Audit 389221

Assistance Listing Number(s), Federal Agency and Program Name: 84.063, 84.007, 84.033, and 84.268; United States Department of Education (ED), Student financial assistance cluster. Finding Type: Noncompliance and significant deficiency in internal control over compliance relating to special tests of enrollment reporting. Criteria: The Institute is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately and timely reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that ED considers high risk. Statement of Condition: Management implemented controls that specifically addressed some of the circumstances surrounding prior year finding 2024-001. Management's review of the enrollment reporting did not detect that the Institute was not timely reporting certain student Campus-Level and Program-Level data elements. Student records within the NSLDS was identified with non-timely Campus-Level and Program-Level data elements. Questioned Costs: There were no questioned costs. Context: In the sample selected, 4 students that withdrew during the 2024-2025 school year were identified with non-timely Campus-Level and Program-Level reported data elements out of a total of 30 students with status changes tested. We identified one error out of an initial sample of 25 students tested. Based on additional procedures, students that withdrew between June 4, 2024 and July 3, 2024 would not have been timely reported and would not have been detected or prevented by the Institute’s internal controls. There were a total of 4 students that withdrew in that date range and all were not timely reported. Cause: The Institute’s internal control over compliance did not detect and correct the errors. The preparer did not timely report withdrawal statuses impacting the student's effective date and status during submission process to NSLDS resulting in over 90 day certification in Campus and Program-Level enrollment data elements that ED considers high risk. The Institute’s internal control over compliance did not detect and correct the error within the 60 day initial window or additional 10-day correction window. Effect: The Institute did not timely report certain Campus-Level and Program-Level records in NSLDS which is information that ED considers high risk. Recommendation: We recommend management review policies and procedures surrounding enrollment reporting submissions to ensure the timeliness of Campus-Level and Program-Level data elements reported to ED. A review performed by an appropriate individual separate from the preparer prior to the submission of the enrollment reports to NSLDS may improve the accuracy and timing of enrollment reporting. Management’s Response: Management agrees with the finding. To resolve this issue, when a student formally withdraws or is academically dismissed in summer, the student information will be manually added to the next National Student Clearinghouse (NSC) upload file, submitted once a month, and marked as “Withdrawn” with an effective status date of the withdrawn date of determination. This complies with NSC processes detailed here: https://help.studentclearinghouse.org/compliancecentral/knowledge-base/enrollment-reporting-for-summer-and-other-non-required-terms/.