FINDING 2022-001 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/Context ? A sample of 34 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2021-2022 academic year. The enrollment information and withdrawal, address change, or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the permanent physical address change for 1 student was not reported within the required timeframe to the NSLDS. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school 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 University of San Diego contracts with a third-party intermediary to transmit enrollment information to NSLDS. Ultimately, the University of San Diego is responsible for the accuracy and timeliness of its reporting, regardless of whether it uses a third party. For the exceptions noted above, the student status change was not reported within the required time frame or not correctly reported due to the University of San Diego not having effective internal controls established to prevent or detect and correct the non-compliance in a timely manner. Repeat Finding ? This is a repeat finding. See 2021-001. Recommendation ? We recommend the University of San Diego revise its policies to establish a requirement that the list of graduates submitted to NSLDS be reviewed prior to and after being submitted to the NSLDS. We also recommend the University of San Diego establish an internal control to identify and report status changes prior to the established deadline. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with this finding. This student had a permanent physical address change before we implemented the change in the process described in finding 2021-001. During the 2021 audit, we identified that the exception to the timeframe for reporting a permanent physical address update was due to an incorrect parameter in the report used to provide the data as a result of employee turnover in the Registrar's Office. Management amended the report parameters to correctly report students who make permanent physical address changes and believes these enhancements will be sufficient to prevent future errors.
FINDING 2022-001 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/Context ? A sample of 34 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2021-2022 academic year. The enrollment information and withdrawal, address change, or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the permanent physical address change for 1 student was not reported within the required timeframe to the NSLDS. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school 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 University of San Diego contracts with a third-party intermediary to transmit enrollment information to NSLDS. Ultimately, the University of San Diego is responsible for the accuracy and timeliness of its reporting, regardless of whether it uses a third party. For the exceptions noted above, the student status change was not reported within the required time frame or not correctly reported due to the University of San Diego not having effective internal controls established to prevent or detect and correct the non-compliance in a timely manner. Repeat Finding ? This is a repeat finding. See 2021-001. Recommendation ? We recommend the University of San Diego revise its policies to establish a requirement that the list of graduates submitted to NSLDS be reviewed prior to and after being submitted to the NSLDS. We also recommend the University of San Diego establish an internal control to identify and report status changes prior to the established deadline. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with this finding. This student had a permanent physical address change before we implemented the change in the process described in finding 2021-001. During the 2021 audit, we identified that the exception to the timeframe for reporting a permanent physical address update was due to an incorrect parameter in the report used to provide the data as a result of employee turnover in the Registrar's Office. Management amended the report parameters to correctly report students who make permanent physical address changes and believes these enhancements will be sufficient to prevent future errors.
FINDING 2022-001 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/Context ? A sample of 34 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2021-2022 academic year. The enrollment information and withdrawal, address change, or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the permanent physical address change for 1 student was not reported within the required timeframe to the NSLDS. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school 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 University of San Diego contracts with a third-party intermediary to transmit enrollment information to NSLDS. Ultimately, the University of San Diego is responsible for the accuracy and timeliness of its reporting, regardless of whether it uses a third party. For the exceptions noted above, the student status change was not reported within the required time frame or not correctly reported due to the University of San Diego not having effective internal controls established to prevent or detect and correct the non-compliance in a timely manner. Repeat Finding ? This is a repeat finding. See 2021-001. Recommendation ? We recommend the University of San Diego revise its policies to establish a requirement that the list of graduates submitted to NSLDS be reviewed prior to and after being submitted to the NSLDS. We also recommend the University of San Diego establish an internal control to identify and report status changes prior to the established deadline. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with this finding. This student had a permanent physical address change before we implemented the change in the process described in finding 2021-001. During the 2021 audit, we identified that the exception to the timeframe for reporting a permanent physical address update was due to an incorrect parameter in the report used to provide the data as a result of employee turnover in the Registrar's Office. Management amended the report parameters to correctly report students who make permanent physical address changes and believes these enhancements will be sufficient to prevent future errors.
