Audit 344168

Findings and Questioned Costs Relating to Federal Awards Finding 2024-001 Federal Agency: Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.268 and 84.063 Federal Award Year: Funding periods between June 1, 2023 through May 31, 2024 Compliance Requirement: Enrollment Reporting Finding Type: Noncompliance and Significant Deficiency Criteria: 34 CFR 685.309(b) - Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition, including perspective For seven out of the 25 students sampled for testing the timeliness and accuracy of the University’s reporting of student enrollment status change to the National Student Loan Data System (NSLDS), the changes in their enrollment status were not reported to NSLDS. These seven students were part of the University’s May 2024 graduating class of 307 students from the College of Liberal Arts and Sciences that were not reported as required to NSLDS. A total of 2,272 students graduated from the University in May 2024. Cause and Effect The University did not have sufficient controls in place to ensure complete and accurate reporting of all student enrollment status changes to NSLDS. Consequently, the June 2024 transmission to NSLDS excluded students who graduated from the College of Liberal Arts and Sciences. In September 2024, the National Student Clearinghouse (NSC), on behalf of the University, updated these students’ status to “withdrawn” for reporting to the NSLDS because they were not included in the University’s active Fall semester roster. This deficiency could affect the timing of these students’ transition into federal loan repayment, however, both the graduated and withdrawn status trigger the student entering into repayment. Questioned Costs No question costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding No. Recommendation We recommend the University enhance its current policies and procedures to ensure that changes to students’ enrollment status is accurately reflected in the underlying records prior to being transmitted. Views of Responsible Officials Villanova University accepts this finding. During the year, there was turnover at the University and we acknowledge the training of new staff is always a priority for the University. Appropriate training and new internal control processes have been implemented. The department has implemented a new graduate only submission file to be transmitted to the NSC at the end of May and another at the end of June. In addition, the University has created a Graduation Audit Report to verify the change in status for students who graduated and a final validation with the Senior Assistant Registrar for Student History to confirm accuracy of student status.

Findings and Questioned Costs Relating to Federal Awards Finding 2024-001 Federal Agency: Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.268 and 84.063 Federal Award Year: Funding periods between June 1, 2023 through May 31, 2024 Compliance Requirement: Enrollment Reporting Finding Type: Noncompliance and Significant Deficiency Criteria: 34 CFR 685.309(b) - Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition, including perspective For seven out of the 25 students sampled for testing the timeliness and accuracy of the University’s reporting of student enrollment status change to the National Student Loan Data System (NSLDS), the changes in their enrollment status were not reported to NSLDS. These seven students were part of the University’s May 2024 graduating class of 307 students from the College of Liberal Arts and Sciences that were not reported as required to NSLDS. A total of 2,272 students graduated from the University in May 2024. Cause and Effect The University did not have sufficient controls in place to ensure complete and accurate reporting of all student enrollment status changes to NSLDS. Consequently, the June 2024 transmission to NSLDS excluded students who graduated from the College of Liberal Arts and Sciences. In September 2024, the National Student Clearinghouse (NSC), on behalf of the University, updated these students’ status to “withdrawn” for reporting to the NSLDS because they were not included in the University’s active Fall semester roster. This deficiency could affect the timing of these students’ transition into federal loan repayment, however, both the graduated and withdrawn status trigger the student entering into repayment. Questioned Costs No question costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding No. Recommendation We recommend the University enhance its current policies and procedures to ensure that changes to students’ enrollment status is accurately reflected in the underlying records prior to being transmitted. Views of Responsible Officials Villanova University accepts this finding. During the year, there was turnover at the University and we acknowledge the training of new staff is always a priority for the University. Appropriate training and new internal control processes have been implemented. The department has implemented a new graduate only submission file to be transmitted to the NSC at the end of May and another at the end of June. In addition, the University has created a Graduation Audit Report to verify the change in status for students who graduated and a final validation with the Senior Assistant Registrar for Student History to confirm accuracy of student status.

