Audit 314659

Finding 2023-001 - Significant Deficiency: Special Tests and Provisions - Control Finding ALN 84.063 - Federal Pell Grant Program and 84.268 - Federal Direct Student Loan Program - Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 682.610 (and further clarified in the November 2022 National Student Loan Data System (NSLDS) Enrollment Reporting Guide), a University is required to certify changes in enrollment data for students within 60 days of the change. Universities are responsible for accurately reporting certain key information, such as the OPEID number, enrollment effective date, enrollment status, graduation status and certification date. Condition: The University recently implemented a revised process and related set of internal controls to ensure that the required enrollment information is submitted to NSLDS accurately. While the University’s standard process includes reporting changes in enrollment status every 30 days to the National Student Clearinghouse (NSC), the updated process included fixed dates for submitting degree verification status updates. Due to multiple start terms (including variable), and the ability for students to have multiple active programs, the error reports were quite large; and therefore, the University began quarterly reporting of graduated status to the National Student Clearinghouse to reduce errors despite the 60-day requirement period. Cause: The process and related internal controls surrounding enrollment reporting related to degree verification through NSC were not designed to ensure timely certification of enrollment reporting changes for graduation statuses, within the 60-day requirement period to NSLDS. Effect: The University’s controls may not prevent potential errors related to timely certification of enrollment reporting. Questioned Costs: Not applicable. Context: Our audit sample of 40 students did not indicate any instances of noncompliance related to enrollment reporting. However, our understanding of the process and internal controls deployed by the University for this compliance requirement did identify a significant deficiency in the design of the internal controls that indicates a likelihood for noncompliance with the enrollment reporting requirements is present. Recommendation: The University should revise the process and internal controls surrounding enrollment reporting to ensure that all enrollment reporting status changes are certified to NSC and thereby NSLDS within the 60-day requirement period. Views Of Responsible Officials: The University acknowledges that the enrollment report update calendar was set to only certify changes four times per year in the 2022-2023 award year.

Finding 2023-001 - Significant Deficiency: Special Tests and Provisions - Control Finding ALN 84.063 - Federal Pell Grant Program and 84.268 - Federal Direct Student Loan Program - Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 682.610 (and further clarified in the November 2022 National Student Loan Data System (NSLDS) Enrollment Reporting Guide), a University is required to certify changes in enrollment data for students within 60 days of the change. Universities are responsible for accurately reporting certain key information, such as the OPEID number, enrollment effective date, enrollment status, graduation status and certification date. Condition: The University recently implemented a revised process and related set of internal controls to ensure that the required enrollment information is submitted to NSLDS accurately. While the University’s standard process includes reporting changes in enrollment status every 30 days to the National Student Clearinghouse (NSC), the updated process included fixed dates for submitting degree verification status updates. Due to multiple start terms (including variable), and the ability for students to have multiple active programs, the error reports were quite large; and therefore, the University began quarterly reporting of graduated status to the National Student Clearinghouse to reduce errors despite the 60-day requirement period. Cause: The process and related internal controls surrounding enrollment reporting related to degree verification through NSC were not designed to ensure timely certification of enrollment reporting changes for graduation statuses, within the 60-day requirement period to NSLDS. Effect: The University’s controls may not prevent potential errors related to timely certification of enrollment reporting. Questioned Costs: Not applicable. Context: Our audit sample of 40 students did not indicate any instances of noncompliance related to enrollment reporting. However, our understanding of the process and internal controls deployed by the University for this compliance requirement did identify a significant deficiency in the design of the internal controls that indicates a likelihood for noncompliance with the enrollment reporting requirements is present. Recommendation: The University should revise the process and internal controls surrounding enrollment reporting to ensure that all enrollment reporting status changes are certified to NSC and thereby NSLDS within the 60-day requirement period. Views Of Responsible Officials: The University acknowledges that the enrollment report update calendar was set to only certify changes four times per year in the 2022-2023 award year.

