FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Material Weakness in
Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section.
Institutions required to take attendance are expected to have a procedure in place for routinely monitoring
attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution’s determination that the student withdrew should be no later than 14 days after the student’s last date of attendance as determined by the institution from its attendance records.
34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) An institution must return the
amount of Title IV funds for which it is responsible under paragraph (g) of this section as soon as possible
but no later than 45 days after the date of the institution’s determination that the student withdrew as
defined in paragraph (l)(3) of this section. Condition/context – A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origination and Disbursement system.
For 2 of the 60 sampled students, an incorrect amount of funds were returned, and for 1 of these 2 students, their funds were not returned in the proper sequence. Of the 60 students sampled, 1 student was not timely identified by NU as a withdrawal. Of the 60 students, the amount to be returned was not remitted within the required 45 day window following NU’s date of determination of withdrawal for 8 students
Cause – The University does not have an effective process in place to ensure all withdrawn students are
timely identified and Title IV funds are returned accurately and timely subsequent to the calculation. Questioned Costs – Known questioned costs were $1,511. We projected the error rate over the entire universe of students whom received federal aid and withdrew, dropped out, or enrolled but never attended during the year ended June 30, 2024. Using this method, we determined likely questioned costs to be approximately $173,236.
Effect – If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government.
Repeat finding – This is a repeat finding, see 2023-001.
Recommendation – We recommend NU evaluate its current process to ensure consistent and accurate criteria are used when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend NU evaluate its process of reviewing Title IV returns to ensure returns were calculated accurately and returned timely and accurately.
FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Material Weakness in
Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section.
Institutions required to take attendance are expected to have a procedure in place for routinely monitoring
attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution’s determination that the student withdrew should be no later than 14 days after the student’s last date of attendance as determined by the institution from its attendance records.
34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) An institution must return the
amount of Title IV funds for which it is responsible under paragraph (g) of this section as soon as possible
but no later than 45 days after the date of the institution’s determination that the student withdrew as
defined in paragraph (l)(3) of this section. Condition/context – A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origination and Disbursement system.
For 2 of the 60 sampled students, an incorrect amount of funds were returned, and for 1 of these 2 students, their funds were not returned in the proper sequence. Of the 60 students sampled, 1 student was not timely identified by NU as a withdrawal. Of the 60 students, the amount to be returned was not remitted within the required 45 day window following NU’s date of determination of withdrawal for 8 students
Cause – The University does not have an effective process in place to ensure all withdrawn students are
timely identified and Title IV funds are returned accurately and timely subsequent to the calculation. Questioned Costs – Known questioned costs were $1,511. We projected the error rate over the entire universe of students whom received federal aid and withdrew, dropped out, or enrolled but never attended during the year ended June 30, 2024. Using this method, we determined likely questioned costs to be approximately $173,236.
Effect – If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government.
Repeat finding – This is a repeat finding, see 2023-001.
Recommendation – We recommend NU evaluate its current process to ensure consistent and accurate criteria are used when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend NU evaluate its process of reviewing Title IV returns to ensure returns were calculated accurately and returned timely and accurately.
FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Material Weakness in
Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section.
Institutions required to take attendance are expected to have a procedure in place for routinely monitoring
attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution’s determination that the student withdrew should be no later than 14 days after the student’s last date of attendance as determined by the institution from its attendance records.
34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) An institution must return the
amount of Title IV funds for which it is responsible under paragraph (g) of this section as soon as possible
but no later than 45 days after the date of the institution’s determination that the student withdrew as
defined in paragraph (l)(3) of this section. Condition/context – A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origination and Disbursement system.
For 2 of the 60 sampled students, an incorrect amount of funds were returned, and for 1 of these 2 students, their funds were not returned in the proper sequence. Of the 60 students sampled, 1 student was not timely identified by NU as a withdrawal. Of the 60 students, the amount to be returned was not remitted within the required 45 day window following NU’s date of determination of withdrawal for 8 students
Cause – The University does not have an effective process in place to ensure all withdrawn students are
timely identified and Title IV funds are returned accurately and timely subsequent to the calculation. Questioned Costs – Known questioned costs were $1,511. We projected the error rate over the entire universe of students whom received federal aid and withdrew, dropped out, or enrolled but never attended during the year ended June 30, 2024. Using this method, we determined likely questioned costs to be approximately $173,236.