FINDING 2022-001 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/Context ? A sample of 34 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2021-2022 academic year. The enrollment information and withdrawal, address change, or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the permanent physical address change for 1 student was not reported within the required timeframe to the NSLDS. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school 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 University of San Diego contracts with a third-party intermediary to transmit enrollment information to NSLDS. Ultimately, the University of San Diego is responsible for the accuracy and timeliness of its reporting, regardless of whether it uses a third party. For the exceptions noted above, the student status change was not reported within the required time frame or not correctly reported due to the University of San Diego not having effective internal controls established to prevent or detect and correct the non-compliance in a timely manner. Repeat Finding ? This is a repeat finding. See 2021-001. Recommendation ? We recommend the University of San Diego revise its policies to establish a requirement that the list of graduates submitted to NSLDS be reviewed prior to and after being submitted to the NSLDS. We also recommend the University of San Diego establish an internal control to identify and report status changes prior to the established deadline. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with this finding. This student had a permanent physical address change before we implemented the change in the process described in finding 2021-001. During the 2021 audit, we identified that the exception to the timeframe for reporting a permanent physical address update was due to an incorrect parameter in the report used to provide the data as a result of employee turnover in the Registrar's Office. Management amended the report parameters to correctly report students who make permanent physical address changes and believes these enhancements will be sufficient to prevent future errors.
FINDING 2022-001 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/Context ? A sample of 34 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2021-2022 academic year. The enrollment information and withdrawal, address change, or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the permanent physical address change for 1 student was not reported within the required timeframe to the NSLDS. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school 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 University of San Diego contracts with a third-party intermediary to transmit enrollment information to NSLDS. Ultimately, the University of San Diego is responsible for the accuracy and timeliness of its reporting, regardless of whether it uses a third party. For the exceptions noted above, the student status change was not reported within the required time frame or not correctly reported due to the University of San Diego not having effective internal controls established to prevent or detect and correct the non-compliance in a timely manner. Repeat Finding ? This is a repeat finding. See 2021-001. Recommendation ? We recommend the University of San Diego revise its policies to establish a requirement that the list of graduates submitted to NSLDS be reviewed prior to and after being submitted to the NSLDS. We also recommend the University of San Diego establish an internal control to identify and report status changes prior to the established deadline. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with this finding. This student had a permanent physical address change before we implemented the change in the process described in finding 2021-001. During the 2021 audit, we identified that the exception to the timeframe for reporting a permanent physical address update was due to an incorrect parameter in the report used to provide the data as a result of employee turnover in the Registrar's Office. Management amended the report parameters to correctly report students who make permanent physical address changes and believes these enhancements will be sufficient to prevent future errors.
FINDING 2022-001 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/Context ? A sample of 34 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2021-2022 academic year. The enrollment information and withdrawal, address change, or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the permanent physical address change for 1 student was not reported within the required timeframe to the NSLDS. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school 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 University of San Diego contracts with a third-party intermediary to transmit enrollment information to NSLDS. Ultimately, the University of San Diego is responsible for the accuracy and timeliness of its reporting, regardless of whether it uses a third party. For the exceptions noted above, the student status change was not reported within the required time frame or not correctly reported due to the University of San Diego not having effective internal controls established to prevent or detect and correct the non-compliance in a timely manner. Repeat Finding ? This is a repeat finding. See 2021-001. Recommendation ? We recommend the University of San Diego revise its policies to establish a requirement that the list of graduates submitted to NSLDS be reviewed prior to and after being submitted to the NSLDS. We also recommend the University of San Diego establish an internal control to identify and report status changes prior to the established deadline. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with this finding. This student had a permanent physical address change before we implemented the change in the process described in finding 2021-001. During the 2021 audit, we identified that the exception to the timeframe for reporting a permanent physical address update was due to an incorrect parameter in the report used to provide the data as a result of employee turnover in the Registrar's Office. Management amended the report parameters to correctly report students who make permanent physical address changes and believes these enhancements will be sufficient to prevent future errors.