Findings and Questioned Costs Relating to Federal Awards Finding 2024-001 Federal Agency: Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.268 and 84.063 Federal Award Year: Funding periods between June 1, 2023 through May 31, 2024 Compliance Requirement: Enrollment Reporting Finding Type: Noncompliance and Significant Deficiency Criteria: 34 CFR 685.309(b) - Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition, including perspective For seven out of the 25 students sampled for testing the timeliness and accuracy of the University’s reporting of student enrollment status change to the National Student Loan Data System (NSLDS), the changes in their enrollment status were not reported to NSLDS. These seven students were part of the University’s May 2024 graduating class of 307 students from the College of Liberal Arts and Sciences that were not reported as required to NSLDS. A total of 2,272 students graduated from the University in May 2024. Cause and Effect The University did not have sufficient controls in place to ensure complete and accurate reporting of all student enrollment status changes to NSLDS. Consequently, the June 2024 transmission to NSLDS excluded students who graduated from the College of Liberal Arts and Sciences. In September 2024, the National Student Clearinghouse (NSC), on behalf of the University, updated these students’ status to “withdrawn” for reporting to the NSLDS because they were not included in the University’s active Fall semester roster. This deficiency could affect the timing of these students’ transition into federal loan repayment, however, both the graduated and withdrawn status trigger the student entering into repayment. Questioned Costs No question costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding No. Recommendation We recommend the University enhance its current policies and procedures to ensure that changes to students’ enrollment status is accurately reflected in the underlying records prior to being transmitted. Views of Responsible Officials Villanova University accepts this finding. During the year, there was turnover at the University and we acknowledge the training of new staff is always a priority for the University. Appropriate training and new internal control processes have been implemented. The department has implemented a new graduate only submission file to be transmitted to the NSC at the end of May and another at the end of June. In addition, the University has created a Graduation Audit Report to verify the change in status for students who graduated and a final validation with the Senior Assistant Registrar for Student History to confirm accuracy of student status.

Findings and Questioned Costs Relating to Federal Awards Finding 2024-001 Federal Agency: Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.268 and 84.063 Federal Award Year: Funding periods between June 1, 2023 through May 31, 2024 Compliance Requirement: Enrollment Reporting Finding Type: Noncompliance and Significant Deficiency Criteria: 34 CFR 685.309(b) - Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition, including perspective For seven out of the 25 students sampled for testing the timeliness and accuracy of the University’s reporting of student enrollment status change to the National Student Loan Data System (NSLDS), the changes in their enrollment status were not reported to NSLDS. These seven students were part of the University’s May 2024 graduating class of 307 students from the College of Liberal Arts and Sciences that were not reported as required to NSLDS. A total of 2,272 students graduated from the University in May 2024. Cause and Effect The University did not have sufficient controls in place to ensure complete and accurate reporting of all student enrollment status changes to NSLDS. Consequently, the June 2024 transmission to NSLDS excluded students who graduated from the College of Liberal Arts and Sciences. In September 2024, the National Student Clearinghouse (NSC), on behalf of the University, updated these students’ status to “withdrawn” for reporting to the NSLDS because they were not included in the University’s active Fall semester roster. This deficiency could affect the timing of these students’ transition into federal loan repayment, however, both the graduated and withdrawn status trigger the student entering into repayment. Questioned Costs No question costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding No. Recommendation We recommend the University enhance its current policies and procedures to ensure that changes to students’ enrollment status is accurately reflected in the underlying records prior to being transmitted. Views of Responsible Officials Villanova University accepts this finding. During the year, there was turnover at the University and we acknowledge the training of new staff is always a priority for the University. Appropriate training and new internal control processes have been implemented. The department has implemented a new graduate only submission file to be transmitted to the NSC at the end of May and another at the end of June. In addition, the University has created a Graduation Audit Report to verify the change in status for students who graduated and a final validation with the Senior Assistant Registrar for Student History to confirm accuracy of student status.