Audit 350606

Criteria or Specific Requirement Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records to the COD ("Common Origination and Disbursement") system. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes the disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected disbursement date. Condition Of the 40 disbursements selected for COD reporting testing, one disbursement was reported late compared to the required 15-day threshold. Cause At that time, the School was transitioning to a new system platform. As such, disbursement was not reported within the 15-day required timeframe. Effect As the change in status was not reported within the specified time or not reported at all, COD data was not up to date. Questioned Costs None noted. Context The auditor selected 40 students to test COD reporting and examined if the School reported the disbursement within 15 days. Identification as a Repeat Finding This is not a repeat finding. Recommendation We recommend the School implement a policy where the disbursements are submitted within the 15 days.

Criteria or Specific Requirement Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves-of absence. It is the institution’s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (“NSLDS”). Condition Of the ten students selected for enrollment reporting testing who graduated, all ten students tested were not reported to NSLDS within the maximum 60-day window. This was not a statistically valid sample. Cause This was overlooked by the School while switching processing systems. There were no 'late transmission' notifications as the 'Graduates Only' report did not repeat in the Spring/Summer 2024 transmission schedule. Effect A student’s enrollment status determines eligibility for in-school status, deferment, grace periods, and repayments, as well as the government’s payment of interest subsidies. The notification of student status changes to NSLDS will cause a student to enter into a grace period and determine a repayment date and, therefore, accurate and timely notification of student status to NSLDS is important. Questioned Costs None noted. Context The auditor selected 40 students to test enrollment and examined if the student had a change of address and whether there was an indication of graduating or withdrawing from the School either voluntarily or for academic purposes. We examined all applicable documentation to determine the date of any such change in status to conclude whether the School was in compliance with the reporting requirements for the student changes in status. Identification as a Repeat Finding This is not a repeat finding. Recommendation We recommend the School implement a policy where the student roster is reviewed within the required 60 days and that all changes in student status be identified and reported timely with the Department of Education. This will ensure that the requirement to notify the NSLDS is done timely and in compliance with the requirement.

Criteria or Specific Requirement Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records to the COD ("Common Origination and Disbursement") system. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes the disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected disbursement date. Condition Of the 40 disbursements selected for COD reporting testing, one disbursement was reported late compared to the required 15-day threshold. Cause At that time, the School was transitioning to a new system platform. As such, disbursement was not reported within the 15-day required timeframe. Effect As the change in status was not reported within the specified time or not reported at all, COD data was not up to date. Questioned Costs None noted. Context The auditor selected 40 students to test COD reporting and examined if the School reported the disbursement within 15 days. Identification as a Repeat Finding This is not a repeat finding. Recommendation We recommend the School implement a policy where the disbursements are submitted within the 15 days.

Criteria or Specific Requirement Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves-of absence. It is the institution’s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (“NSLDS”). Condition Of the ten students selected for enrollment reporting testing who graduated, all ten students tested were not reported to NSLDS within the maximum 60-day window. This was not a statistically valid sample. Cause This was overlooked by the School while switching processing systems. There were no 'late transmission' notifications as the 'Graduates Only' report did not repeat in the Spring/Summer 2024 transmission schedule. Effect A student’s enrollment status determines eligibility for in-school status, deferment, grace periods, and repayments, as well as the government’s payment of interest subsidies. The notification of student status changes to NSLDS will cause a student to enter into a grace period and determine a repayment date and, therefore, accurate and timely notification of student status to NSLDS is important. Questioned Costs None noted. Context The auditor selected 40 students to test enrollment and examined if the student had a change of address and whether there was an indication of graduating or withdrawing from the School either voluntarily or for academic purposes. We examined all applicable documentation to determine the date of any such change in status to conclude whether the School was in compliance with the reporting requirements for the student changes in status. Identification as a Repeat Finding This is not a repeat finding. Recommendation We recommend the School implement a policy where the student roster is reviewed within the required 60 days and that all changes in student status be identified and reported timely with the Department of Education. This will ensure that the requirement to notify the NSLDS is done timely and in compliance with the requirement.