FINDING 2022-002 - Special Tests and Provisions - Borrower Data Transmission and Reconciliation: Significant Deficiency in Internal Control Over Compliance: See Schedule of Findings and Questioned Costs for Chart/Table. Criteria - 34 CFR 685.300(b)(5) - On a monthly basis, the school must reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Condition / Context - The University of San Diego operates a law school and an undergraduate and graduate school. A sample of 6 direct loan reconciliations were selected from the population of all reconciliations performed by the University, under both schools during the year ended June 30, 2022. We obtained the supporting schedules used to reconcile the disbursed direct loan funds to the federal government?s records. The University did not complete reconciliations of its direct loan program disbursements for the undergraduate and graduate school. Cause - The process for reconciling this data was revised during the year ended June 30, 2022, and the change was not reflected in the University of San Diego?s policies and procedures. There was turnover in the position responsible for reconciling this data, and the responsibility did not transfer to another individual, and as a result, the reconciliations were not completed. Effect - There is a chance that the University of San Diego?s records may not match the federal government?s records of direct loan disbursement. Repeat finding - This is not a repeat finding. Recommendation - We recommend the University revise its existing policies and procedures to accommodate the change. View of responsible officials - Management concurs with this finding. This exception was due to a change in the undergraduate and graduate school monthly reconciliation process that was not subsequently communicated during employee turnover in the Controller?s Office. Management updated the direct lending servicing system reconciliation procedures to accommodate the change in process. Management believes these enhancements will be sufficient to prevent future errors.
FINDING 2022-001 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/Context ? A sample of 34 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2021-2022 academic year. The enrollment information and withdrawal, address change, or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the permanent physical address change for 1 student was not reported within the required timeframe to the NSLDS. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school 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 University of San Diego contracts with a third-party intermediary to transmit enrollment information to NSLDS. Ultimately, the University of San Diego is responsible for the accuracy and timeliness of its reporting, regardless of whether it uses a third party. For the exceptions noted above, the student status change was not reported within the required time frame or not correctly reported due to the University of San Diego not having effective internal controls established to prevent or detect and correct the non-compliance in a timely manner. Repeat Finding ? This is a repeat finding. See 2021-001. Recommendation ? We recommend the University of San Diego revise its policies to establish a requirement that the list of graduates submitted to NSLDS be reviewed prior to and after being submitted to the NSLDS. We also recommend the University of San Diego establish an internal control to identify and report status changes prior to the established deadline. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with this finding. This student had a permanent physical address change before we implemented the change in the process described in finding 2021-001. During the 2021 audit, we identified that the exception to the timeframe for reporting a permanent physical address update was due to an incorrect parameter in the report used to provide the data as a result of employee turnover in the Registrar's Office. Management amended the report parameters to correctly report students who make permanent physical address changes and believes these enhancements will be sufficient to prevent future errors.
FINDING 2022-002 - Special Tests and Provisions - Borrower Data Transmission and Reconciliation: Significant Deficiency in Internal Control Over Compliance: See Schedule of Findings and Questioned Costs for Chart/Table. Criteria - 34 CFR 685.300(b)(5) - On a monthly basis, the school must reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Condition / Context - The University of San Diego operates a law school and an undergraduate and graduate school. A sample of 6 direct loan reconciliations were selected from the population of all reconciliations performed by the University, under both schools during the year ended June 30, 2022. We obtained the supporting schedules used to reconcile the disbursed direct loan funds to the federal government?s records. The University did not complete reconciliations of its direct loan program disbursements for the undergraduate and graduate school. Cause - The process for reconciling this data was revised during the year ended June 30, 2022, and the change was not reflected in the University of San Diego?s policies and procedures. There was turnover in the position responsible for reconciling this data, and the responsibility did not transfer to another individual, and as a result, the reconciliations were not completed. Effect - There is a chance that the University of San Diego?s records may not match the federal government?s records of direct loan disbursement. Repeat finding - This is not a repeat finding. Recommendation - We recommend the University revise its existing policies and procedures to accommodate the change. View of responsible officials - Management concurs with this finding. This exception was due to a change in the undergraduate and graduate school monthly reconciliation process that was not subsequently communicated during employee turnover in the Controller?s Office. Management updated the direct lending servicing system reconciliation procedures to accommodate the change in process. Management believes these enhancements will be sufficient to prevent future errors.
