Audit 344324

Finding 2024-001: Significant Deficiency - Enrollment Reporting Repeat Finding: 2023-002 ALN: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program Federal Award Identification Number: P268K232105; P063P222105 Award Year: July 1, 2023 - June 30, 2024 Federal Agency: U.S. Department of Education Pass Through Entity: Not applicable Criteria: 34 CFR 685.309(b) states that upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary in the manner and format prescribed by the Secretary and within the timeframe prescribed by the Secretary. 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 half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Condition: For one withdrawn student out of the 50 tested, the University incorrectly reported the date a student had withdrawn to the National Student Loan Data System (NSLDS). Cause: The University identified that there was an error in reporting for this student, the first date of the semester was entered as the withdrawal date rather than the true withdrawal date. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and other information, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Questioned Costs: None. Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates and status changes are reported to NSLDS within required time frames, as well as create accurate reports internally to track all students' whose status changed and verify against the roster submitted to NSLDS. This could include a review of withdrawal or graduation dates compared to the effective dates reported to NSLDS to make sure they are accurate. Management Response: Holy Family University is dedicated to ensuring the accuracy of our reporting to the NSLDS. The following is how we plan to verify the integrity of our reports. The Registrar’s Office will compare the list of students pulled in the monthly NSC process to a report showing all students who withdrew that month. This will ensure that we are reporting all withdrawn/graduated students in a timely manner. In addition, the Registrar’s Office will verify the potential graduation of students whose grades are changed after the end of the term. If the new grade completes their degree, the student will be reported as “graduated” when we process the next session’s graduation applications. This will eliminate the reliance on an external database, as manual updates tend to lack consistency. Lastly, prior to submitting the Graduates Only file to the NSLDS, the Registrar will compare the entire list of graduates to the report showing all students who withdrew throughout the semester. This will be a double check since we will also be checking grade changes, as mentioned above.

Finding 2024-001: Significant Deficiency - Enrollment Reporting Repeat Finding: 2023-002 ALN: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program Federal Award Identification Number: P268K232105; P063P222105 Award Year: July 1, 2023 - June 30, 2024 Federal Agency: U.S. Department of Education Pass Through Entity: Not applicable Criteria: 34 CFR 685.309(b) states that upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary in the manner and format prescribed by the Secretary and within the timeframe prescribed by the Secretary. 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 half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Condition: For one withdrawn student out of the 50 tested, the University incorrectly reported the date a student had withdrawn to the National Student Loan Data System (NSLDS). Cause: The University identified that there was an error in reporting for this student, the first date of the semester was entered as the withdrawal date rather than the true withdrawal date. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and other information, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Questioned Costs: None. Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates and status changes are reported to NSLDS within required time frames, as well as create accurate reports internally to track all students' whose status changed and verify against the roster submitted to NSLDS. This could include a review of withdrawal or graduation dates compared to the effective dates reported to NSLDS to make sure they are accurate. Management Response: Holy Family University is dedicated to ensuring the accuracy of our reporting to the NSLDS. The following is how we plan to verify the integrity of our reports. The Registrar’s Office will compare the list of students pulled in the monthly NSC process to a report showing all students who withdrew that month. This will ensure that we are reporting all withdrawn/graduated students in a timely manner. In addition, the Registrar’s Office will verify the potential graduation of students whose grades are changed after the end of the term. If the new grade completes their degree, the student will be reported as “graduated” when we process the next session’s graduation applications. This will eliminate the reliance on an external database, as manual updates tend to lack consistency. Lastly, prior to submitting the Graduates Only file to the NSLDS, the Registrar will compare the entire list of graduates to the report showing all students who withdrew throughout the semester. This will be a double check since we will also be checking grade changes, as mentioned above.