Condition Found:
For 12 students out of 40 selected for testwork, the institution inaccurately reported their date of
disbursement of the award to the COD system, which represents one out of the six required data elements
to be reported to the COD. The differences in disbursement dates ranged from 1 to 4 days.
For 2 students out of 40 selected for testwork, the institution inaccurately reported the date of enrollment of
the student to the COD system, which represents one out of the six required data elements to be reported
to the COD. The differences in enrollment dates were 3 days.
For 15 students out of 40 selected for testwork, the institution inaccurately reported the Academic End
dates of the student to the COD system, which represents one out of the six required data elements to be
reported to the COD. However, the differences in academic end dates ranged from 1 to 75 days, the
majority of which were within 1 to 2 days, 1 sample was had a 46-day variance, 1 sample had a 74-day
variance and the 1 sample had a 75-day variance.
Out of the 29 discrepancies identified above, 9 of the samples had inaccurate data for 2 elements
(disbursement date and academic end date) and the remaining samples had inaccurate data for 1 element
each.
Cause and Possible Asserted Effect:
The institution’s control to reconcile the data between the institution’s records and COD system did not
operate consistently to ensure accurate data is reported to COD on a timely basis.
Condition Found:
For 19 out of 40 students selected for testwork, the Title IV funds credited to the student resulted in a credit
balance owed to the student. The institution did not refund the credit balances back to the student for more
than a period of 14 days and did not obtain proper authorizations from the student to retain the balance.
The delay in repayment ranged from 15 to 102 days.
Cause and Possible Asserted Effect:
It was identified that management had turnover in the financial aid department, which caused delays in
recording and processing refunds among the accounting and accounts payable departments. This resulted
in a failure by the institution to make payment to the students within the 14-day timeframe required by the
Department of Education and did not obtain voluntary authorization from the student to retain the credit
balances. Therefore, this evidenced the lack of an appropriately designed control by the institution to
ensure credit balances are refunded to students within the timeframe requirements.
Condition Found:
The Institution utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for
transmissions of its enrollment reporting changes to the National Student Loan Data System (NSLDS). The
University receives the Enrollment Reporting Roster and updates it for changes in student status. The file is
sent to the Clearinghouse who transmits the updated information to NSLDS.
For a sample of 40 students who were recipients of Direct Loans or Pell Grants between January 1, 2023
and December 31, 2023 who had been identified as having withdrawn, graduated, or modified their
enrollment status as defined by the University’s Satisfactory Academic Progress Policy through a change in
course load, the following were noted:
• 2023-003: For 2 of the 40 students selected for enrollment reporting testing, the student’s program
level enrollment effective date did not agree to that of their campus level data and/or the data per the
institution’s records. This represents 1 out of 9 high-risk data elements within the program level data
element requirements.
• 2023-004: For 1 student out of 40 selected for testwork, comparison of the institution’s records to that
of NSLDS evidenced that enrollment reporting for these students were not reported to NSLDS on a
timely basis. Therefore, management did not report the status changes to NSLDS within the required
timeframe of 60 days from the date they became aware of the change.
Cause and Possible Asserted Effect:
2023-003: The Institution’s controls over its review of the recording and communication of these status
changes does not operate consistently to ensure that individuals’ enrollment statuses are completely and
accurately communicated to NSLDS at the program level details.
2023-004: Management’s review over its enrollment reporting requirements for SFA was not operating as
designed to ensure timely reporting of status changes. Management sent the status change to the
Clearinghouse within the required timeframe; however, NSC did not send the data to NSLDS until after the
60-day requirement. As such, management’s control did not operate at a precise enough level to detect
and prevent noncompliance.
Further, the institution failed to maintain adequate review and documentation over student enrollment
status changes, resulting in a delay timeliness and inaccuracy of reporting to NSLDS.
Condition Found:
The Institution utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for
transmissions of its enrollment reporting changes to the National Student Loan Data System (NSLDS). The
University receives the Enrollment Reporting Roster and updates it for changes in student status. The file is
sent to the Clearinghouse who transmits the updated information to NSLDS.
For a sample of 40 students who were recipients of Direct Loans or Pell Grants between January 1, 2023
and December 31, 2023 who had been identified as having withdrawn, graduated, or modified their
enrollment status as defined by the University’s Satisfactory Academic Progress Policy through a change in
course load, the following were noted:
• 2023-003: For 2 of the 40 students selected for enrollment reporting testing, the student’s program
level enrollment effective date did not agree to that of their campus level data and/or the data per the
institution’s records. This represents 1 out of 9 high-risk data elements within the program level data
element requirements.
