Audit 383866

FINDING 2025-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (see Section III-Federal Awards Findings and Questioned Costs for included table) Criteria – Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that institution but has ceased to be enrolled on at least a half-time basis. Condition/Context – A sample of 28 out of a population of approximately 200 federal aid recipient students were selected from system generated reports of students who had a reduction or increase in attendance levels, graduated, withdrew, dropped out, or enrolled but never attended during the 2024- 2025 academic year. A comparison was made between each selected student’s National Student Loan Data System (NSLDS) enrollment detail to the student’s academic files and other institutional records to verify that the College was accurately reporting significant campus-level and program-level enrollment data within the required time frame. Of the 28 students whom had a change in address, graduated, or withdrew, 2 were not reported to the NSLDS within the required timeframe. Questioned Costs – No questioned costs were identified as part of this finding. Effect – Enrollment status is utilized by students, the U.S. Department of Education, the Direct Loan program, lenders, and other institutions to determine in‐school status. NSLDS also uses the newly submitted enrollment data to recalculate a student’s 150% limit for direct subsidized loans to determine if loss or protection of the subsidy should occur. Therefore, this significant deficiency in enrollment reporting could result in incorrect future eligibility for undergraduate aid, as well as impact future subsidy loss or protection related to the 150% limit. Cause – The student status change was not timely reported due to the College not having effective internal controls established to prevent, or detect and correct, the non-compliance in a timely manner. Repeat Finding – This is a repeat finding, see 2024-002. Recommendation – We recommend the College implement a detective control by which a sample of student status changes are subsequently verified within the NSLDS for accurate and timely reporting. Views of Responsible Officials and Planned Corrective Actions – Otis College of Art and Design agrees with the finding. The Executive Director of Financial Aid and The One Stop, Michaela Matsumoto and Registrar, Nicole Raef are the responsible individuals for implementation of the corrective action plan. The Registrar implemented a centralized tracking system that is now used for every withdrawal and graduation status change at all points in the semester. Registration reviews the withdrawal list weekly to ensure each change is accurately reflected in both Clearinghouse and NSLDS. To address graduation status updates, Otis College of Art and Design are adjusting the timeline of its final spring enrollment report to Clearinghouse so it is submitted at the end of May. This allows Clearinghouse to transmit the data to NSLDS at the beginning of June resulting in fewer manual updates in NSLDS. Registration will then review all graduated students to confirm accurate NSLDS reporting rather than relying solely on Clearinghouse submissions. In addition, the Registration office will review and correct the Clearinghouse error report on a monthly basis. The Financial Aid and Registration offices will also initiate quarterly meetings to ensure timely submissions and address any emerging issues.