Special Tests – Enrollment Reporting
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
ASSISTANCE LISTING Number:
84.268 – Federal Direct Student Loans
84.063 – Federal Pell Grant Program
Federal Award Identification Number and Year: P063P230362 2024 and P268K240362 2024
Award Period: June 1, 2023 to June 30, 2024
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter
Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information; “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file. The University must also have an adequate process to internally review submissions to either the third-party servicer or directly to NSLDS. Additionally, Institutions are required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR
200.303.
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 student enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). Our testing resulted in the following items of noncompliance.
1. 10 individual students where a student's campus-level enrollment effective date was not correctly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2)
2. 13 instances where a student’s enrollment status change was not reported timely to NSLDS. 34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2)
Questioned costs: N/A
Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 21 students with exceptions. 2 students had multiple instances of noncompliance.
Cause: Turnover at the university did not lead to adequate corrective action taken after the prior year audit. The University was unaware of the errors which were caused by the transmission of data between there student information system and the third-party servicer.
Effect: The NSLDS system could not be updated accurately or timely with student enrollment information.
Repeat finding: Yes 2023-001
Recommendation: We recommend that the University ensure it has enhanced its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely.
View of responsible official: The University agrees with the finding.
Special Tests – Enrollment Reporting
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
ASSISTANCE LISTING Number:
84.268 – Federal Direct Student Loans
84.063 – Federal Pell Grant Program
Federal Award Identification Number and Year: P063P230362 2024 and P268K240362 2024
Award Period: June 1, 2023 to June 30, 2024
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter
Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information; “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file. The University must also have an adequate process to internally review submissions to either the third-party servicer or directly to NSLDS. Additionally, Institutions are required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR
200.303.
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 student enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). Our testing resulted in the following items of noncompliance.
1. 10 individual students where a student's campus-level enrollment effective date was not correctly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2)
2. 13 instances where a student’s enrollment status change was not reported timely to NSLDS. 34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2)
Questioned costs: N/A
Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 21 students with exceptions. 2 students had multiple instances of noncompliance.
Cause: Turnover at the university did not lead to adequate corrective action taken after the prior year audit. The University was unaware of the errors which were caused by the transmission of data between there student information system and the third-party servicer.
Effect: The NSLDS system could not be updated accurately or timely with student enrollment information.
Repeat finding: Yes 2023-001
Recommendation: We recommend that the University ensure it has enhanced its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely.
View of responsible official: The University agrees with the finding.
Eligibility – Direct Loan Entrance Counseling
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
ASSISTANCE LISTING Numbers:
84.268 – Federal Direct Student Loans
Federal Award Identification Number and Year: P268K240362 2024
Award Period: June 1, 2023 to June 30, 2024
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter
Criteria or specific requirement: As outlined under 34 CFR 668.164(l), an institution is required to ensure entrance counseling has been performed before disbursing Direct loan funds to the student for Direct Subsidized Loan, Direct Unsubsidized Loan and Direct PLUS Loan to a graduate or professional student.
Condition: During our testing, one of the 40 students selected for testing did not receive entrance counseling prior to receiving their first Grad PLUS Direct Loan Disbursement.
Questioned costs: Federal Direct Student Loans - $3,381.
Context: Out of our population and sample of 40 students, the University did not document 1 student’s entrance counseling completion.
Cause: The University’s processes and controls did not ensure that entrance counseling was completed or did not retain proper support to indicate this process took place.
Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate.
Repeat finding: No
Recommendation: We recommend the Institute review its policies and procedures around sending entrance information to students to ensure students are receiving proper counseling and ensure entrance counseling is documented before loans disbursements are made.
View of responsible official: The University agrees with the finding.
Special Tests – Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
ASSISTANCE LISTING Numbers:
84.268 – Federal Direct Student Loans
84.063 – Federal Pell Grant Program
Federal Award Identification Number and Year: P063P230362 2024 and P268K240362 2024
Award Period: June 1, 2023 to June 30, 2024
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter
Criteria or specific requirement: An institution must provide to Department of Education an up-to date URL for the contract for publication in a centralized database accessible to the public. Unless the school has a Tier Two arrangement under the threshold, the URL must also include the contract data described in the paragraph above (34 CFR 668.164(e)(2)(viii); 668.164(f)(4)(iii)(B); 668.164(f)(4)(v)). Additionally, Institutions are required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR 200.303.
