Audit 370308

Federal Program: Student Financial Assistance Cluster Listing Number: 84.268 Federal Direct Student Loans Program Federal Agency: Department of Education Award Year: June 1, 2024 – May 31, 2025 Criteria: According to the Code of Federal Regulations 685.309, enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. An institution must notify the Secretary of Education if it discovers a loan under Title IV of the Act was made to or on behalf of a student who was enrolled on at least a half-time basis or failed to enroll on a least a half-time basis for the period for which the loan was interested. Department of Education lists several certification methods for enrollment reporting, including certifying directly through the National Student Loan Data System (NSLDS) website, or certifying through NSLDS’s batch enrollment reporting process. Additionally, there are two categories of enrollment information within NSLDS, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Further, per the NSLDS Enrollment Reporting Guide, as with any school/servicer arrangement for the administration of Title IV programs, if the institution uses an Enrollment Reporting Servicer, the institution still has the primary responsibility in submitting timely, accurate, and complete responses to Enrollment Reporting Roster files, and for reporting any changes in student enrollment status in a timely manner. Institutions must also ensure to maintain proper documentation in accordance with 34 CFR 682.610(c) and 34 CFR 685.300(b). Condition and Context: Of the 60 students with enrollment changes selected for testwork, we noted that for five graduated students the University did not report the students’ status or enrollment change accurately to NSLDS. Specifically, the enrollment status for two students was reported by the University as graduated to the National Student Clearinghouse (NSC), however NSC reported the student status as withdrawal to NSLDS, and the University did not subsequently correct and report the students as graduated. Further, the enrollment status for three students was reported by the University as graduated to the National Student Clearinghouse (NSC), however NSC reported the student status as Full-time to NSLDS, and the University did not subsequently correct and report the students as graduated. Possible Cause and Effect: The University’s internal control process failed in detecting that inaccurate information was reported by NSC to NSLDS. Isolated or Systemic: Systemic. Questioned Costs: None noted. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: No. Recommendation: We recommend that the University enhances its internal controls to ensure all information submitted by NSC to NSLDS is reviewed for accuracy on a timely basis. View of Responsible Officials: The University concurs with this finding and is reviewing the internal controls and working with NSC to ensure accurate and timely reporting.