Effect – If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government.
Repeat finding – This is a repeat finding, see 2023-001.
Recommendation – We recommend NU evaluate its current process to ensure consistent and accurate criteria are used when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend NU evaluate its process of reviewing Title IV returns to ensure returns were calculated accurately and returned timely and accurately.
FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Material Weakness in
Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section.
Institutions required to take attendance are expected to have a procedure in place for routinely monitoring
attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution’s determination that the student withdrew should be no later than 14 days after the student’s last date of attendance as determined by the institution from its attendance records.
34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) An institution must return the
amount of Title IV funds for which it is responsible under paragraph (g) of this section as soon as possible
but no later than 45 days after the date of the institution’s determination that the student withdrew as
defined in paragraph (l)(3) of this section. Condition/context – A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origination and Disbursement system.
For 2 of the 60 sampled students, an incorrect amount of funds were returned, and for 1 of these 2 students, their funds were not returned in the proper sequence. Of the 60 students sampled, 1 student was not timely identified by NU as a withdrawal. Of the 60 students, the amount to be returned was not remitted within the required 45 day window following NU’s date of determination of withdrawal for 8 students
Cause – The University does not have an effective process in place to ensure all withdrawn students are
timely identified and Title IV funds are returned accurately and timely subsequent to the calculation. Questioned Costs – Known questioned costs were $1,511. We projected the error rate over the entire universe of students whom received federal aid and withdrew, dropped out, or enrolled but never attended during the year ended June 30, 2024. Using this method, we determined likely questioned costs to be approximately $173,236.
Effect – If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government.
Repeat finding – This is a repeat finding, see 2023-001.
Recommendation – We recommend NU evaluate its current process to ensure consistent and accurate criteria are used when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend NU evaluate its process of reviewing Title IV returns to ensure returns were calculated accurately and returned timely and accurately.
FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Material Weakness in
Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section.
Institutions required to take attendance are expected to have a procedure in place for routinely monitoring
attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution’s determination that the student withdrew should be no later than 14 days after the student’s last date of attendance as determined by the institution from its attendance records.
34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) An institution must return the
amount of Title IV funds for which it is responsible under paragraph (g) of this section as soon as possible
but no later than 45 days after the date of the institution’s determination that the student withdrew as
defined in paragraph (l)(3) of this section. Condition/context – A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origination and Disbursement system.
For 2 of the 60 sampled students, an incorrect amount of funds were returned, and for 1 of these 2 students, their funds were not returned in the proper sequence. Of the 60 students sampled, 1 student was not timely identified by NU as a withdrawal. Of the 60 students, the amount to be returned was not remitted within the required 45 day window following NU’s date of determination of withdrawal for 8 students
Cause – The University does not have an effective process in place to ensure all withdrawn students are
timely identified and Title IV funds are returned accurately and timely subsequent to the calculation. Questioned Costs – Known questioned costs were $1,511. We projected the error rate over the entire universe of students whom received federal aid and withdrew, dropped out, or enrolled but never attended during the year ended June 30, 2024. Using this method, we determined likely questioned costs to be approximately $173,236.
Effect – If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government.
Repeat finding – This is a repeat finding, see 2023-001.
Recommendation – We recommend NU evaluate its current process to ensure consistent and accurate criteria are used when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend NU evaluate its process of reviewing Title IV returns to ensure returns were calculated accurately and returned timely and accurately.
FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Material Weakness in
Internal Control over Compliance (See Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): 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
i. 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 half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or
ii. A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address.
Condition/context – A sample of 60 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per NU’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. Of the 60 students who had a change in address, graduated, or withdrew, 28 were not reported to the NSLDS within the required timeframe. Of the 60 students, 11 had an incorrect effective date reported to the NSLDS. Cause – NU does not have an effective process to review NSLDS submissions, performed by NU’s third-party administrator, for accuracy and completeness on a periodic basis. Several of the late submissions identified above were a result the unexpected termination of NU’s agreement with its third-party administrator in approximately July 2024 that prevented NSLDS submissions NU wide during the months of August 2024 and November 2024.
Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, 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.
Repeat finding – This is a repeat finding. See 2023-002. Recommendation – We recommend NU evaluate its current process to ensure consistent and accurate criteria are used when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend NU evaluate its current process to ensure NSLDS is reviewed for accuracy and completeness over its students on a regular basis in order to ensure compliance and meet reporting deadlines.
FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Material Weakness in
Internal Control over Compliance (See Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): 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
i. 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 half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or
ii. A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address.
Condition/context – A sample of 60 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per NU’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. Of the 60 students who had a change in address, graduated, or withdrew, 28 were not reported to the NSLDS within the required timeframe. Of the 60 students, 11 had an incorrect effective date reported to the NSLDS. Cause – NU does not have an effective process to review NSLDS submissions, performed by NU’s third-party administrator, for accuracy and completeness on a periodic basis. Several of the late submissions identified above were a result the unexpected termination of NU’s agreement with its third-party administrator in approximately July 2024 that prevented NSLDS submissions NU wide during the months of August 2024 and November 2024.
Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, 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.
Repeat finding – This is a repeat finding. See 2023-002. Recommendation – We recommend NU evaluate its current process to ensure consistent and accurate criteria are used when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend NU evaluate its current process to ensure NSLDS is reviewed for accuracy and completeness over its students on a regular basis in order to ensure compliance and meet reporting deadlines.
FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Material Weakness in
Internal Control over Compliance (See Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): 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
i. 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 half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or
ii. A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address.
Condition/context – A sample of 60 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per NU’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. Of the 60 students who had a change in address, graduated, or withdrew, 28 were not reported to the NSLDS within the required timeframe. Of the 60 students, 11 had an incorrect effective date reported to the NSLDS. Cause – NU does not have an effective process to review NSLDS submissions, performed by NU’s third-party administrator, for accuracy and completeness on a periodic basis. Several of the late submissions identified above were a result the unexpected termination of NU’s agreement with its third-party administrator in approximately July 2024 that prevented NSLDS submissions NU wide during the months of August 2024 and November 2024.
Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, 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.
Repeat finding – This is a repeat finding. See 2023-002. Recommendation – We recommend NU evaluate its current process to ensure consistent and accurate criteria are used when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend NU evaluate its current process to ensure NSLDS is reviewed for accuracy and completeness over its students on a regular basis in order to ensure compliance and meet reporting deadlines.
FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Material Weakness in
Internal Control over Compliance (See Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): 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
i. 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 half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or
ii. A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address.
Condition/context – A sample of 60 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per NU’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. Of the 60 students who had a change in address, graduated, or withdrew, 28 were not reported to the NSLDS within the required timeframe. Of the 60 students, 11 had an incorrect effective date reported to the NSLDS. Cause – NU does not have an effective process to review NSLDS submissions, performed by NU’s third-party administrator, for accuracy and completeness on a periodic basis. Several of the late submissions identified above were a result the unexpected termination of NU’s agreement with its third-party administrator in approximately July 2024 that prevented NSLDS submissions NU wide during the months of August 2024 and November 2024.
Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, 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.
Repeat finding – This is a repeat finding. See 2023-002. Recommendation – We recommend NU evaluate its current process to ensure consistent and accurate criteria are used when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend NU evaluate its current process to ensure NSLDS is reviewed for accuracy and completeness over its students on a regular basis in order to ensure compliance and meet reporting deadlines.
FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Material Weakness in
Internal Control over Compliance (See Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): 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
i. 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 half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or
ii. A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address.
Condition/context – A sample of 60 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per NU’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. Of the 60 students who had a change in address, graduated, or withdrew, 28 were not reported to the NSLDS within the required timeframe. Of the 60 students, 11 had an incorrect effective date reported to the NSLDS. Cause – NU does not have an effective process to review NSLDS submissions, performed by NU’s third-party administrator, for accuracy and completeness on a periodic basis. Several of the late submissions identified above were a result the unexpected termination of NU’s agreement with its third-party administrator in approximately July 2024 that prevented NSLDS submissions NU wide during the months of August 2024 and November 2024.
Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, 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.
Repeat finding – This is a repeat finding. See 2023-002. Recommendation – We recommend NU evaluate its current process to ensure consistent and accurate criteria are used when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend NU evaluate its current process to ensure NSLDS is reviewed for accuracy and completeness over its students on a regular basis in order to ensure compliance and meet reporting deadlines.
FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Material Weakness in
Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section.
Institutions required to take attendance are expected to have a procedure in place for routinely monitoring
attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution’s determination that the student withdrew should be no later than 14 days after the student’s last date of attendance as determined by the institution from its attendance records.