Condition: During our testing the University could not provide support that an up-to-date contract establishing their tier two arrangement was provided to the Department of Education.
Questioned costs: N/A
Context: The University did not meet the compliance requirement to report the contract and contract components to the Department of Education.
Cause: Turnover at the university did not lead to adequate corrective action taken after the prior year audit. The University was not aware of the requirement and previously personal did not retain applicable support, if completed.
Effect: The Department of Education was not provided required information regarding the contract.
Repeat finding: Yes 2023-003
Recommendation: We recommend that the University ensure it has enhanced its policies and procedures to ensure required contracts and contract components are provided to the Department of
education when required.
View of responsible official: The University agrees with the finding.
Special Tests – Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
ASSISTANCE LISTING Numbers:
84.268 – Federal Direct Student Loans
84.063 – Federal Pell Grant Program
Federal Award Identification Number and Year: P063P230362 2024 and P268K240362 2024
Award Period: June 1, 2023 to June 30, 2024
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter
Criteria or specific requirement: An institution must provide to Department of Education an up-to date URL for the contract for publication in a centralized database accessible to the public. Unless the school has a Tier Two arrangement under the threshold, the URL must also include the contract data described in the paragraph above (34 CFR 668.164(e)(2)(viii); 668.164(f)(4)(iii)(B); 668.164(f)(4)(v)). Additionally, Institutions are required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR 200.303.
Condition: During our testing the University could not provide support that an up-to-date contract establishing their tier two arrangement was provided to the Department of Education.
Questioned costs: N/A
Context: The University did not meet the compliance requirement to report the contract and contract components to the Department of Education.
Cause: Turnover at the university did not lead to adequate corrective action taken after the prior year audit. The University was not aware of the requirement and previously personal did not retain applicable support, if completed.
Effect: The Department of Education was not provided required information regarding the contract.
Repeat finding: Yes 2023-003
Recommendation: We recommend that the University ensure it has enhanced its policies and procedures to ensure required contracts and contract components are provided to the Department of
education when required.
View of responsible official: The University agrees with the finding.
Special Tests – Enrollment Reporting
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
ASSISTANCE LISTING Number:
84.268 – Federal Direct Student Loans
84.063 – Federal Pell Grant Program
Federal Award Identification Number and Year: P063P230362 2024 and P268K240362 2024
Award Period: June 1, 2023 to June 30, 2024
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter
Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information; “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file. The University must also have an adequate process to internally review submissions to either the third-party servicer or directly to NSLDS. Additionally, Institutions are required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR
200.303.
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 student enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). Our testing resulted in the following items of noncompliance.
1. 10 individual students where a student's campus-level enrollment effective date was not correctly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2)
2. 13 instances where a student’s enrollment status change was not reported timely to NSLDS. 34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2)
Questioned costs: N/A
Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 21 students with exceptions. 2 students had multiple instances of noncompliance.
Cause: Turnover at the university did not lead to adequate corrective action taken after the prior year audit. The University was unaware of the errors which were caused by the transmission of data between there student information system and the third-party servicer.
Effect: The NSLDS system could not be updated accurately or timely with student enrollment information.
Repeat finding: Yes 2023-001
Recommendation: We recommend that the University ensure it has enhanced its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely.
View of responsible official: The University agrees with the finding.
Special Tests – Enrollment Reporting
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
ASSISTANCE LISTING Number:
84.268 – Federal Direct Student Loans
84.063 – Federal Pell Grant Program
Federal Award Identification Number and Year: P063P230362 2024 and P268K240362 2024
Award Period: June 1, 2023 to June 30, 2024
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter
Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. There are two categories of enrollment information; “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file. The University must also have an adequate process to internally review submissions to either the third-party servicer or directly to NSLDS. Additionally, Institutions are required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR
200.303.
Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 student enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). Our testing resulted in the following items of noncompliance.
1. 10 individual students where a student's campus-level enrollment effective date was not correctly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2)
2. 13 instances where a student’s enrollment status change was not reported timely to NSLDS. 34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2)
Questioned costs: N/A
Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 21 students with exceptions. 2 students had multiple instances of noncompliance.
Cause: Turnover at the university did not lead to adequate corrective action taken after the prior year audit. The University was unaware of the errors which were caused by the transmission of data between there student information system and the third-party servicer.