FINDING 2022-001 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/Context ? A sample of 34 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2021-2022 academic year. The enrollment information and withdrawal, address change, or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the permanent physical address change for 1 student was not reported within the required timeframe to the NSLDS. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school 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 University of San Diego contracts with a third-party intermediary to transmit enrollment information to NSLDS. Ultimately, the University of San Diego is responsible for the accuracy and timeliness of its reporting, regardless of whether it uses a third party. For the exceptions noted above, the student status change was not reported within the required time frame or not correctly reported due to the University of San Diego not having effective internal controls established to prevent or detect and correct the non-compliance in a timely manner. Repeat Finding ? This is a repeat finding. See 2021-001. Recommendation ? We recommend the University of San Diego revise its policies to establish a requirement that the list of graduates submitted to NSLDS be reviewed prior to and after being submitted to the NSLDS. We also recommend the University of San Diego establish an internal control to identify and report status changes prior to the established deadline. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with this finding. This student had a permanent physical address change before we implemented the change in the process described in finding 2021-001. During the 2021 audit, we identified that the exception to the timeframe for reporting a permanent physical address update was due to an incorrect parameter in the report used to provide the data as a result of employee turnover in the Registrar's Office. Management amended the report parameters to correctly report students who make permanent physical address changes and believes these enhancements will be sufficient to prevent future errors.
FINDING 2022-001 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/Context ? A sample of 34 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2021-2022 academic year. The enrollment information and withdrawal, address change, or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the permanent physical address change for 1 student was not reported within the required timeframe to the NSLDS. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school 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 University of San Diego contracts with a third-party intermediary to transmit enrollment information to NSLDS. Ultimately, the University of San Diego is responsible for the accuracy and timeliness of its reporting, regardless of whether it uses a third party. For the exceptions noted above, the student status change was not reported within the required time frame or not correctly reported due to the University of San Diego not having effective internal controls established to prevent or detect and correct the non-compliance in a timely manner. Repeat Finding ? This is a repeat finding. See 2021-001. Recommendation ? We recommend the University of San Diego revise its policies to establish a requirement that the list of graduates submitted to NSLDS be reviewed prior to and after being submitted to the NSLDS. We also recommend the University of San Diego establish an internal control to identify and report status changes prior to the established deadline. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with this finding. This student had a permanent physical address change before we implemented the change in the process described in finding 2021-001. During the 2021 audit, we identified that the exception to the timeframe for reporting a permanent physical address update was due to an incorrect parameter in the report used to provide the data as a result of employee turnover in the Registrar's Office. Management amended the report parameters to correctly report students who make permanent physical address changes and believes these enhancements will be sufficient to prevent future errors.
