Audit 382466

FINDING 2025-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (SEE FINDING 2025-001 FOR INCLUDED TABLE) Criteria – 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: (i) 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 half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) 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 – A sample of 20 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2024-2025 academic year. The enrollment information and withdrawal, address change, or graduation date per the University’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 20 students who had a change in address, graduated, or withdrew, there were four student files with errors. There was one student file that had incorrect enrollment status reported and not reported within the required timeframe. A second student file was reported under the incorrect enrollment status but within the appropriate time requirement. Lastly, two additional student files were not reported within the required timeframe. Cause – The review procedures in place do not sufficiently address situations involving the Degree Verify transmission failures. 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 – This is not a repeat finding. Recommendation – We recommend the University establish a formal policy requiring a review of student status information submitted to the NSLDS, by a third-party intermediary on the University’s behalf, for completeness and accuracy. We also recommend the University establish a cadence of monitoring reporting deadlines, particularly those around classes of graduating students. Views of responsible officials and planned corrective actions – Management agrees and has created a corrective action plan.