Effect: The NSLDS system could not be updated accurately or timely with student enrollment information.
Repeat finding: Yes 2023-001
Recommendation: We recommend that the University ensure it has enhanced its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely.
View of responsible official: The University agrees with the finding.
Eligibility – Direct Loan Entrance Counseling
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
ASSISTANCE LISTING Numbers:
84.268 – Federal Direct Student Loans
Federal Award Identification Number and Year: P268K240362 2024
Award Period: June 1, 2023 to June 30, 2024
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter
Criteria or specific requirement: As outlined under 34 CFR 668.164(l), an institution is required to ensure entrance counseling has been performed before disbursing Direct loan funds to the student for Direct Subsidized Loan, Direct Unsubsidized Loan and Direct PLUS Loan to a graduate or professional student.
Condition: During our testing, one of the 40 students selected for testing did not receive entrance counseling prior to receiving their first Grad PLUS Direct Loan Disbursement.
Questioned costs: Federal Direct Student Loans - $3,381.
Context: Out of our population and sample of 40 students, the University did not document 1 student’s entrance counseling completion.
Cause: The University’s processes and controls did not ensure that entrance counseling was completed or did not retain proper support to indicate this process took place.
Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate.
Repeat finding: No
Recommendation: We recommend the Institute review its policies and procedures around sending entrance information to students to ensure students are receiving proper counseling and ensure entrance counseling is documented before loans disbursements are made.
View of responsible official: The University agrees with the finding.
Special Tests – Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
ASSISTANCE LISTING Numbers:
84.268 – Federal Direct Student Loans
84.063 – Federal Pell Grant Program
Federal Award Identification Number and Year: P063P230362 2024 and P268K240362 2024
Award Period: June 1, 2023 to June 30, 2024
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter
Criteria or specific requirement: An institution must provide to Department of Education an up-to date URL for the contract for publication in a centralized database accessible to the public. Unless the school has a Tier Two arrangement under the threshold, the URL must also include the contract data described in the paragraph above (34 CFR 668.164(e)(2)(viii); 668.164(f)(4)(iii)(B); 668.164(f)(4)(v)). Additionally, Institutions are required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR 200.303.
Condition: During our testing the University could not provide support that an up-to-date contract establishing their tier two arrangement was provided to the Department of Education.
Questioned costs: N/A
Context: The University did not meet the compliance requirement to report the contract and contract components to the Department of Education.
Cause: Turnover at the university did not lead to adequate corrective action taken after the prior year audit. The University was not aware of the requirement and previously personal did not retain applicable support, if completed.
Effect: The Department of Education was not provided required information regarding the contract.
Repeat finding: Yes 2023-003
Recommendation: We recommend that the University ensure it has enhanced its policies and procedures to ensure required contracts and contract components are provided to the Department of
education when required.
View of responsible official: The University agrees with the finding.
Special Tests – Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device
Federal Agency: Department of Education
Federal Program Title: Student Financial Assistance Cluster
ASSISTANCE LISTING Numbers:
84.268 – Federal Direct Student Loans
84.063 – Federal Pell Grant Program
Federal Award Identification Number and Year: P063P230362 2024 and P268K240362 2024
Award Period: June 1, 2023 to June 30, 2024
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter
Criteria or specific requirement: An institution must provide to Department of Education an up-to date URL for the contract for publication in a centralized database accessible to the public. Unless the school has a Tier Two arrangement under the threshold, the URL must also include the contract data described in the paragraph above (34 CFR 668.164(e)(2)(viii); 668.164(f)(4)(iii)(B); 668.164(f)(4)(v)). Additionally, Institutions are required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR 200.303.
Condition: During our testing the University could not provide support that an up-to-date contract establishing their tier two arrangement was provided to the Department of Education.
Questioned costs: N/A
Context: The University did not meet the compliance requirement to report the contract and contract components to the Department of Education.
Cause: Turnover at the university did not lead to adequate corrective action taken after the prior year audit. The University was not aware of the requirement and previously personal did not retain applicable support, if completed.
Effect: The Department of Education was not provided required information regarding the contract.
Repeat finding: Yes 2023-003
Recommendation: We recommend that the University ensure it has enhanced its policies and procedures to ensure required contracts and contract components are provided to the Department of
education when required.
View of responsible official: The University agrees with the finding.