34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) An institution must return the
amount of Title IV funds for which it is responsible under paragraph (g) of this section as soon as possible
but no later than 45 days after the date of the institution’s determination that the student withdrew as
defined in paragraph (l)(3) of this section. Condition/context – A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origination and Disbursement system.
For 2 of the 60 sampled students, an incorrect amount of funds were returned, and for 1 of these 2 students, their funds were not returned in the proper sequence. Of the 60 students sampled, 1 student was not timely identified by NU as a withdrawal. Of the 60 students, the amount to be returned was not remitted within the required 45 day window following NU’s date of determination of withdrawal for 8 students
Cause – The University does not have an effective process in place to ensure all withdrawn students are
timely identified and Title IV funds are returned accurately and timely subsequent to the calculation. Questioned Costs – Known questioned costs were $1,511. We projected the error rate over the entire universe of students whom received federal aid and withdrew, dropped out, or enrolled but never attended during the year ended June 30, 2024. Using this method, we determined likely questioned costs to be approximately $173,236.
Effect – If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government.
Repeat finding – This is a repeat finding, see 2023-001.
Recommendation – We recommend NU evaluate its current process to ensure consistent and accurate criteria are used when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend NU evaluate its process of reviewing Title IV returns to ensure returns were calculated accurately and returned timely and accurately.
FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Material Weakness in
Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section.
Institutions required to take attendance are expected to have a procedure in place for routinely monitoring
attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution’s determination that the student withdrew should be no later than 14 days after the student’s last date of attendance as determined by the institution from its attendance records.
34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) An institution must return the
amount of Title IV funds for which it is responsible under paragraph (g) of this section as soon as possible
but no later than 45 days after the date of the institution’s determination that the student withdrew as
defined in paragraph (l)(3) of this section. Condition/context – A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origination and Disbursement system.
For 2 of the 60 sampled students, an incorrect amount of funds were returned, and for 1 of these 2 students, their funds were not returned in the proper sequence. Of the 60 students sampled, 1 student was not timely identified by NU as a withdrawal. Of the 60 students, the amount to be returned was not remitted within the required 45 day window following NU’s date of determination of withdrawal for 8 students
Cause – The University does not have an effective process in place to ensure all withdrawn students are
timely identified and Title IV funds are returned accurately and timely subsequent to the calculation. Questioned Costs – Known questioned costs were $1,511. We projected the error rate over the entire universe of students whom received federal aid and withdrew, dropped out, or enrolled but never attended during the year ended June 30, 2024. Using this method, we determined likely questioned costs to be approximately $173,236.
Effect – If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government.
Repeat finding – This is a repeat finding, see 2023-001.
Recommendation – We recommend NU evaluate its current process to ensure consistent and accurate criteria are used when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend NU evaluate its process of reviewing Title IV returns to ensure returns were calculated accurately and returned timely and accurately.
FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Material Weakness in
Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section.
Institutions required to take attendance are expected to have a procedure in place for routinely monitoring
attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution’s determination that the student withdrew should be no later than 14 days after the student’s last date of attendance as determined by the institution from its attendance records.
34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) An institution must return the
amount of Title IV funds for which it is responsible under paragraph (g) of this section as soon as possible
but no later than 45 days after the date of the institution’s determination that the student withdrew as
defined in paragraph (l)(3) of this section. Condition/context – A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origination and Disbursement system.
For 2 of the 60 sampled students, an incorrect amount of funds were returned, and for 1 of these 2 students, their funds were not returned in the proper sequence. Of the 60 students sampled, 1 student was not timely identified by NU as a withdrawal. Of the 60 students, the amount to be returned was not remitted within the required 45 day window following NU’s date of determination of withdrawal for 8 students
Cause – The University does not have an effective process in place to ensure all withdrawn students are
timely identified and Title IV funds are returned accurately and timely subsequent to the calculation. Questioned Costs – Known questioned costs were $1,511. We projected the error rate over the entire universe of students whom received federal aid and withdrew, dropped out, or enrolled but never attended during the year ended June 30, 2024. Using this method, we determined likely questioned costs to be approximately $173,236.
Effect – If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government.
Repeat finding – This is a repeat finding, see 2023-001.
Recommendation – We recommend NU evaluate its current process to ensure consistent and accurate criteria are used when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend NU evaluate its process of reviewing Title IV returns to ensure returns were calculated accurately and returned timely and accurately.
FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Material Weakness in
Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section.
Institutions required to take attendance are expected to have a procedure in place for routinely monitoring
attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution’s determination that the student withdrew should be no later than 14 days after the student’s last date of attendance as determined by the institution from its attendance records.
34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) An institution must return the
amount of Title IV funds for which it is responsible under paragraph (g) of this section as soon as possible
but no later than 45 days after the date of the institution’s determination that the student withdrew as
defined in paragraph (l)(3) of this section. Condition/context – A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origination and Disbursement system.
For 2 of the 60 sampled students, an incorrect amount of funds were returned, and for 1 of these 2 students, their funds were not returned in the proper sequence. Of the 60 students sampled, 1 student was not timely identified by NU as a withdrawal. Of the 60 students, the amount to be returned was not remitted within the required 45 day window following NU’s date of determination of withdrawal for 8 students
Cause – The University does not have an effective process in place to ensure all withdrawn students are
timely identified and Title IV funds are returned accurately and timely subsequent to the calculation. Questioned Costs – Known questioned costs were $1,511. We projected the error rate over the entire universe of students whom received federal aid and withdrew, dropped out, or enrolled but never attended during the year ended June 30, 2024. Using this method, we determined likely questioned costs to be approximately $173,236.
Effect – If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government.
Repeat finding – This is a repeat finding, see 2023-001.
Recommendation – We recommend NU evaluate its current process to ensure consistent and accurate criteria are used when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend NU evaluate its process of reviewing Title IV returns to ensure returns were calculated accurately and returned timely and accurately.
FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Material Weakness in
Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 668.22 (a)(2): A student is considered to have withdrawn from a payment period or period of enrollment if, for a student in a non-term program or a subscription-based program, the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence, as defined in paragraph (d) of this section.
Institutions required to take attendance are expected to have a procedure in place for routinely monitoring
attendance records to determine in a timely manner when a student withdrawals. Except in unusual instances, the date of the institution’s determination that the student withdrew should be no later than 14 days after the student’s last date of attendance as determined by the institution from its attendance records.
34 CFR section 668.22(j): Timeframe for the return of Title IV funds. (1) An institution must return the
amount of Title IV funds for which it is responsible under paragraph (g) of this section as soon as possible
but no later than 45 days after the date of the institution’s determination that the student withdrew as
defined in paragraph (l)(3) of this section. Condition/context – A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government’s Common Origination and Disbursement system.
For 2 of the 60 sampled students, an incorrect amount of funds were returned, and for 1 of these 2 students, their funds were not returned in the proper sequence. Of the 60 students sampled, 1 student was not timely identified by NU as a withdrawal. Of the 60 students, the amount to be returned was not remitted within the required 45 day window following NU’s date of determination of withdrawal for 8 students
Cause – The University does not have an effective process in place to ensure all withdrawn students are
timely identified and Title IV funds are returned accurately and timely subsequent to the calculation. Questioned Costs – Known questioned costs were $1,511. We projected the error rate over the entire universe of students whom received federal aid and withdrew, dropped out, or enrolled but never attended during the year ended June 30, 2024. Using this method, we determined likely questioned costs to be approximately $173,236.
Effect – If controls are not in place and operating correctly, NU may not timely return the required Title IV funds to the federal government.
Repeat finding – This is a repeat finding, see 2023-001.
Recommendation – We recommend NU evaluate its current process to ensure consistent and accurate criteria are used when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend NU evaluate its process of reviewing Title IV returns to ensure returns were calculated accurately and returned timely and accurately.
FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Material Weakness in
Internal Control over Compliance (See Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): 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
i. 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 half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or
ii. A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address.
Condition/context – A sample of 60 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per NU’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. Of the 60 students who had a change in address, graduated, or withdrew, 28 were not reported to the NSLDS within the required timeframe. Of the 60 students, 11 had an incorrect effective date reported to the NSLDS. Cause – NU does not have an effective process to review NSLDS submissions, performed by NU’s third-party administrator, for accuracy and completeness on a periodic basis. Several of the late submissions identified above were a result the unexpected termination of NU’s agreement with its third-party administrator in approximately July 2024 that prevented NSLDS submissions NU wide during the months of August 2024 and November 2024.
Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, 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.
