Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in a student’s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not expect its next Roster File to NSLDS within 60 days.
Condition: The University did not report students’ status changes accurately and within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with required federal guidelines.
Questioned Costs: None.
Context:
Program Level: Based on a sample of 25 students, 1 student’s program begin date was not accurately reported to the NSLDS.
Campus Level: Based on a sample of 25 students, 2 students selected were not reported to the NSLDS within the required timeframe.
Identification of Repeat Finding: This is a new finding for FY2024.
Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner.
Views of Responsible Officials: The University will report to the National Student Clearing (NSC) House using regularly scheduled enrollment reports every 30 days. Suppose a student’s enrollment status is not captured in the regularly scheduled enrollment reports with the NSC. In that case, the enrollment reporting will be reported
directly to the National Student Loan Database Service(NSLDS), such as after the end of the term once grades are
processed. The enrollment reporting in which a student receives a failing grade of all “Fs” for a quarter will be adjusted to meet the reporting time frame.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in a student’s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not expect its next Roster File to NSLDS within 60 days.
Condition: The University did not report students’ status changes accurately and within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with required federal guidelines.
Questioned Costs: None.
Context:
Program Level: Based on a sample of 25 students, 1 student’s program begin date was not accurately reported to the NSLDS.
Campus Level: Based on a sample of 25 students, 2 students selected were not reported to the NSLDS within the required timeframe.
Identification of Repeat Finding: This is a new finding for FY2024.
Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner.
Views of Responsible Officials: The University will report to the National Student Clearing (NSC) House using regularly scheduled enrollment reports every 30 days. Suppose a student’s enrollment status is not captured in the regularly scheduled enrollment reports with the NSC. In that case, the enrollment reporting will be reported
directly to the National Student Loan Database Service(NSLDS), such as after the end of the term once grades are
processed. The enrollment reporting in which a student receives a failing grade of all “Fs” for a quarter will be adjusted to meet the reporting time frame.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in a student’s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not expect its next Roster File to NSLDS within 60 days.
Condition: The University did not report students’ status changes accurately and within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with required federal guidelines.
Questioned Costs: None.
Context:
Program Level: Based on a sample of 25 students, 1 student’s program begin date was not accurately reported to the NSLDS.
Campus Level: Based on a sample of 25 students, 2 students selected were not reported to the NSLDS within the required timeframe.
Identification of Repeat Finding: This is a new finding for FY2024.
Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner.
Views of Responsible Officials: The University will report to the National Student Clearing (NSC) House using regularly scheduled enrollment reports every 30 days. Suppose a student’s enrollment status is not captured in the regularly scheduled enrollment reports with the NSC. In that case, the enrollment reporting will be reported
directly to the National Student Loan Database Service(NSLDS), such as after the end of the term once grades are
processed. The enrollment reporting in which a student receives a failing grade of all “Fs” for a quarter will be adjusted to meet the reporting time frame.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in a student’s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not expect its next Roster File to NSLDS within 60 days.
Condition: The University did not report students’ status changes accurately and within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with required federal guidelines.
Questioned Costs: None.
Context:
Program Level: Based on a sample of 25 students, 1 student’s program begin date was not accurately reported to the NSLDS.
Campus Level: Based on a sample of 25 students, 2 students selected were not reported to the NSLDS within the required timeframe.
Identification of Repeat Finding: This is a new finding for FY2024.
Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner.
Views of Responsible Officials: The University will report to the National Student Clearing (NSC) House using regularly scheduled enrollment reports every 30 days. Suppose a student’s enrollment status is not captured in the regularly scheduled enrollment reports with the NSC. In that case, the enrollment reporting will be reported
directly to the National Student Loan Database Service(NSLDS), such as after the end of the term once grades are
processed. The enrollment reporting in which a student receives a failing grade of all “Fs” for a quarter will be adjusted to meet the reporting time frame.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Disbursement to or on Behalf of Students: Federal regulation 88 FR 41092 states an institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement.
Condition: The University did not report student’s direct loan disbursement to the COD within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with required federal guidelines.
Questioned Costs: None.
Context: Direct Loan COD disbursement: Based on a sample of 25 Direct loan disbursements tested, 1 instance of a student’s Direct Loan disbursement was not reported to COD within 15 days as required.
Identification of Repeat Finding: This is a new finding for FY2024.
Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner.
Views of Responsible Officials: After speaking with a Common Origination and Disbursement (COD) system representative, she stated that schools will receive a Warning Edit 055 when record of disbursement has not been received after 30 days. She verified that we did not receive this Warning Edit 055 from COD because we had not exceeded 30 days. The COD rep went on to share that this 15-day regulation used to be a 30-day regulation, but COD has not updated their Warning Edit 055 process to notify schools. It’s only done after 30 days. COD rep did identify a report Michelle will run to identify anyone who is not showing up with a disbursement record prior
to the 15 days. The COD report is called the Anticipated Disbursement Queue and will be ran every 14 days to identify any potential issues.