• 2023-004: For 1 student out of 40 selected for testwork, comparison of the institution’s records to that
of NSLDS evidenced that enrollment reporting for these students were not reported to NSLDS on a
timely basis. Therefore, management did not report the status changes to NSLDS within the required
timeframe of 60 days from the date they became aware of the change.
Cause and Possible Asserted Effect:
2023-003: The Institution’s controls over its review of the recording and communication of these status
changes does not operate consistently to ensure that individuals’ enrollment statuses are completely and
accurately communicated to NSLDS at the program level details.
2023-004: Management’s review over its enrollment reporting requirements for SFA was not operating as
designed to ensure timely reporting of status changes. Management sent the status change to the
Clearinghouse within the required timeframe; however, NSC did not send the data to NSLDS until after the
60-day requirement. As such, management’s control did not operate at a precise enough level to detect
and prevent noncompliance.
Further, the institution failed to maintain adequate review and documentation over student enrollment
status changes, resulting in a delay timeliness and inaccuracy of reporting to NSLDS.
Condition Found:
For 12 students out of 40 selected for testwork, the institution inaccurately reported their date of
disbursement of the award to the COD system, which represents one out of the six required data elements
to be reported to the COD. The differences in disbursement dates ranged from 1 to 4 days.
For 2 students out of 40 selected for testwork, the institution inaccurately reported the date of enrollment of
the student to the COD system, which represents one out of the six required data elements to be reported
to the COD. The differences in enrollment dates were 3 days.
For 15 students out of 40 selected for testwork, the institution inaccurately reported the Academic End
dates of the student to the COD system, which represents one out of the six required data elements to be
reported to the COD. However, the differences in academic end dates ranged from 1 to 75 days, the
majority of which were within 1 to 2 days, 1 sample was had a 46-day variance, 1 sample had a 74-day
variance and the 1 sample had a 75-day variance.
Out of the 29 discrepancies identified above, 9 of the samples had inaccurate data for 2 elements
(disbursement date and academic end date) and the remaining samples had inaccurate data for 1 element
each.
Cause and Possible Asserted Effect:
The institution’s control to reconcile the data between the institution’s records and COD system did not
operate consistently to ensure accurate data is reported to COD on a timely basis.
Condition Found:
For 19 out of 40 students selected for testwork, the Title IV funds credited to the student resulted in a credit
balance owed to the student. The institution did not refund the credit balances back to the student for more
than a period of 14 days and did not obtain proper authorizations from the student to retain the balance.
The delay in repayment ranged from 15 to 102 days.
Cause and Possible Asserted Effect:
It was identified that management had turnover in the financial aid department, which caused delays in
recording and processing refunds among the accounting and accounts payable departments. This resulted
in a failure by the institution to make payment to the students within the 14-day timeframe required by the
Department of Education and did not obtain voluntary authorization from the student to retain the credit
balances. Therefore, this evidenced the lack of an appropriately designed control by the institution to
ensure credit balances are refunded to students within the timeframe requirements.
Condition Found:
The Institution utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for
transmissions of its enrollment reporting changes to the National Student Loan Data System (NSLDS). The
University receives the Enrollment Reporting Roster and updates it for changes in student status. The file is
sent to the Clearinghouse who transmits the updated information to NSLDS.
For a sample of 40 students who were recipients of Direct Loans or Pell Grants between January 1, 2023
and December 31, 2023 who had been identified as having withdrawn, graduated, or modified their
enrollment status as defined by the University’s Satisfactory Academic Progress Policy through a change in
course load, the following were noted:
• 2023-003: For 2 of the 40 students selected for enrollment reporting testing, the student’s program
level enrollment effective date did not agree to that of their campus level data and/or the data per the
institution’s records. This represents 1 out of 9 high-risk data elements within the program level data
element requirements.
• 2023-004: For 1 student out of 40 selected for testwork, comparison of the institution’s records to that
of NSLDS evidenced that enrollment reporting for these students were not reported to NSLDS on a
timely basis. Therefore, management did not report the status changes to NSLDS within the required
timeframe of 60 days from the date they became aware of the change.
Cause and Possible Asserted Effect:
2023-003: The Institution’s controls over its review of the recording and communication of these status
changes does not operate consistently to ensure that individuals’ enrollment statuses are completely and
accurately communicated to NSLDS at the program level details.