FINDING 2022-001 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/Context ? A sample of 34 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2021-2022 academic year. The enrollment information and withdrawal, address change, or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the permanent physical address change for 1 student was not reported within the required timeframe to the NSLDS. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school 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 University of San Diego contracts with a third-party intermediary to transmit enrollment information to NSLDS. Ultimately, the University of San Diego is responsible for the accuracy and timeliness of its reporting, regardless of whether it uses a third party. For the exceptions noted above, the student status change was not reported within the required time frame or not correctly reported due to the University of San Diego not having effective internal controls established to prevent or detect and correct the non-compliance in a timely manner. Repeat Finding ? This is a repeat finding. See 2021-001. Recommendation ? We recommend the University of San Diego revise its policies to establish a requirement that the list of graduates submitted to NSLDS be reviewed prior to and after being submitted to the NSLDS. We also recommend the University of San Diego establish an internal control to identify and report status changes prior to the established deadline. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with this finding. This student had a permanent physical address change before we implemented the change in the process described in finding 2021-001. During the 2021 audit, we identified that the exception to the timeframe for reporting a permanent physical address update was due to an incorrect parameter in the report used to provide the data as a result of employee turnover in the Registrar's Office. Management amended the report parameters to correctly report students who make permanent physical address changes and believes these enhancements will be sufficient to prevent future errors.
FINDING 2022-001 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/Context ? A sample of 34 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2021-2022 academic year. The enrollment information and withdrawal, address change, or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the permanent physical address change for 1 student was not reported within the required timeframe to the NSLDS. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school 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 University of San Diego contracts with a third-party intermediary to transmit enrollment information to NSLDS. Ultimately, the University of San Diego is responsible for the accuracy and timeliness of its reporting, regardless of whether it uses a third party. For the exceptions noted above, the student status change was not reported within the required time frame or not correctly reported due to the University of San Diego not having effective internal controls established to prevent or detect and correct the non-compliance in a timely manner. Repeat Finding ? This is a repeat finding. See 2021-001. Recommendation ? We recommend the University of San Diego revise its policies to establish a requirement that the list of graduates submitted to NSLDS be reviewed prior to and after being submitted to the NSLDS. We also recommend the University of San Diego establish an internal control to identify and report status changes prior to the established deadline. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with this finding. This student had a permanent physical address change before we implemented the change in the process described in finding 2021-001. During the 2021 audit, we identified that the exception to the timeframe for reporting a permanent physical address update was due to an incorrect parameter in the report used to provide the data as a result of employee turnover in the Registrar's Office. Management amended the report parameters to correctly report students who make permanent physical address changes and believes these enhancements will be sufficient to prevent future errors.
FINDING 2022-001 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/Context ? A sample of 34 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2021-2022 academic year. The enrollment information and withdrawal, address change, or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the permanent physical address change for 1 student was not reported within the required timeframe to the NSLDS. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school 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 University of San Diego contracts with a third-party intermediary to transmit enrollment information to NSLDS. Ultimately, the University of San Diego is responsible for the accuracy and timeliness of its reporting, regardless of whether it uses a third party. For the exceptions noted above, the student status change was not reported within the required time frame or not correctly reported due to the University of San Diego not having effective internal controls established to prevent or detect and correct the non-compliance in a timely manner. Repeat Finding ? This is a repeat finding. See 2021-001. Recommendation ? We recommend the University of San Diego revise its policies to establish a requirement that the list of graduates submitted to NSLDS be reviewed prior to and after being submitted to the NSLDS. We also recommend the University of San Diego establish an internal control to identify and report status changes prior to the established deadline. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with this finding. This student had a permanent physical address change before we implemented the change in the process described in finding 2021-001. During the 2021 audit, we identified that the exception to the timeframe for reporting a permanent physical address update was due to an incorrect parameter in the report used to provide the data as a result of employee turnover in the Registrar's Office. Management amended the report parameters to correctly report students who make permanent physical address changes and believes these enhancements will be sufficient to prevent future errors.
