Audit 387426

Federal Program: U.S. Department of Education: Student Financial Aid Cluster Federal Direct Loan Program, Assistance Listing 84.268 Criteria: The College must comply with 34 Section 668.22. Condition: During our testing of official withdrawals, we selected six samples and noted for four of the samples, the incorrect withdrawal date was reported to the National Student Loan Data System (NSLDS). The difference in days from the correct withdrawal date reported ranged from 1 to 25 days. For three of the four students with incorrect withdrawal dates reported, the determination date was used instead of the withdrawal date. For one of the four students with the incorrect withdrawal date reported, the withdrawal date was a clerical error. Cause: The University’s procedure to review NSLDS reporting did not catch the error. Effect: The provisions of 34 CFR Section 668.22 were not followed and thus four students had the incorrect withdrawal date reported to NSLDS. Questioned Costs: There were no known questioned costs as a result of our testing of six official withdrawals. Recommendation: We recommend that the University review and revise their policies and procedures related to NSLDS reporting. Specifically, the University should implement a review process to verify accurate inputs before reporting to NSLDS. Views of responsible officials and planned corrective actions: The University does not agree with the conclusion of this finding. The University determines a student’s withdrawal date based on the student’s official notification or, where applicable, the date of determination when a student ceases attendance without providing official notice. Based on the University’s review of institutional records and applicable regulatory guidance in effect during the audit period, management believes the withdrawal processing methodology applied was reasonable and consistent with institutional procedures and Title IV requirements. For three of the four students identified, the data reported to NSLDS reflected the institution’s determination date rather than the withdrawal date. Management maintains that this approach was the result of interpretation applied to specific withdrawal circumstances and did not materially misrepresent the students’ enrollment status or Title IV outcomes. For the remaining student, management agrees that a clerical data-entry error resulted in an incorrect withdrawal date being reported to NSLDS; however, this instance was isolated and does not represent a systemic control deficiency. While the University does not agree that the instances cited constitute noncompliance, management acknowledges the auditor’s concern regarding consistency in distinguishing withdrawal dates from determination dates for NSLDS reporting purposes. In response, and without conceding noncompliance, the University will enhance its policies, procedures, and internal controls to promote consistent application of regulatory definitions and reduce the risk of future discrepancies.