FINDING 2024-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (See Section III Federal Award Findings and Questioned Costs - Finding 2024-001 for included table)
Criteria – The National Student Loan Data System (NSLDS) is the Department of Education’s (ED’s) centralized database for students’ enrollment information. It is the University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes.
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
1. 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; or
2. 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 – From a system generated population of 185 federal aid recipient students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year, we selected a sample of 15 students. The enrollment information and withdrawal, address change, or graduation date per the School’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 15 students who had a change in address, graduated, or withdrew, three had errors reported to NSLDS.
Cause – The University contracts with a third-party intermediary to transmit enrollment information to NSLDS. Ultimately, the University is responsible for the accuracy and timeliness of its reporting, regardless of whether it uses a third-party. For the exceptions noted above, the University had updated its records to reflect correct status changes, however, there were technical difficulties encountered during integration between the Student Information System (SIS) and the Financial Aid Management System (FAMS) leading to inaccurate reporting to the NSDLS. The student status in FAMS was marked as “test
active” but this designation should have not been sent to NSLDS and consequently, the three files were mistakenly transmitted to NSLDS. Once the errors were detected, the University corrected the students’ records and updated NSLDS accordingly.
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 – Yes, see 2023-001.
Recommendation – We recommend the University institute a process and control to ensure student enrollment information reflected in NSLDS is in agreement with University records. This may include a checklist that is followed after an enrollment status change occurs, along with scheduled reminders to submit the changes. Another option could include a monthly or biweekly random sample of federal aid recipient students being selected for inspection, during which the current NSLDS reporting for that student is compared to the University’s underlying student records to ensure complete and accurate
reporting has occurred.
Views of responsible officials and planned corrective actions – Management agrees with the recommendation and has developed a corrective action plan to address the finding.
FINDING 2024-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (See Section III Federal Award Findings and Questioned Costs - Finding 2024-001 for included table)
Criteria – The National Student Loan Data System (NSLDS) is the Department of Education’s (ED’s) centralized database for students’ enrollment information. It is the University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes.
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
1. 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; or
2. 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 – From a system generated population of 185 federal aid recipient students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year, we selected a sample of 15 students. The enrollment information and withdrawal, address change, or graduation date per the School’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 15 students who had a change in address, graduated, or withdrew, three had errors reported to NSLDS.
Cause – The University contracts with a third-party intermediary to transmit enrollment information to NSLDS. Ultimately, the University is responsible for the accuracy and timeliness of its reporting, regardless of whether it uses a third-party. For the exceptions noted above, the University had updated its records to reflect correct status changes, however, there were technical difficulties encountered during integration between the Student Information System (SIS) and the Financial Aid Management System (FAMS) leading to inaccurate reporting to the NSDLS. The student status in FAMS was marked as “test
active” but this designation should have not been sent to NSLDS and consequently, the three files were mistakenly transmitted to NSLDS. Once the errors were detected, the University corrected the students’ records and updated NSLDS accordingly.
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 – Yes, see 2023-001.
Recommendation – We recommend the University institute a process and control to ensure student enrollment information reflected in NSLDS is in agreement with University records. This may include a checklist that is followed after an enrollment status change occurs, along with scheduled reminders to submit the changes. Another option could include a monthly or biweekly random sample of federal aid recipient students being selected for inspection, during which the current NSLDS reporting for that student is compared to the University’s underlying student records to ensure complete and accurate
reporting has occurred.
Views of responsible officials and planned corrective actions – Management agrees with the recommendation and has developed a corrective action plan to address the finding.
FINDING 2024-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (See Section III Federal Award Findings and Questioned Costs - Finding 2024-001 for included table)
Criteria – The National Student Loan Data System (NSLDS) is the Department of Education’s (ED’s) centralized database for students’ enrollment information. It is the University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes.
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
1. 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; or
2. 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 – From a system generated population of 185 federal aid recipient students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year, we selected a sample of 15 students. The enrollment information and withdrawal, address change, or graduation date per the School’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 15 students who had a change in address, graduated, or withdrew, three had errors reported to NSLDS.
Cause – The University contracts with a third-party intermediary to transmit enrollment information to NSLDS. Ultimately, the University is responsible for the accuracy and timeliness of its reporting, regardless of whether it uses a third-party. For the exceptions noted above, the University had updated its records to reflect correct status changes, however, there were technical difficulties encountered during integration between the Student Information System (SIS) and the Financial Aid Management System (FAMS) leading to inaccurate reporting to the NSDLS. The student status in FAMS was marked as “test
active” but this designation should have not been sent to NSLDS and consequently, the three files were mistakenly transmitted to NSLDS. Once the errors were detected, the University corrected the students’ records and updated NSLDS accordingly.
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 – Yes, see 2023-001.
Recommendation – We recommend the University institute a process and control to ensure student enrollment information reflected in NSLDS is in agreement with University records. This may include a checklist that is followed after an enrollment status change occurs, along with scheduled reminders to submit the changes. Another option could include a monthly or biweekly random sample of federal aid recipient students being selected for inspection, during which the current NSLDS reporting for that student is compared to the University’s underlying student records to ensure complete and accurate
reporting has occurred.
Views of responsible officials and planned corrective actions – Management agrees with the recommendation and has developed a corrective action plan to address the finding.
FINDING 2024-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (See Section III Federal Award Findings and Questioned Costs - Finding 2024-001 for included table)
Criteria – The National Student Loan Data System (NSLDS) is the Department of Education’s (ED’s) centralized database for students’ enrollment information. It is the University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes.
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
1. 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; or
2. 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 – From a system generated population of 185 federal aid recipient students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year, we selected a sample of 15 students. The enrollment information and withdrawal, address change, or graduation date per the School’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 15 students who had a change in address, graduated, or withdrew, three had errors reported to NSLDS.
Cause – The University contracts with a third-party intermediary to transmit enrollment information to NSLDS. Ultimately, the University is responsible for the accuracy and timeliness of its reporting, regardless of whether it uses a third-party. For the exceptions noted above, the University had updated its records to reflect correct status changes, however, there were technical difficulties encountered during integration between the Student Information System (SIS) and the Financial Aid Management System (FAMS) leading to inaccurate reporting to the NSDLS. The student status in FAMS was marked as “test
active” but this designation should have not been sent to NSLDS and consequently, the three files were mistakenly transmitted to NSLDS. Once the errors were detected, the University corrected the students’ records and updated NSLDS accordingly.
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 – Yes, see 2023-001.
Recommendation – We recommend the University institute a process and control to ensure student enrollment information reflected in NSLDS is in agreement with University records. This may include a checklist that is followed after an enrollment status change occurs, along with scheduled reminders to submit the changes. Another option could include a monthly or biweekly random sample of federal aid recipient students being selected for inspection, during which the current NSLDS reporting for that student is compared to the University’s underlying student records to ensure complete and accurate
reporting has occurred.
Views of responsible officials and planned corrective actions – Management agrees with the recommendation and has developed a corrective action plan to address the finding.