Federal Program Information: Student Financial Assistance Cluster: Federal Perkins Loans (Assistance Listing # 84.038)
Criteria or Specific Requirement: N. Special Tests and Provisions – Perkins Loan Recordkeeping and Record Retention: Federal regulation 34 CFR 674.19.(e) states an institution shall keep the original promissory notes and repayment schedules until the loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents.
Condition: The University did not maintain copies of student’s promissory notes for the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with required federal guidelines.
Questioned Costs: None.
Context: Based on a sample of 25 Perkins Loans tested, 2 instances of a student’s Perkins master promissory note was not retained by the university as required.
Identification of Repeat Finding: This is a new finding for FY2024.
Recommendation: The University should implement procedures to ensure that Perkins promissory notes are properly maintained.
Views of Responsible Officials: The following steps outline the corrective actions that will be taken to resolve this issue:
1. Contact the Borrower - Life University will initiate contact with the borrower to inform them of the need to update or establish a new MPN or equivalent documentation. This will be done via the following communication channels:
• Phone call (if available)
• Email notification
• Postal mail (if no response is received through other means)
2. Provide Clear Instructions for Documentation - The university will send a formal notice to the borrower detailing the need for a new MPN or equivalent documentation. This will include instructions on how to sign the new agreement, the importance of the MPN, and a clear explanation of the implications for the outstanding loan amount.
3. Reassign Collection Rights - Once the borrower has completed the required documentation, Life University will work with ECSI to reassign the university’s right to collect on the remaining balance.
4. Documentation Review and Verification - After the MPN is completed by the borrower, Life University will review the new MPN for completeness and accuracy. This review will ensure that the terms are correctly documented, that the borrower’s consent is properly obtained, and that the right to collect on the outstanding amount is clearly assigned.
5. Update Financial Records - Life University will update its financial records to reflect the new MPN and the re assigned collection rights. The university will also ensure that any outstanding amounts and repayment schedules are updated accordingly.
6. Ongoing Communication and Monitoring - The university will maintain communication with the borrower throughout the process, providing reminders if necessary.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in a student’s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not expect its next Roster File to NSLDS within 60 days.
Condition: The University did not report students’ status changes accurately and within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with required federal guidelines.
Questioned Costs: None.
Context:
Program Level: Based on a sample of 25 students, 1 student’s program begin date was not accurately reported to the NSLDS.
Campus Level: Based on a sample of 25 students, 2 students selected were not reported to the NSLDS within the required timeframe.
Identification of Repeat Finding: This is a new finding for FY2024.
Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner.
Views of Responsible Officials: The University will report to the National Student Clearing (NSC) House using regularly scheduled enrollment reports every 30 days. Suppose a student’s enrollment status is not captured in the regularly scheduled enrollment reports with the NSC. In that case, the enrollment reporting will be reported
directly to the National Student Loan Database Service(NSLDS), such as after the end of the term once grades are
processed. The enrollment reporting in which a student receives a failing grade of all “Fs” for a quarter will be adjusted to meet the reporting time frame.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in a student’s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not expect its next Roster File to NSLDS within 60 days.
Condition: The University did not report students’ status changes accurately and within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with required federal guidelines.
Questioned Costs: None.
Context:
Program Level: Based on a sample of 25 students, 1 student’s program begin date was not accurately reported to the NSLDS.
Campus Level: Based on a sample of 25 students, 2 students selected were not reported to the NSLDS within the required timeframe.
Identification of Repeat Finding: This is a new finding for FY2024.
Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner.
Views of Responsible Officials: The University will report to the National Student Clearing (NSC) House using regularly scheduled enrollment reports every 30 days. Suppose a student’s enrollment status is not captured in the regularly scheduled enrollment reports with the NSC. In that case, the enrollment reporting will be reported
directly to the National Student Loan Database Service(NSLDS), such as after the end of the term once grades are
processed. The enrollment reporting in which a student receives a failing grade of all “Fs” for a quarter will be adjusted to meet the reporting time frame.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in a student’s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not expect its next Roster File to NSLDS within 60 days.
Condition: The University did not report students’ status changes accurately and within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with required federal guidelines.
Questioned Costs: None.
Context:
Program Level: Based on a sample of 25 students, 1 student’s program begin date was not accurately reported to the NSLDS.
Campus Level: Based on a sample of 25 students, 2 students selected were not reported to the NSLDS within the required timeframe.
Identification of Repeat Finding: This is a new finding for FY2024.
Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner.
