Audit 379896

Federal Program Information: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Enrollment Reporting – Institutions are required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the University becomes aware of the change in enrollment status. Campus and Program Level records are required to be submitted timely, accurately, and completely. According to the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Condition: For certain students whose status changed during the year, the University did not accurately or timely report data elements identified as high risk by ED. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with enrollment reporting compliance requirements. Questioned Costs: None. Context: For 2 of 40 students selected for campus level and program level testing, the students’ statuses were not certified within the required timeframe. For 2 of 40 program-level records tested, the records contained an inaccurately reported data element. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2024-001 in the 2024 report. Recommendation: We recommend that the University implement procedures to ensure that that all status changes are submitted to the NSLDS website within the required timeframe and that all record data elements are reported accurately. Views of Responsible Officials: Liberty University acknowledges that its FY25 single audit identified instances where students’ enrollment reporting was not updated in a timely manner in accordance with U.S. Department of Education (ED) requirements. Liberty has invested significant effort into ensuring its enrollment reporting process is handled compliantly and within alignment with ED’s best practices. Liberty’s Registrar’s Office created a new Director of Clearinghouse Reporting position in May 2024, who is responsible for monitoring Clearinghouse feeds and any associated error reports and works closely with Liberty’s Financial Aid and Information Technology (ADS) offices to ensure enrollment reporting compliance. Liberty has continued the work of developing a more comprehensive quality control (QC) process by reviewing the Clearinghouse Reject report in a timely manner, meeting on a monthly basis with internal stakeholders, and working more closely with Clearinghouse Representatives to identify scenarios where enrollment records are accurately reported to Clearinghouse but never sent on to NSLDS. Liberty University plans to provide Clearinghouse representatives with specific audit cases to identify gaps in enrollment reporting and increase accuracy of individual reviews. Liberty Internal QC Reporting: Liberty University will continue to work quality control and the Clearinghouse Reject report which has enabled the university to be more proactive in its compliance efforts. Additionally, Graduated Dates Prior to Term End, NSLDS MisMatches, NSLDS No Banner SSN, and the NSLDS Record Missing reports will continue to be worked in a timely manner. These reports have been helpful to identify more common/persistent errors/delays and provide an additional layer of quality control checks for Liberty’s enrollment reporting. Accountability Meetings: Liberty began holding a series of biweekly “Enrollment Reporting Check-In” meetings with key stakeholders from Financial Aid, Registrar, and IT/ADS in February 2024, which are dedicated to discussing current and upcoming enrollment reporting submissions and errors, trends seen with SSCR errors, and brainstorming ways to ensure ongoing compliance. These meetings will continue with a focus on ways to improve reporting logic to prevent errors from occurring. While improvement efforts continue to be underway, Liberty believes these efforts are starting to bear fruit as evidenced by a 99.7% reduction in the number of repeat errors from FY24 to FY25. Finally, Liberty University uses a standard formula for its Program Lengths in order to ensure compliance with other requirements, however certain programs have unique program lengths which may not align with this standard formula for Enrollment Reporting purposes. The Financial Aid Office will work with Registrar and the Provost’s Office, to evaluate any programs which fall outside the standard formula and adjust the published program dates as necessary. Moving forward Liberty will continue to hold monthly meetings with key stakeholders to discuss any enrollment reporting errors and ensure best practices are implemented to ensure ongoing and timely accuracy. The University’s Registrar’s Office will also continue to review the QC reports in an appropriate manner, as well as evaluate the processes for withdrawal/graduated student files. Liberty will continue to review and implement updates as necessary to maintain enrollment reporting compliance and believes these new processes will allow us to be compliant in subsequent years.

Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (ALN 84.007), Federal Work- Study Program (ALN 84.033), Federal Pell Grant Program (ALN 84.063), Federal Direct Loan Program (ALN 84.268), and Teacher Education Assistance for College and Higher Education (“TEACH”) Grants (ALN 84.379) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Verification: For students selected for verification by the central processor, the institutions must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E). Condition: For a student selected for verification, certain information required to be verified did not match the underlying supporting documentation (including certain tax information). Cause: Administrative oversight and insufficient internal controls over verification requirements. Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations and the University was not in compliance with verification compliance requirements. Questioned Costs: None. Context: For 1 of 20 students selected for testing, the University did not complete appropriate verification procedures prior to disbursing aid. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls over compliance to ensure that students are verified as required. Views of Responsible Officials: To strengthen compliance and ensure the accuracy of student aid eligibility determinations, we will enhance Liberty’s quality control (QC) measures within the federal verification process. Our primary goal is to minimize errors, improve consistency, and ensure all Financial Aid verification activities align with federal regulations and institutional policy. We will begin by implementing a more targeted QC process aimed at validating records of students who submitted subsequent tax documents. We will increase our verification QC selections of this particular population from 35% (current) to 60% (future) to verify data accuracy, documentation completeness, and adherence to ED’s Application and Verification Guide (AVG). Findings from these reviews will be used to identify training needs and process improvements. Staff training will be expanded to focus on federal verification requirements, common error trends, and documentation standards. Refresher trainings will be held with the entire verification processing team, and supplemental individual coaching will be provided on a monthly basis to address any specific issues identified through QC. We will also create reporting to ensure the percentage of reviews mentioned above is maintained by our QC workflow. Regular data analysis will help identify any systemic issues early, allowing for corrective actions to mitigate any compliance issues. By reinforcing staff training, system monitoring, and increased reviews, we will ensure that our federal verification process remains accurate, compliant, and student-centered.