Repeat finding – This is a repeat finding. See 2023-002. Recommendation – We recommend NU evaluate its current process to ensure consistent and accurate criteria are used when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend NU evaluate its current process to ensure NSLDS is reviewed for accuracy and completeness over its students on a regular basis in order to ensure compliance and meet reporting deadlines.
FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Material Weakness in
Internal Control over Compliance (See Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): 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
i. 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 half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or
ii. A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address.
Condition/context – A sample of 60 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per NU’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. Of the 60 students who had a change in address, graduated, or withdrew, 28 were not reported to the NSLDS within the required timeframe. Of the 60 students, 11 had an incorrect effective date reported to the NSLDS. Cause – NU does not have an effective process to review NSLDS submissions, performed by NU’s third-party administrator, for accuracy and completeness on a periodic basis. Several of the late submissions identified above were a result the unexpected termination of NU’s agreement with its third-party administrator in approximately July 2024 that prevented NSLDS submissions NU wide during the months of August 2024 and November 2024.
Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, 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.
Repeat finding – This is a repeat finding. See 2023-002. Recommendation – We recommend NU evaluate its current process to ensure consistent and accurate criteria are used when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend NU evaluate its current process to ensure NSLDS is reviewed for accuracy and completeness over its students on a regular basis in order to ensure compliance and meet reporting deadlines.
FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Material Weakness in
Internal Control over Compliance (See Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): 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
i. 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 half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or
ii. A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address.
Condition/context – A sample of 60 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per NU’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. Of the 60 students who had a change in address, graduated, or withdrew, 28 were not reported to the NSLDS within the required timeframe. Of the 60 students, 11 had an incorrect effective date reported to the NSLDS. Cause – NU does not have an effective process to review NSLDS submissions, performed by NU’s third-party administrator, for accuracy and completeness on a periodic basis. Several of the late submissions identified above were a result the unexpected termination of NU’s agreement with its third-party administrator in approximately July 2024 that prevented NSLDS submissions NU wide during the months of August 2024 and November 2024.
Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, 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.
Repeat finding – This is a repeat finding. See 2023-002. Recommendation – We recommend NU evaluate its current process to ensure consistent and accurate criteria are used when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend NU evaluate its current process to ensure NSLDS is reviewed for accuracy and completeness over its students on a regular basis in order to ensure compliance and meet reporting deadlines.
FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Material Weakness in
Internal Control over Compliance (See Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): 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
i. 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 half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or
ii. A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address.
Condition/context – A sample of 60 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per NU’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. Of the 60 students who had a change in address, graduated, or withdrew, 28 were not reported to the NSLDS within the required timeframe. Of the 60 students, 11 had an incorrect effective date reported to the NSLDS. Cause – NU does not have an effective process to review NSLDS submissions, performed by NU’s third-party administrator, for accuracy and completeness on a periodic basis. Several of the late submissions identified above were a result the unexpected termination of NU’s agreement with its third-party administrator in approximately July 2024 that prevented NSLDS submissions NU wide during the months of August 2024 and November 2024.
Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, 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.
Repeat finding – This is a repeat finding. See 2023-002. Recommendation – We recommend NU evaluate its current process to ensure consistent and accurate criteria are used when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend NU evaluate its current process to ensure NSLDS is reviewed for accuracy and completeness over its students on a regular basis in order to ensure compliance and meet reporting deadlines.
FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Material Weakness in
Internal Control over Compliance (See Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): 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
i. 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 half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or
ii. A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address.
Condition/context – A sample of 60 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per NU’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. Of the 60 students who had a change in address, graduated, or withdrew, 28 were not reported to the NSLDS within the required timeframe. Of the 60 students, 11 had an incorrect effective date reported to the NSLDS. Cause – NU does not have an effective process to review NSLDS submissions, performed by NU’s third-party administrator, for accuracy and completeness on a periodic basis. Several of the late submissions identified above were a result the unexpected termination of NU’s agreement with its third-party administrator in approximately July 2024 that prevented NSLDS submissions NU wide during the months of August 2024 and November 2024.
Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, 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.
Repeat finding – This is a repeat finding. See 2023-002. Recommendation – We recommend NU evaluate its current process to ensure consistent and accurate criteria are used when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend NU evaluate its current process to ensure NSLDS is reviewed for accuracy and completeness over its students on a regular basis in order to ensure compliance and meet reporting deadlines.