Views of Responsible Officials: The University will report to the National Student Clearing (NSC) House using regularly scheduled enrollment reports every 30 days. Suppose a student’s enrollment status is not captured in the regularly scheduled enrollment reports with the NSC. In that case, the enrollment reporting will be reported
directly to the National Student Loan Database Service(NSLDS), such as after the end of the term once grades are
processed. The enrollment reporting in which a student receives a failing grade of all “Fs” for a quarter will be adjusted to meet the reporting time frame.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in a student’s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not expect its next Roster File to NSLDS within 60 days.
Condition: The University did not report students’ status changes accurately and within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with required federal guidelines.
Questioned Costs: None.
Context:
Program Level: Based on a sample of 25 students, 1 student’s program begin date was not accurately reported to the NSLDS.
Campus Level: Based on a sample of 25 students, 2 students selected were not reported to the NSLDS within the required timeframe.
Identification of Repeat Finding: This is a new finding for FY2024.
Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner.
Views of Responsible Officials: The University will report to the National Student Clearing (NSC) House using regularly scheduled enrollment reports every 30 days. Suppose a student’s enrollment status is not captured in the regularly scheduled enrollment reports with the NSC. In that case, the enrollment reporting will be reported
directly to the National Student Loan Database Service(NSLDS), such as after the end of the term once grades are
processed. The enrollment reporting in which a student receives a failing grade of all “Fs” for a quarter will be adjusted to meet the reporting time frame.
Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268)
Criteria or Specific Requirement: N. Special Tests and Provisions – Disbursement to or on Behalf of Students: Federal regulation 88 FR 41092 states an institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement.
Condition: The University did not report student’s direct loan disbursement to the COD within the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with required federal guidelines.
Questioned Costs: None.
Context: Direct Loan COD disbursement: Based on a sample of 25 Direct loan disbursements tested, 1 instance of a student’s Direct Loan disbursement was not reported to COD within 15 days as required.
Identification of Repeat Finding: This is a new finding for FY2024.
Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner.
Views of Responsible Officials: After speaking with a Common Origination and Disbursement (COD) system representative, she stated that schools will receive a Warning Edit 055 when record of disbursement has not been received after 30 days. She verified that we did not receive this Warning Edit 055 from COD because we had not exceeded 30 days. The COD rep went on to share that this 15-day regulation used to be a 30-day regulation, but COD has not updated their Warning Edit 055 process to notify schools. It’s only done after 30 days. COD rep did identify a report Michelle will run to identify anyone who is not showing up with a disbursement record prior
to the 15 days. The COD report is called the Anticipated Disbursement Queue and will be ran every 14 days to identify any potential issues.
Federal Program Information: Student Financial Assistance Cluster: Federal Perkins Loans (Assistance Listing # 84.038)
Criteria or Specific Requirement: N. Special Tests and Provisions – Perkins Loan Recordkeeping and Record Retention: Federal regulation 34 CFR 674.19.(e) states an institution shall keep the original promissory notes and repayment schedules until the loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents.
Condition: The University did not maintain copies of student’s promissory notes for the required timeframe.
Cause: Administrative oversight.
Effect or Possible Effect: The University was not in compliance with required federal guidelines.
Questioned Costs: None.
Context: Based on a sample of 25 Perkins Loans tested, 2 instances of a student’s Perkins master promissory note was not retained by the university as required.
Identification of Repeat Finding: This is a new finding for FY2024.
Recommendation: The University should implement procedures to ensure that Perkins promissory notes are properly maintained.
Views of Responsible Officials: The following steps outline the corrective actions that will be taken to resolve this issue:
1. Contact the Borrower - Life University will initiate contact with the borrower to inform them of the need to update or establish a new MPN or equivalent documentation. This will be done via the following communication channels:
• Phone call (if available)
• Email notification
• Postal mail (if no response is received through other means)
2. Provide Clear Instructions for Documentation - The university will send a formal notice to the borrower detailing the need for a new MPN or equivalent documentation. This will include instructions on how to sign the new agreement, the importance of the MPN, and a clear explanation of the implications for the outstanding loan amount.
3. Reassign Collection Rights - Once the borrower has completed the required documentation, Life University will work with ECSI to reassign the university’s right to collect on the remaining balance.
4. Documentation Review and Verification - After the MPN is completed by the borrower, Life University will review the new MPN for completeness and accuracy. This review will ensure that the terms are correctly documented, that the borrower’s consent is properly obtained, and that the right to collect on the outstanding amount is clearly assigned.
5. Update Financial Records - Life University will update its financial records to reflect the new MPN and the re assigned collection rights. The university will also ensure that any outstanding amounts and repayment schedules are updated accordingly.
6. Ongoing Communication and Monitoring - The university will maintain communication with the borrower throughout the process, providing reminders if necessary.