2023-004: Management’s review over its enrollment reporting requirements for SFA was not operating as
designed to ensure timely reporting of status changes. Management sent the status change to the
Clearinghouse within the required timeframe; however, NSC did not send the data to NSLDS until after the
60-day requirement. As such, management’s control did not operate at a precise enough level to detect
and prevent noncompliance.
Further, the institution failed to maintain adequate review and documentation over student enrollment
status changes, resulting in a delay timeliness and inaccuracy of reporting to NSLDS.
Condition Found:
The Institution utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for
transmissions of its enrollment reporting changes to the National Student Loan Data System (NSLDS). The
University receives the Enrollment Reporting Roster and updates it for changes in student status. The file is
sent to the Clearinghouse who transmits the updated information to NSLDS.
For a sample of 40 students who were recipients of Direct Loans or Pell Grants between January 1, 2023
and December 31, 2023 who had been identified as having withdrawn, graduated, or modified their
enrollment status as defined by the University’s Satisfactory Academic Progress Policy through a change in
course load, the following were noted:
• 2023-003: For 2 of the 40 students selected for enrollment reporting testing, the student’s program
level enrollment effective date did not agree to that of their campus level data and/or the data per the
institution’s records. This represents 1 out of 9 high-risk data elements within the program level data
element requirements.
• 2023-004: For 1 student out of 40 selected for testwork, comparison of the institution’s records to that
of NSLDS evidenced that enrollment reporting for these students were not reported to NSLDS on a
timely basis. Therefore, management did not report the status changes to NSLDS within the required
timeframe of 60 days from the date they became aware of the change.
Cause and Possible Asserted Effect:
2023-003: The Institution’s controls over its review of the recording and communication of these status
changes does not operate consistently to ensure that individuals’ enrollment statuses are completely and
accurately communicated to NSLDS at the program level details.
2023-004: Management’s review over its enrollment reporting requirements for SFA was not operating as
designed to ensure timely reporting of status changes. Management sent the status change to the
Clearinghouse within the required timeframe; however, NSC did not send the data to NSLDS until after the
60-day requirement. As such, management’s control did not operate at a precise enough level to detect
and prevent noncompliance.
Further, the institution failed to maintain adequate review and documentation over student enrollment
status changes, resulting in a delay timeliness and inaccuracy of reporting to NSLDS.
Condition Found:
For 12 students out of 40 selected for testwork, the institution inaccurately reported their date of
disbursement of the award to the COD system, which represents one out of the six required data elements
to be reported to the COD. The differences in disbursement dates ranged from 1 to 4 days.
For 2 students out of 40 selected for testwork, the institution inaccurately reported the date of enrollment of
the student to the COD system, which represents one out of the six required data elements to be reported
to the COD. The differences in enrollment dates were 3 days.
For 15 students out of 40 selected for testwork, the institution inaccurately reported the Academic End
dates of the student to the COD system, which represents one out of the six required data elements to be
reported to the COD. However, the differences in academic end dates ranged from 1 to 75 days, the
majority of which were within 1 to 2 days, 1 sample was had a 46-day variance, 1 sample had a 74-day
variance and the 1 sample had a 75-day variance.
Out of the 29 discrepancies identified above, 9 of the samples had inaccurate data for 2 elements
(disbursement date and academic end date) and the remaining samples had inaccurate data for 1 element
each.
Cause and Possible Asserted Effect:
The institution’s control to reconcile the data between the institution’s records and COD system did not
operate consistently to ensure accurate data is reported to COD on a timely basis.
Condition Found:
For 19 out of 40 students selected for testwork, the Title IV funds credited to the student resulted in a credit
balance owed to the student. The institution did not refund the credit balances back to the student for more
than a period of 14 days and did not obtain proper authorizations from the student to retain the balance.
The delay in repayment ranged from 15 to 102 days.
Cause and Possible Asserted Effect:
It was identified that management had turnover in the financial aid department, which caused delays in
recording and processing refunds among the accounting and accounts payable departments. This resulted
in a failure by the institution to make payment to the students within the 14-day timeframe required by the
Department of Education and did not obtain voluntary authorization from the student to retain the credit
balances. Therefore, this evidenced the lack of an appropriately designed control by the institution to
ensure credit balances are refunded to students within the timeframe requirements.
Condition Found:
The Institution utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for
transmissions of its enrollment reporting changes to the National Student Loan Data System (NSLDS). The
University receives the Enrollment Reporting Roster and updates it for changes in student status. The file is
sent to the Clearinghouse who transmits the updated information to NSLDS.
