significant Deficiency)
Grantor: U.S. Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing #: 84.268, 84.063
Award Titles: Federal Direct Student Loan Program, Federal Pell Grant Program
Award Years: 7/2022 – 6/2024
Criteria
34 CFR 685.309(b):
(1) 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 -
(i) In the manner and format prescribed by the Secretary; and
(ii) Within the timeframe prescribed by the Secretary.
(2) 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 -
(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 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; or
(ii) A student who is enrolled at the school and who received a loan under title IV of the Act has
changed his or her permanent address.
34 CFR 690.83(b)(2): An institution shall submit, in accordance with deadline dates established by the
Secretary, through publication in the Federal Register, other reports and information the Secretary requires
and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.
Condition
Of the population of students who had a status change and received Pell Grants and/or Direct Loans during
the period February 28, 2023 through December 31, 2023, 60 students were selected for enrollment
reporting testing of the campus-level and program-level records. Of the 60 students selected, 12 instances
were noted in which the program begin date was incorrectly reported to the National Student Loan Data
System (NSLDS). Two instances were noted in the Winter 2023 semester and five instances were noted in
the Spring 2023 and Fall 2023 semesters, respectively. This is a repeat of finding 2022-001.
Cause
The 12 instances related to a system error within the University’s student information system, PeopleSoft,
in which the system inappropriately codes certain students’ enrollment with the wrong program begin
date. Specifically, when a student returns from a leave of absence, PeopleSoft creates a new version of the
program. The new version of the program resets the program begin date to when the student returned
instead of when the student originally began the program.
Effect
A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as
well as for payment of interest subsidies all of which are impacted by inaccurate and untimely reporting.
Questioned Costs
None
Recommendation
We recommend that the University continue to execute its prior year corrective action plan, process
improvements and information system enhancements, and to provide adequate training to the individuals
responsible for updating students’ electronic files to ensure status changes are reported accurately to NSLDS.
Management’s Views and Corrective Action Plan
Management’s response is reported in management’s view and corrective action plan included at the end of
this report.
Finding 2023-002 - Non-Compliance with Financial Need Requirements for Subsidized Direct
Loans in Non-Standard Semesters
Grantor: U.S. Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing #: 84.268
Award Title: Federal Direct Student Loan Program
Award Years: 7/2022 – 6/2024
Criteria
34 CFR 685.200. 2(i) Borrower eligibility
A Direct Subsidized Loan borrower must demonstrate financial need in accordance with title IV, part F of
the Act.
20 U.S. Code § 1087kk - Amount of need
Except as otherwise provided therein, the amount of need of any student for financial assistance under this
subchapter (except subparts [1] 1 or 2 of part A of this subchapter) is equal to—
(1)the cost of attendance of such student, minus
(2)the expected family contribution for such student, minus
(3)estimated financial assistance not received under this subchapter (as defined in section 1087vv(j) of
this title).
Condition
Of the population of students who were awarded and received federal student financial assistance during the
fiscal year, 25 students were selected for eligibility testing. Of the 25 students selected, one instance was
noted in which a student was awarded a subsidized direct loan in excess of their estimated need. This
instance occurred in the Spring 2023 non-standard semester.
Cause
The instance pertains to a system error in which the student information system inappropriately defaults
estimated family contribution (EFC) to zero for direct loan recipients during the non-standard Spring
2023 semester, rather than allocating the EFC for the students period of enrollment. This resulted in the
student receiving a subsidized direct loan they would not be eligible to receive.
Effect
Awarding subsidized direct loans to students without financial need resulted in disbursement of needbased
federal aid to an ineligible student.
Questioned Costs
$2,474
Recommendation
We recommend that the University update their student information system configuration to appropriately
account for EFCs based on the student’s enrollment (on a 12 month enrollment period for students enrolled in the
non-standard Spring semester) to ensure federal student financial assistance is awarded to eligible students.
Management’s Views and Corrective Action Plan
Management’s response is reported in management’s view and corrective action plan included at the end of
this report.
Finding 2023-001 - Non-Compliance with Accurate Student Enrollment Change Submissions to
the National Student Loan Data System (Significant Deficiency)
Grantor: U.S. Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing #: 84.268, 84.063
Award Titles: Federal Direct Student Loan Program, Federal Pell Grant Program
Award Years: 7/2022 – 6/2024
Criteria
34 CFR 685.309(b):
(1) 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 -
(i) In the manner and format prescribed by the Secretary; and
(ii) Within the timeframe prescribed by the Secretary.
(2) 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 -
(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 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; or
(ii) A student who is enrolled at the school and who received a loan under title IV of the Act has
changed his or her permanent address.
34 CFR 690.83(b)(2): An institution shall submit, in accordance with deadline dates established by the
Secretary, through publication in the Federal Register, other reports and information the Secretary requires
and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.
Condition
Of the population of students who had a status change and received Pell Grants and/or Direct Loans during
the period February 28, 2023 through December 31, 2023, 60 students were selected for enrollment
reporting testing of the campus-level and program-level records. Of the 60 students selected, 12 instances
were noted in which the program begin date was incorrectly reported to the National Student Loan Data
System (NSLDS). Two instances were noted in the Winter 2023 semester and five instances were noted in
the Spring 2023 and Fall 2023 semesters, respectively. This is a repeat of finding 2022-001.