Finding 2023-001 - Significant Deficiency: Special Tests and Provisions - Control Finding ALN 84.063 - Federal Pell Grant Program and 84.268 - Federal Direct Student Loan Program - Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 682.610 (and further clarified in the November 2022 National Student Loan Data System (NSLDS) Enrollment Reporting Guide), a University is required to certify changes in enrollment data for students within 60 days of the change. Universities are responsible for accurately reporting certain key information, such as the OPEID number, enrollment effective date, enrollment status, graduation status and certification date. Condition: The University recently implemented a revised process and related set of internal controls to ensure that the required enrollment information is submitted to NSLDS accurately. While the University’s standard process includes reporting changes in enrollment status every 30 days to the National Student Clearinghouse (NSC), the updated process included fixed dates for submitting degree verification status updates. Due to multiple start terms (including variable), and the ability for students to have multiple active programs, the error reports were quite large; and therefore, the University began quarterly reporting of graduated status to the National Student Clearinghouse to reduce errors despite the 60-day requirement period. Cause: The process and related internal controls surrounding enrollment reporting related to degree verification through NSC were not designed to ensure timely certification of enrollment reporting changes for graduation statuses, within the 60-day requirement period to NSLDS. Effect: The University’s controls may not prevent potential errors related to timely certification of enrollment reporting. Questioned Costs: Not applicable. Context: Our audit sample of 40 students did not indicate any instances of noncompliance related to enrollment reporting. However, our understanding of the process and internal controls deployed by the University for this compliance requirement did identify a significant deficiency in the design of the internal controls that indicates a likelihood for noncompliance with the enrollment reporting requirements is present. Recommendation: The University should revise the process and internal controls surrounding enrollment reporting to ensure that all enrollment reporting status changes are certified to NSC and thereby NSLDS within the 60-day requirement period. Views Of Responsible Officials: The University acknowledges that the enrollment report update calendar was set to only certify changes four times per year in the 2022-2023 award year.

Finding 2023-001 - Significant Deficiency: Special Tests and Provisions - Control Finding ALN 84.063 - Federal Pell Grant Program and 84.268 - Federal Direct Student Loan Program - Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 682.610 (and further clarified in the November 2022 National Student Loan Data System (NSLDS) Enrollment Reporting Guide), a University is required to certify changes in enrollment data for students within 60 days of the change. Universities are responsible for accurately reporting certain key information, such as the OPEID number, enrollment effective date, enrollment status, graduation status and certification date. Condition: The University recently implemented a revised process and related set of internal controls to ensure that the required enrollment information is submitted to NSLDS accurately. While the University’s standard process includes reporting changes in enrollment status every 30 days to the National Student Clearinghouse (NSC), the updated process included fixed dates for submitting degree verification status updates. Due to multiple start terms (including variable), and the ability for students to have multiple active programs, the error reports were quite large; and therefore, the University began quarterly reporting of graduated status to the National Student Clearinghouse to reduce errors despite the 60-day requirement period. Cause: The process and related internal controls surrounding enrollment reporting related to degree verification through NSC were not designed to ensure timely certification of enrollment reporting changes for graduation statuses, within the 60-day requirement period to NSLDS. Effect: The University’s controls may not prevent potential errors related to timely certification of enrollment reporting. Questioned Costs: Not applicable. Context: Our audit sample of 40 students did not indicate any instances of noncompliance related to enrollment reporting. However, our understanding of the process and internal controls deployed by the University for this compliance requirement did identify a significant deficiency in the design of the internal controls that indicates a likelihood for noncompliance with the enrollment reporting requirements is present. Recommendation: The University should revise the process and internal controls surrounding enrollment reporting to ensure that all enrollment reporting status changes are certified to NSC and thereby NSLDS within the 60-day requirement period. Views Of Responsible Officials: The University acknowledges that the enrollment report update calendar was set to only certify changes four times per year in the 2022-2023 award year.