Audit 331458

Finding 2024-002 – Special Tests and Provisions – Enrollment Reporting – Material Weakness in Internal Control Over Compliance (See SFQC - Section III - Federal Award Findings and Questioned Costs - Finding 2024-002 for table included) Criteria: The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information. It is Woodbury University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes. Woodbury University is ultimately responsible for the timeliness and accuracy of this information even when a third-party servicer is used as an intermediary to report on the University’s behalf. Woodbury University currently contracts with a third-party servicer and has elected to receive an Enrollment Reporting roster file every 30 days from NSLDS. At a minimum, institutions must certify the enrollment status of all students included on the roster file within 15 days of receiving the roster file. If errors are identified, the University has 10 days to resubmit a corrected response. Unless the school expects to complete its next roster file within 60 days, the school must notify the secretary within 30 days, if it discovers that a student who received a loan under Title IV of the Act either did not enroll or ceased to be enrolled on at least a half-time basis (34 CFR section 685.309). Condition/context: From a system generated population of 119 students who received federal aid and either graduated, withdrew, or changed their permanent address during the year ended June 30, 2024, we selected a sample of 17 students who received direct loans. We find this sample representative to the population. The enrollment information and withdrawal or graduation date per the Woodbury University’s records were compared to the information reported to NSLDS in order to determine if status changes were reported accurately and within the required timeframes. Of the 17 students selected for testing, 17 were not reported to the NSLDS within the required timeframe and had an incorrect status reported to the NSLDS. Questioned Costs: No questioned costs were identified as part of this finding. Effect: The NSLDS database did not include all accurate information in the timeframe required by ED. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine inschool status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Cause: The lack of timely reporting was caused by turnover in the Registrar’s office. Repeat finding: Yes, see 2023-002. Recommendation: Woodbury University should develop additional procedures and controls to monitor the accuracy of information provided to its third-party servicer and to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate. Each institution has access to manually correct information directly within NSLDS at any time. Views of responsible officials and planned corrective actions: Management agrees with the finding and recommendation and plans to implement additional controls.

Finding 2024-002 – Special Tests and Provisions – Enrollment Reporting – Material Weakness in Internal Control Over Compliance (See SFQC - Section III - Federal Award Findings and Questioned Costs - Finding 2024-002 for table included) Criteria: The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information. It is Woodbury University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes. Woodbury University is ultimately responsible for the timeliness and accuracy of this information even when a third-party servicer is used as an intermediary to report on the University’s behalf. Woodbury University currently contracts with a third-party servicer and has elected to receive an Enrollment Reporting roster file every 30 days from NSLDS. At a minimum, institutions must certify the enrollment status of all students included on the roster file within 15 days of receiving the roster file. If errors are identified, the University has 10 days to resubmit a corrected response. Unless the school expects to complete its next roster file within 60 days, the school must notify the secretary within 30 days, if it discovers that a student who received a loan under Title IV of the Act either did not enroll or ceased to be enrolled on at least a half-time basis (34 CFR section 685.309). Condition/context: From a system generated population of 119 students who received federal aid and either graduated, withdrew, or changed their permanent address during the year ended June 30, 2024, we selected a sample of 17 students who received direct loans. We find this sample representative to the population. The enrollment information and withdrawal or graduation date per the Woodbury University’s records were compared to the information reported to NSLDS in order to determine if status changes were reported accurately and within the required timeframes. Of the 17 students selected for testing, 17 were not reported to the NSLDS within the required timeframe and had an incorrect status reported to the NSLDS. Questioned Costs: No questioned costs were identified as part of this finding. Effect: The NSLDS database did not include all accurate information in the timeframe required by ED. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine inschool status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Cause: The lack of timely reporting was caused by turnover in the Registrar’s office. Repeat finding: Yes, see 2023-002. Recommendation: Woodbury University should develop additional procedures and controls to monitor the accuracy of information provided to its third-party servicer and to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate. Each institution has access to manually correct information directly within NSLDS at any time. Views of responsible officials and planned corrective actions: Management agrees with the finding and recommendation and plans to implement additional controls.