For a sample of 40 students who were recipients of Direct Loans or Pell Grants between January 1, 2023
and December 31, 2023 who had been identified as having withdrawn, graduated, or modified their
enrollment status as defined by the University’s Satisfactory Academic Progress Policy through a change in
course load, the following were noted:
• 2023-003: For 2 of the 40 students selected for enrollment reporting testing, the student’s program
level enrollment effective date did not agree to that of their campus level data and/or the data per the
institution’s records. This represents 1 out of 9 high-risk data elements within the program level data
element requirements.
• 2023-004: For 1 student out of 40 selected for testwork, comparison of the institution’s records to that
of NSLDS evidenced that enrollment reporting for these students were not reported to NSLDS on a
timely basis. Therefore, management did not report the status changes to NSLDS within the required
timeframe of 60 days from the date they became aware of the change.
Cause and Possible Asserted Effect:
2023-003: The Institution’s controls over its review of the recording and communication of these status
changes does not operate consistently to ensure that individuals’ enrollment statuses are completely and
accurately communicated to NSLDS at the program level details.
2023-004: Management’s review over its enrollment reporting requirements for SFA was not operating as
designed to ensure timely reporting of status changes. Management sent the status change to the
Clearinghouse within the required timeframe; however, NSC did not send the data to NSLDS until after the
60-day requirement. As such, management’s control did not operate at a precise enough level to detect
and prevent noncompliance.
Further, the institution failed to maintain adequate review and documentation over student enrollment
status changes, resulting in a delay timeliness and inaccuracy of reporting to NSLDS.
Condition Found:
The Institution utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for
transmissions of its enrollment reporting changes to the National Student Loan Data System (NSLDS). The
University receives the Enrollment Reporting Roster and updates it for changes in student status. The file is
sent to the Clearinghouse who transmits the updated information to NSLDS.
For a sample of 40 students who were recipients of Direct Loans or Pell Grants between January 1, 2023
and December 31, 2023 who had been identified as having withdrawn, graduated, or modified their
enrollment status as defined by the University’s Satisfactory Academic Progress Policy through a change in
course load, the following were noted:
• 2023-003: For 2 of the 40 students selected for enrollment reporting testing, the student’s program
level enrollment effective date did not agree to that of their campus level data and/or the data per the
institution’s records. This represents 1 out of 9 high-risk data elements within the program level data
element requirements.
• 2023-004: For 1 student out of 40 selected for testwork, comparison of the institution’s records to that
of NSLDS evidenced that enrollment reporting for these students were not reported to NSLDS on a
timely basis. Therefore, management did not report the status changes to NSLDS within the required
timeframe of 60 days from the date they became aware of the change.
Cause and Possible Asserted Effect:
2023-003: The Institution’s controls over its review of the recording and communication of these status
changes does not operate consistently to ensure that individuals’ enrollment statuses are completely and
accurately communicated to NSLDS at the program level details.
2023-004: Management’s review over its enrollment reporting requirements for SFA was not operating as
designed to ensure timely reporting of status changes. Management sent the status change to the
Clearinghouse within the required timeframe; however, NSC did not send the data to NSLDS until after the
60-day requirement. As such, management’s control did not operate at a precise enough level to detect
and prevent noncompliance.
Further, the institution failed to maintain adequate review and documentation over student enrollment
status changes, resulting in a delay timeliness and inaccuracy of reporting to NSLDS.
Condition Found:
For 12 students out of 40 selected for testwork, the institution inaccurately reported their date of
disbursement of the award to the COD system, which represents one out of the six required data elements
to be reported to the COD. The differences in disbursement dates ranged from 1 to 4 days.
For 2 students out of 40 selected for testwork, the institution inaccurately reported the date of enrollment of
the student to the COD system, which represents one out of the six required data elements to be reported
to the COD. The differences in enrollment dates were 3 days.
For 15 students out of 40 selected for testwork, the institution inaccurately reported the Academic End
dates of the student to the COD system, which represents one out of the six required data elements to be
reported to the COD. However, the differences in academic end dates ranged from 1 to 75 days, the
majority of which were within 1 to 2 days, 1 sample was had a 46-day variance, 1 sample had a 74-day
variance and the 1 sample had a 75-day variance.
Out of the 29 discrepancies identified above, 9 of the samples had inaccurate data for 2 elements
(disbursement date and academic end date) and the remaining samples had inaccurate data for 1 element
each.
Cause and Possible Asserted Effect:
The institution’s control to reconcile the data between the institution’s records and COD system did not
operate consistently to ensure accurate data is reported to COD on a timely basis.
