FINDING 2025-001 Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code – The Classification of Instructional Programs (CIP) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics (NCES). They were most recently updated in 2020 and are usually updated every ten years. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition: Campus Level: Certain students’ enrollment status changes were not reported or were reported outside of the required timeframe. Program Level: Significant data elements were inaccurately reported for certain students. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: For 2 of 40 campus level records tested, the University did not certify the students’ enrollment data within the required timeframe. For 2 of 40 campus level records tested, the University did not notify the NSLDS of a change in the student’s enrollment. For 2 of 40 program level records tested, the University did not certify the students’ enrollment data within the required timeframe. For 40 of 40 program level records tested, the University did not accurately report one or more significant data elements to the NSLDS. Identification as a Repeat Finding: This is a repeat of prior year Finding 2024-001. Recommendation: We recommend the University enhances its procedures and internal controls over enrollment reporting to ensure students’ enrollment statuses are reported accurately and timely to NSLDS. Views of Responsible Officials: Audit testing identified errors in withdrawal effective dates, enrollment status changes, and program begin dates. Incorrect or untimely information was reported to NSLDS due to inconsistent internal communication and a lack of systematic reconciliation with National Student Clearinghouse (the “NSC”) reporting files. To ensure ongoing accuracy in enrollment reporting, Southern Virginia University is strengthening communication and coordination across departments involved in the reporting process. Beginning February 2026, the Financial Aid Office implemented a workflow to review NSC and NSLDS error reports more promptly and resolve discrepancies as they arise. Financial Aid will monitor this process monthly until errors are no longer identified, ensuring timely and accurate reporting going forward. The Registrar's Office will receive training on date reporting requirements and expectations for NSLDS so that they use the correct enrollment change dates.
FINDING 2025-002 Federal Program Information: Student Financial Aid Cluster (ALN: Various) Criteria or Specific Requirement: N. Special Tests and Provisions – Disbursements to or on Behalf of Students – Notification of Disbursements - The institution must provide notification to the student of the amount of and type of Title IV funds they are expected to receive and how and when those disbursements will be made (often referred to as an award letter or college financing plan) (34 CFR 668.165(a)(1)). When Direct Loans or TEACH funds are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement (a minimum of 14 or 30 days depending on confirmation process). The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR 668.165). Institutions that implement an affirmative confirmation process (as described in 34 CFR 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan or TEACH Grants. Condition: For certain students selected for testing, evidence of award letters being sent to the student could not be provided, or the award letter was not sent timely. For certain students selected for testing, evidence of a disbursement notification being sent to the student or parent could not be provided, or the notification was not sent timely. Cause: Insufficient internal control and administrative oversight. Additionally, the system automated notification function was inadvertently turned off, requiring all notifications during the year to be processed manually. Effect or Potential Effect: The University was not in compliance with the requirements for notifying students or parents of the awards they could expect to receive, or the disbursement of federal loan funds to their account. Questioned Costs: None. Context: For 2 of 25 students tested, the University was unable to provide documentation supporting award letters being sent to the student. For 1 of 25 students tested, the University did not provide the student with an award letter until subsequent to the disbursement of funds. For 20 of 25 students tested, the University was unable to provide documentation supporting appropriate loan disbursement notification to students and/or parents. For 3 of 25 students tested, the loan disbursement notifications were not made within the required timeframe. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhances its internal controls over compliance to ensure that students or parents are appropriately notified of awards and disbursements as required. Views of Responsible Officials: A sample review identified documentation gaps in Award Letters and Loan Disbursement Notifications. Notification processes were manual, leading to inconsistent documentation in the financial aid management system during employment transitions that occurred during the award year. In October 2025, Southern Virginia University transitioned both award letter notifications and loan disbursement notifications to an automated process through the Student Financial Aid Management System. All notifications are now system-generated and automatically logged within each student’s record, ensuring a complete and permanent communication history. The Financial Aid Office will maintain automated notification workflows and conduct an annual review before each aid year to verify that award letter and loan disbursement notifications are generating automatically, and documentation of the notifications is happening correctly.
FINDING 2025-003 Federal Program Information: Federal Supplemental Educational Opportunity Grants (ALN 84.007), Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions – Return of Title IV Funds: The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is after the completion of 60 percent of (1) the calendar days in the payment period or period of enrollment for a program measured in credit hours, or (2) the clock hours scheduled to be completed for the payment period or period of enrollment for a program measured in clock hours (34 CFR 668.22(e)(2)). Otherwise, the percentage earned by the student is equal to the percentage (60 percent or less) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The percentage of Title IV grant or loan assistance that has not been earned by the student is the complement of one of these calculations. Standard term-based institutions must always use the payment period as the basis for the determination. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Returns of Title IV funds must be distributed in the prescribed order (34 CFR 668.22(i)). Post-withdrawal disbursements of loan funds may be credited to the student’s account if current-year outstanding charges exist on the student’s account, up to the amount of the current-year outstanding charges only after obtaining confirmation from the student, or parent in the case of a parent PLUS loan, that he or she still wishes to have some or all of the loan funds disbursed 34 CFR 668.22(a)(6)). Condition: For a certain student that withdrew during the year, the University did not properly calculate the amounts to be returned to the ED. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with the return of Title IV funds requirements. Questioned Costs: Known questioned costs: $883; total questioned costs: $22,813. Known questioned costs of $883 were identified as a result of the described error in a withdrawal calculation; total questioned costs includes an error extrapolation over the entire population sampled. Subsequent to the identification of this error, the University returned the appropriate amount to the Department. Context: For 1 of 3 students tested, the University did not appropriately return the required amount of Title IV aid to the Department. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhances its internal controls and policies and procedures over the applicable compliance requirements to ensure that student withdrawal calculations are prepared accurately. Views of Responsible Officials: The University relied on a paper-based withdrawal process that did not consistently reach all departments in a timely manner. As a result, withdrawal dates and status changes were not always communicated accurately or in a timely manner between campus departments. Southern Virginia University has taken the following steps to resolve the issue: • A new internal check was created to verify that withdrawal dates match the verified withdrawal date before federal aid or institutional charges are updated. • The withdrawal form is being updated to require Financial Aid and Student Accounts signatures, ensuring that all relevant offices receive the information before it is finalized. • Communication procedures between the Registrar, Financial Aid, and Student Accounts have been formalized to ensure that withdrawal information is shared consistently. Southern Virginia University has also taken the following preventive actions: • A regular withdrawal review will be completed to confirm accurate dates, status changes, and timely updates across all departments and systems. • The University will maintain and distribute an updated written withdrawal workflow to impacted departments clarifying communication, verification, and documentation requirements for university withdrawals. • Staff in all involved departments will participate in training to reinforce the updated procedures.