Audit 345558

Finding 2024-001 Special Tests and Provisions Grantor: Department of Education Program: Federal Direct Student Loans Assistance Listing #: 84.268 Award Year: 07/1/2023 – 06/30/2024 Pass-through Number: Not applicable Criteria In accordance with 34 CFR 690.83(b)(2) and 685.309, the University is required to report enrollment information under the Federal Pell Grant and Federal Direct Loan programs through National Student Loan Data System (NSLDS). The enrollment information, inclusive of Campus Level and Program Level data, must be reviewed, updated and validated by the University in a timely manner. Furthermore, specific to the Federal Direct Loan program, for a student that received a Direct Loan and was enrolled or accepted for enrollment at the University, and the student had 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, the University must report the change to the NSLDS within 60 days from which the change was identified. Additionally, per the Federal Register Vol. 82, No. 122, an institution must submit Direct Loan disbursement records to the Common Origination and Disbursement (COD) within 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Condition For 5 of 25 selections, the University did not report the selected student’s campus and program-level status change to the NSLDS timely. Four of these selections were reported four days late and one was reported 21 days late. These student status changes were reported to the University’s service provider before 60 days; however, the service provider did not have sufficient time to report these changes to the NSLDS within the 60-day time frame. Additionally, for one of 25 selections, the University did not report the selected student’s disbursement to the COD timely. The disbursement was reported 90 days late. Cause The University identified and reported the student status change to the third-party service provider within 60 days. However, the third-party service provider did not have sufficient time to report to the NSLDS by the 60-day deadline. In regard to the COD disbursement that was reported late, there was a system reporting error that caused the late reporting. The University identified and resolved the system reporting error after detection. Effect Certain required reporting was not submitted within the time frame required by the regulations. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies all of which are impacted by inaccurate and late reporting. Questioned Costs There are no questioned costs associated with this finding as the matters are related to timely reporting. Recommendations The University should enhance communication between the Student Advisors, University Registrar's Office and Financial Aid Office for student status changes to ensure sufficient time for changes in status to be reported to both the third-party service provider and ultimately the NSLDS. The University should ensure that system reporting is set up and maintained in a way that allows for complete and accurate identification of disbursements that are required to be reported to the COD. Separately, the University should establish procedures to send reminders when loans have been disbursed to ensure the required reporting to the COD to takes place in a timely manner. Management’s View and Corrective Action Plan Please refer to management’s corrective action plan for management’s response and corrective action related to this finding.

Finding 2024-001 Special Tests and Provisions Grantor: Department of Education Program: Federal Direct Student Loans Assistance Listing #: 84.268 Award Year: 07/1/2023 – 06/30/2024 Pass-through Number: Not applicable Criteria In accordance with 34 CFR 690.83(b)(2) and 685.309, the University is required to report enrollment information under the Federal Pell Grant and Federal Direct Loan programs through National Student Loan Data System (NSLDS). The enrollment information, inclusive of Campus Level and Program Level data, must be reviewed, updated and validated by the University in a timely manner. Furthermore, specific to the Federal Direct Loan program, for a student that received a Direct Loan and was enrolled or accepted for enrollment at the University, and the student had 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, the University must report the change to the NSLDS within 60 days from which the change was identified. Additionally, per the Federal Register Vol. 82, No. 122, an institution must submit Direct Loan disbursement records to the Common Origination and Disbursement (COD) within 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. Condition For 5 of 25 selections, the University did not report the selected student’s campus and program-level status change to the NSLDS timely. Four of these selections were reported four days late and one was reported 21 days late. These student status changes were reported to the University’s service provider before 60 days; however, the service provider did not have sufficient time to report these changes to the NSLDS within the 60-day time frame. Additionally, for one of 25 selections, the University did not report the selected student’s disbursement to the COD timely. The disbursement was reported 90 days late. Cause The University identified and reported the student status change to the third-party service provider within 60 days. However, the third-party service provider did not have sufficient time to report to the NSLDS by the 60-day deadline. In regard to the COD disbursement that was reported late, there was a system reporting error that caused the late reporting. The University identified and resolved the system reporting error after detection. Effect Certain required reporting was not submitted within the time frame required by the regulations. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies all of which are impacted by inaccurate and late reporting. Questioned Costs There are no questioned costs associated with this finding as the matters are related to timely reporting. Recommendations The University should enhance communication between the Student Advisors, University Registrar's Office and Financial Aid Office for student status changes to ensure sufficient time for changes in status to be reported to both the third-party service provider and ultimately the NSLDS. The University should ensure that system reporting is set up and maintained in a way that allows for complete and accurate identification of disbursements that are required to be reported to the COD. Separately, the University should establish procedures to send reminders when loans have been disbursed to ensure the required reporting to the COD to takes place in a timely manner. Management’s View and Corrective Action Plan Please refer to management’s corrective action plan for management’s response and corrective action related to this finding.