Condition Found:
For 19 out of 40 students selected for testwork, the Title IV funds credited to the student resulted in a credit
balance owed to the student. The institution did not refund the credit balances back to the student for more
than a period of 14 days and did not obtain proper authorizations from the student to retain the balance.
The delay in repayment ranged from 15 to 102 days.
Cause and Possible Asserted Effect:
It was identified that management had turnover in the financial aid department, which caused delays in
recording and processing refunds among the accounting and accounts payable departments. This resulted
in a failure by the institution to make payment to the students within the 14-day timeframe required by the
Department of Education and did not obtain voluntary authorization from the student to retain the credit
balances. Therefore, this evidenced the lack of an appropriately designed control by the institution to
ensure credit balances are refunded to students within the timeframe requirements.
Condition Found:
The Institution utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for
transmissions of its enrollment reporting changes to the National Student Loan Data System (NSLDS). The
University receives the Enrollment Reporting Roster and updates it for changes in student status. The file is
sent to the Clearinghouse who transmits the updated information to NSLDS.
For a sample of 40 students who were recipients of Direct Loans or Pell Grants between January 1, 2023
and December 31, 2023 who had been identified as having withdrawn, graduated, or modified their
enrollment status as defined by the University’s Satisfactory Academic Progress Policy through a change in
course load, the following were noted:
• 2023-003: For 2 of the 40 students selected for enrollment reporting testing, the student’s program
level enrollment effective date did not agree to that of their campus level data and/or the data per the
institution’s records. This represents 1 out of 9 high-risk data elements within the program level data
element requirements.
• 2023-004: For 1 student out of 40 selected for testwork, comparison of the institution’s records to that
of NSLDS evidenced that enrollment reporting for these students were not reported to NSLDS on a
timely basis. Therefore, management did not report the status changes to NSLDS within the required
timeframe of 60 days from the date they became aware of the change.
Cause and Possible Asserted Effect:
2023-003: The Institution’s controls over its review of the recording and communication of these status
changes does not operate consistently to ensure that individuals’ enrollment statuses are completely and
accurately communicated to NSLDS at the program level details.
2023-004: Management’s review over its enrollment reporting requirements for SFA was not operating as
designed to ensure timely reporting of status changes. Management sent the status change to the
Clearinghouse within the required timeframe; however, NSC did not send the data to NSLDS until after the
60-day requirement. As such, management’s control did not operate at a precise enough level to detect
and prevent noncompliance.
Further, the institution failed to maintain adequate review and documentation over student enrollment
status changes, resulting in a delay timeliness and inaccuracy of reporting to NSLDS.
Condition Found:
The Institution utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for
transmissions of its enrollment reporting changes to the National Student Loan Data System (NSLDS). The
University receives the Enrollment Reporting Roster and updates it for changes in student status. The file is
sent to the Clearinghouse who transmits the updated information to NSLDS.
For a sample of 40 students who were recipients of Direct Loans or Pell Grants between January 1, 2023
and December 31, 2023 who had been identified as having withdrawn, graduated, or modified their
enrollment status as defined by the University’s Satisfactory Academic Progress Policy through a change in
course load, the following were noted:
• 2023-003: For 2 of the 40 students selected for enrollment reporting testing, the student’s program
level enrollment effective date did not agree to that of their campus level data and/or the data per the
institution’s records. This represents 1 out of 9 high-risk data elements within the program level data
element requirements.
• 2023-004: For 1 student out of 40 selected for testwork, comparison of the institution’s records to that
of NSLDS evidenced that enrollment reporting for these students were not reported to NSLDS on a
timely basis. Therefore, management did not report the status changes to NSLDS within the required
timeframe of 60 days from the date they became aware of the change.
Cause and Possible Asserted Effect:
2023-003: The Institution’s controls over its review of the recording and communication of these status
changes does not operate consistently to ensure that individuals’ enrollment statuses are completely and
accurately communicated to NSLDS at the program level details.
2023-004: Management’s review over its enrollment reporting requirements for SFA was not operating as
designed to ensure timely reporting of status changes. Management sent the status change to the
Clearinghouse within the required timeframe; however, NSC did not send the data to NSLDS until after the
60-day requirement. As such, management’s control did not operate at a precise enough level to detect
and prevent noncompliance.
Further, the institution failed to maintain adequate review and documentation over student enrollment
status changes, resulting in a delay timeliness and inaccuracy of reporting to NSLDS.