Audit 340417

Finding No. 2023-001 Student Financial Assistance Cluster: U.S. Department of Education: Federal Pell Grant Program – ALN 84.063 Federal Direct Loan Program – ALN 84.268 Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement – Special Tests and Provisions – Enrollment Reporting – Significant Deficiency and Noncompliance Criteria Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the NSLDS (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Condition and Context We selected twenty-five students who received a Federal Direct Loan or a Pell Grant and whose enrollment status changed during the year and noted the following exceptions. • For twenty-five enrollment status changes, the status change was not reported within 60 days. Twenty-four of these twenty-five were reported 85 days late, and the last was reported 193 days late. Cause The students involved in this finding were all students who graduated. The University uses the National Student Clearinghouse (NSC) to report enrollment information to the NSLDS. The University submitted graduation status changes through the degree verify file on a timely basis to the NSC. However, the NSC did not timely notify the University to file the graduates only enrollment report to the NSC and therefore, the NSLDS. The University subsequently provided the graduates only enrollment report to the NSC outside of the 60 calendar day reporting requirement. Effect Enrollment status changes not reported in a timely manner could impact the timeliness of the student entering repayment status. Questioned Costs There were no questioned costs related to this finding. Recommendation We recommend the University reinforces its policies and procedures for persons responsible for reporting status changes to the service provider to ensure compliance with the requirement of submitting accurate and complete enrollment reports in a timely manner to the NSLDS. Views of Responsible Official Management of the University agrees with the recommendation. Corrective action by the Provost for Graduate Continuing and Professional Studies and University Registrar is as follows: The graduates only enrollment report will be supplied to the NSC by the Registrar’s Office on a consistent schedule of submission within 60 days of each graduation period. Initial corrective action was completed by the University Registrar’s office in October, 2023 with the submission of a graduates only enrollment report to the NSC. A schedule for consistent submissions of a graduates only enrollment report has already been provided to the NSC.

Finding No. 2023-001 Student Financial Assistance Cluster: U.S. Department of Education: Federal Pell Grant Program – ALN 84.063 Federal Direct Loan Program – ALN 84.268 Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement – Special Tests and Provisions – Enrollment Reporting – Significant Deficiency and Noncompliance Criteria Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the NSLDS (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Condition and Context We selected twenty-five students who received a Federal Direct Loan or a Pell Grant and whose enrollment status changed during the year and noted the following exceptions. • For twenty-five enrollment status changes, the status change was not reported within 60 days. Twenty-four of these twenty-five were reported 85 days late, and the last was reported 193 days late. Cause The students involved in this finding were all students who graduated. The University uses the National Student Clearinghouse (NSC) to report enrollment information to the NSLDS. The University submitted graduation status changes through the degree verify file on a timely basis to the NSC. However, the NSC did not timely notify the University to file the graduates only enrollment report to the NSC and therefore, the NSLDS. The University subsequently provided the graduates only enrollment report to the NSC outside of the 60 calendar day reporting requirement. Effect Enrollment status changes not reported in a timely manner could impact the timeliness of the student entering repayment status. Questioned Costs There were no questioned costs related to this finding. Recommendation We recommend the University reinforces its policies and procedures for persons responsible for reporting status changes to the service provider to ensure compliance with the requirement of submitting accurate and complete enrollment reports in a timely manner to the NSLDS. Views of Responsible Official Management of the University agrees with the recommendation. Corrective action by the Provost for Graduate Continuing and Professional Studies and University Registrar is as follows: The graduates only enrollment report will be supplied to the NSC by the Registrar’s Office on a consistent schedule of submission within 60 days of each graduation period. Initial corrective action was completed by the University Registrar’s office in October, 2023 with the submission of a graduates only enrollment report to the NSC. A schedule for consistent submissions of a graduates only enrollment report has already been provided to the NSC.

Finding No. 2023-001 Student Financial Assistance Cluster: U.S. Department of Education: Federal Pell Grant Program – ALN 84.063 Federal Direct Loan Program – ALN 84.268 Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement – Special Tests and Provisions – Enrollment Reporting – Significant Deficiency and Noncompliance Criteria Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the NSLDS (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Condition and Context We selected twenty-five students who received a Federal Direct Loan or a Pell Grant and whose enrollment status changed during the year and noted the following exceptions. • For twenty-five enrollment status changes, the status change was not reported within 60 days. Twenty-four of these twenty-five were reported 85 days late, and the last was reported 193 days late. Cause The students involved in this finding were all students who graduated. The University uses the National Student Clearinghouse (NSC) to report enrollment information to the NSLDS. The University submitted graduation status changes through the degree verify file on a timely basis to the NSC. However, the NSC did not timely notify the University to file the graduates only enrollment report to the NSC and therefore, the NSLDS. The University subsequently provided the graduates only enrollment report to the NSC outside of the 60 calendar day reporting requirement. Effect Enrollment status changes not reported in a timely manner could impact the timeliness of the student entering repayment status. Questioned Costs There were no questioned costs related to this finding. Recommendation We recommend the University reinforces its policies and procedures for persons responsible for reporting status changes to the service provider to ensure compliance with the requirement of submitting accurate and complete enrollment reports in a timely manner to the NSLDS. Views of Responsible Official Management of the University agrees with the recommendation. Corrective action by the Provost for Graduate Continuing and Professional Studies and University Registrar is as follows: The graduates only enrollment report will be supplied to the NSC by the Registrar’s Office on a consistent schedule of submission within 60 days of each graduation period. Initial corrective action was completed by the University Registrar’s office in October, 2023 with the submission of a graduates only enrollment report to the NSC. A schedule for consistent submissions of a graduates only enrollment report has already been provided to the NSC.

Finding No. 2023-001 Student Financial Assistance Cluster: U.S. Department of Education: Federal Pell Grant Program – ALN 84.063 Federal Direct Loan Program – ALN 84.268 Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement – Special Tests and Provisions – Enrollment Reporting – Significant Deficiency and Noncompliance Criteria Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the NSLDS (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Condition and Context We selected twenty-five students who received a Federal Direct Loan or a Pell Grant and whose enrollment status changed during the year and noted the following exceptions. • For twenty-five enrollment status changes, the status change was not reported within 60 days. Twenty-four of these twenty-five were reported 85 days late, and the last was reported 193 days late. Cause The students involved in this finding were all students who graduated. The University uses the National Student Clearinghouse (NSC) to report enrollment information to the NSLDS. The University submitted graduation status changes through the degree verify file on a timely basis to the NSC. However, the NSC did not timely notify the University to file the graduates only enrollment report to the NSC and therefore, the NSLDS. The University subsequently provided the graduates only enrollment report to the NSC outside of the 60 calendar day reporting requirement. Effect Enrollment status changes not reported in a timely manner could impact the timeliness of the student entering repayment status. Questioned Costs There were no questioned costs related to this finding. Recommendation We recommend the University reinforces its policies and procedures for persons responsible for reporting status changes to the service provider to ensure compliance with the requirement of submitting accurate and complete enrollment reports in a timely manner to the NSLDS. Views of Responsible Official Management of the University agrees with the recommendation. Corrective action by the Provost for Graduate Continuing and Professional Studies and University Registrar is as follows: The graduates only enrollment report will be supplied to the NSC by the Registrar’s Office on a consistent schedule of submission within 60 days of each graduation period. Initial corrective action was completed by the University Registrar’s office in October, 2023 with the submission of a graduates only enrollment report to the NSC. A schedule for consistent submissions of a graduates only enrollment report has already been provided to the NSC.