FINDING 2022-001 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/Context ? A sample of 34 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2021-2022 academic year. The enrollment information and withdrawal, address change, or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the permanent physical address change for 1 student was not reported within the required timeframe to the NSLDS. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school 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 University of San Diego contracts with a third-party intermediary to transmit enrollment information to NSLDS. Ultimately, the University of San Diego is responsible for the accuracy and timeliness of its reporting, regardless of whether it uses a third party. For the exceptions noted above, the student status change was not reported within the required time frame or not correctly reported due to the University of San Diego not having effective internal controls established to prevent or detect and correct the non-compliance in a timely manner. Repeat Finding ? This is a repeat finding. See 2021-001. Recommendation ? We recommend the University of San Diego revise its policies to establish a requirement that the list of graduates submitted to NSLDS be reviewed prior to and after being submitted to the NSLDS. We also recommend the University of San Diego establish an internal control to identify and report status changes prior to the established deadline. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with this finding. This student had a permanent physical address change before we implemented the change in the process described in finding 2021-001. During the 2021 audit, we identified that the exception to the timeframe for reporting a permanent physical address update was due to an incorrect parameter in the report used to provide the data as a result of employee turnover in the Registrar's Office. Management amended the report parameters to correctly report students who make permanent physical address changes and believes these enhancements will be sufficient to prevent future errors.
FINDING 2022-001 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/Context ? A sample of 34 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2021-2022 academic year. The enrollment information and withdrawal, address change, or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the permanent physical address change for 1 student was not reported within the required timeframe to the NSLDS. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school 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 University of San Diego contracts with a third-party intermediary to transmit enrollment information to NSLDS. Ultimately, the University of San Diego is responsible for the accuracy and timeliness of its reporting, regardless of whether it uses a third party. For the exceptions noted above, the student status change was not reported within the required time frame or not correctly reported due to the University of San Diego not having effective internal controls established to prevent or detect and correct the non-compliance in a timely manner. Repeat Finding ? This is a repeat finding. See 2021-001. Recommendation ? We recommend the University of San Diego revise its policies to establish a requirement that the list of graduates submitted to NSLDS be reviewed prior to and after being submitted to the NSLDS. We also recommend the University of San Diego establish an internal control to identify and report status changes prior to the established deadline. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with this finding. This student had a permanent physical address change before we implemented the change in the process described in finding 2021-001. During the 2021 audit, we identified that the exception to the timeframe for reporting a permanent physical address update was due to an incorrect parameter in the report used to provide the data as a result of employee turnover in the Registrar's Office. Management amended the report parameters to correctly report students who make permanent physical address changes and believes these enhancements will be sufficient to prevent future errors.
FINDING 2022-002 - Special Tests and Provisions - Borrower Data Transmission and Reconciliation: Significant Deficiency in Internal Control Over Compliance: See Schedule of Findings and Questioned Costs for Chart/Table. Criteria - 34 CFR 685.300(b)(5) - On a monthly basis, the school must reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Condition / Context - The University of San Diego operates a law school and an undergraduate and graduate school. A sample of 6 direct loan reconciliations were selected from the population of all reconciliations performed by the University, under both schools during the year ended June 30, 2022. We obtained the supporting schedules used to reconcile the disbursed direct loan funds to the federal government?s records. The University did not complete reconciliations of its direct loan program disbursements for the undergraduate and graduate school. Cause - The process for reconciling this data was revised during the year ended June 30, 2022, and the change was not reflected in the University of San Diego?s policies and procedures. There was turnover in the position responsible for reconciling this data, and the responsibility did not transfer to another individual, and as a result, the reconciliations were not completed. Effect - There is a chance that the University of San Diego?s records may not match the federal government?s records of direct loan disbursement. Repeat finding - This is not a repeat finding. Recommendation - We recommend the University revise its existing policies and procedures to accommodate the change. View of responsible officials - Management concurs with this finding. This exception was due to a change in the undergraduate and graduate school monthly reconciliation process that was not subsequently communicated during employee turnover in the Controller?s Office. Management updated the direct lending servicing system reconciliation procedures to accommodate the change in process. Management believes these enhancements will be sufficient to prevent future errors.