Cause
The 12 instances related to a system error within the University’s student information system, PeopleSoft,
in which the system inappropriately codes certain students’ enrollment with the wrong program begin
date. Specifically, when a student returns from a leave of absence, PeopleSoft creates a new version of the
program. The new version of the program resets the program begin date to when the student returned
instead of when the student originally began the program.
Effect
A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as
well as for payment of interest subsidies all of which are impacted by inaccurate and untimely reporting.
Questioned Costs
None
Recommendation
We recommend that the University continue to execute its prior year corrective action plan, process
improvements and information system enhancements, and to provide adequate training to the individuals
responsible for updating students’ electronic files to ensure status changes are reported accurately to NSLDS.
Management’s Views and Corrective Action Plan
Management’s response is reported in management’s view and corrective action plan included at the end of
this report.
Finding 2023-001 - Non-Compliance with Accurate Student Enrollment Change Submissions to
the National Student Loan Data System (Significant Deficiency)
Grantor: U.S. Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing #: 84.268, 84.063
Award Titles: Federal Direct Student Loan Program, Federal Pell Grant Program
Award Years: 7/2022 – 6/2024
Criteria
34 CFR 685.309(b):
(1) 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 -
(i) In the manner and format prescribed by the Secretary; and
(ii) Within the timeframe prescribed by the Secretary.
(2) 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 -
(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 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; or
(ii) A student who is enrolled at the school and who received a loan under title IV of the Act has
changed his or her permanent address.
34 CFR 690.83(b)(2): An institution shall submit, in accordance with deadline dates established by the
Secretary, through publication in the Federal Register, other reports and information the Secretary requires
and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.
Condition
Of the population of students who had a status change and received Pell Grants and/or Direct Loans during
the period February 28, 2023 through December 31, 2023, 60 students were selected for enrollment
reporting testing of the campus-level and program-level records. Of the 60 students selected, 12 instances
were noted in which the program begin date was incorrectly reported to the National Student Loan Data
System (NSLDS). Two instances were noted in the Winter 2023 semester and five instances were noted in
the Spring 2023 and Fall 2023 semesters, respectively. This is a repeat of finding 2022-001.
Cause
The 12 instances related to a system error within the University’s student information system, PeopleSoft,
in which the system inappropriately codes certain students’ enrollment with the wrong program begin
date. Specifically, when a student returns from a leave of absence, PeopleSoft creates a new version of the
program. The new version of the program resets the program begin date to when the student returned
instead of when the student originally began the program.
Effect
A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as
well as for payment of interest subsidies all of which are impacted by inaccurate and untimely reporting.
Questioned Costs
None
Recommendation
We recommend that the University continue to execute its prior year corrective action plan, process
improvements and information system enhancements, and to provide adequate training to the individuals
responsible for updating students’ electronic files to ensure status changes are reported accurately to NSLDS.
Management’s Views and Corrective Action Plan
Management’s response is reported in management’s view and corrective action plan included at the end of
this report.
Finding 2023-002 - Non-Compliance with Financial Need Requirements for Subsidized Direct
Loans in Non-Standard Semesters
Grantor: U.S. Department of Education
Program: Student Financial Assistance Cluster
Assistance Listing #: 84.268
Award Title: Federal Direct Student Loan Program
Award Years: 7/2022 – 6/2024
Criteria
34 CFR 685.200. 2(i) Borrower eligibility
A Direct Subsidized Loan borrower must demonstrate financial need in accordance with title IV, part F of
the Act.
20 U.S. Code § 1087kk - Amount of need
Except as otherwise provided therein, the amount of need of any student for financial assistance under this
subchapter (except subparts [1] 1 or 2 of part A of this subchapter) is equal to—
(1)the cost of attendance of such student, minus
(2)the expected family contribution for such student, minus
(3)estimated financial assistance not received under this subchapter (as defined in section 1087vv(j) of
this title).
Condition
Of the population of students who were awarded and received federal student financial assistance during the
fiscal year, 25 students were selected for eligibility testing. Of the 25 students selected, one instance was
noted in which a student was awarded a subsidized direct loan in excess of their estimated need. This
instance occurred in the Spring 2023 non-standard semester.
Cause
The instance pertains to a system error in which the student information system inappropriately defaults
estimated family contribution (EFC) to zero for direct loan recipients during the non-standard Spring
2023 semester, rather than allocating the EFC for the students period of enrollment. This resulted in the
student receiving a subsidized direct loan they would not be eligible to receive.
Effect
Awarding subsidized direct loans to students without financial need resulted in disbursement of needbased
federal aid to an ineligible student.
Questioned Costs
$2,474
Recommendation
We recommend that the University update their student information system configuration to appropriately
account for EFCs based on the student’s enrollment (on a 12 month enrollment period for students enrolled in the
non-standard Spring semester) to ensure federal student financial assistance is awarded to eligible students.
Management’s Views and Corrective Action Plan
Management’s response is reported in management’s view and corrective action plan included at the end of
this report.