FINDING 2022-001 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/Context ? A sample of 34 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2021-2022 academic year. The enrollment information and withdrawal, address change, or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the permanent physical address change for 1 student was not reported within the required timeframe to the NSLDS. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school 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 University of San Diego contracts with a third-party intermediary to transmit enrollment information to NSLDS. Ultimately, the University of San Diego is responsible for the accuracy and timeliness of its reporting, regardless of whether it uses a third party. For the exceptions noted above, the student status change was not reported within the required time frame or not correctly reported due to the University of San Diego not having effective internal controls established to prevent or detect and correct the non-compliance in a timely manner. Repeat Finding ? This is a repeat finding. See 2021-001. Recommendation ? We recommend the University of San Diego revise its policies to establish a requirement that the list of graduates submitted to NSLDS be reviewed prior to and after being submitted to the NSLDS. We also recommend the University of San Diego establish an internal control to identify and report status changes prior to the established deadline. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with this finding. This student had a permanent physical address change before we implemented the change in the process described in finding 2021-001. During the 2021 audit, we identified that the exception to the timeframe for reporting a permanent physical address update was due to an incorrect parameter in the report used to provide the data as a result of employee turnover in the Registrar's Office. Management amended the report parameters to correctly report students who make permanent physical address changes and believes these enhancements will be sufficient to prevent future errors.
FINDING 2022-002 - Special Tests and Provisions - Borrower Data Transmission and Reconciliation: Significant Deficiency in Internal Control Over Compliance: See Schedule of Findings and Questioned Costs for Chart/Table. Criteria - 34 CFR 685.300(b)(5) - On a monthly basis, the school must reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Condition / Context - The University of San Diego operates a law school and an undergraduate and graduate school. A sample of 6 direct loan reconciliations were selected from the population of all reconciliations performed by the University, under both schools during the year ended June 30, 2022. We obtained the supporting schedules used to reconcile the disbursed direct loan funds to the federal government?s records. The University did not complete reconciliations of its direct loan program disbursements for the undergraduate and graduate school. Cause - The process for reconciling this data was revised during the year ended June 30, 2022, and the change was not reflected in the University of San Diego?s policies and procedures. There was turnover in the position responsible for reconciling this data, and the responsibility did not transfer to another individual, and as a result, the reconciliations were not completed. Effect - There is a chance that the University of San Diego?s records may not match the federal government?s records of direct loan disbursement. Repeat finding - This is not a repeat finding. Recommendation - We recommend the University revise its existing policies and procedures to accommodate the change. View of responsible officials - Management concurs with this finding. This exception was due to a change in the undergraduate and graduate school monthly reconciliation process that was not subsequently communicated during employee turnover in the Controller?s Office. Management updated the direct lending servicing system reconciliation procedures to accommodate the change in process. Management believes these enhancements will be sufficient to prevent future errors.
FINDING 2022-001 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance "SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE" Criteria ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/Context ? A sample of 34 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2021-2022 academic year. The enrollment information and withdrawal, address change, or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. An exception was noted whereby the permanent physical address change for 1 student was not reported within the required timeframe to the NSLDS. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school 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 University of San Diego contracts with a third-party intermediary to transmit enrollment information to NSLDS. Ultimately, the University of San Diego is responsible for the accuracy and timeliness of its reporting, regardless of whether it uses a third party. For the exceptions noted above, the student status change was not reported within the required time frame or not correctly reported due to the University of San Diego not having effective internal controls established to prevent or detect and correct the non-compliance in a timely manner. Repeat Finding ? This is a repeat finding. See 2021-001. Recommendation ? We recommend the University of San Diego revise its policies to establish a requirement that the list of graduates submitted to NSLDS be reviewed prior to and after being submitted to the NSLDS. We also recommend the University of San Diego establish an internal control to identify and report status changes prior to the established deadline. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with this finding. This student had a permanent physical address change before we implemented the change in the process described in finding 2021-001. During the 2021 audit, we identified that the exception to the timeframe for reporting a permanent physical address update was due to an incorrect parameter in the report used to provide the data as a result of employee turnover in the Registrar's Office. Management amended the report parameters to correctly report students who make permanent physical address changes and believes these enhancements will be sufficient to prevent future errors.