Audit 392841

Finding 2025-001: NSLDS Reporting Federal Agency U.S. Department of Education Federal Program Student Financial Assistance Cluster (CFDA # 84.268, 84.063) Federal Award Year July 1, 2024 through June 30, 2025 46 (Continued) Federal Award Numbers P268K251300; P063P241300 Criteria or Requirement Per Sections 34 CFR 690.83(b)(2) and 34 CFR 685.309, a school shall update the student status confirmation report for changes in student status, report the date the enrollment status was effective and return the student status confirmation report to the Secretary within 30 days unless it plans to submit an enrollment report within the next 60 days of receipt. Per Sections 4.4.2 through 4.4.4 of the NSLDS enrollment reporting guide, institutions are responsible for accurately reporting all Campus-Level Record data elements and considers certain data elements to be high risk including OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. Per Section 4.4.8 of the NSLDS enrollment reporting guide, institutions are responsible for accurately reporting all Program-Level Record data elements and considers certain data elements to be high risk including OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition Found For 3 out of 40 students, the graduate status was reported to NSLDS between 78 and 101 days after the date the school became aware of the status change. There were a total of 34 graduates from the Spring 2025 semester, certified outside of the normal graduation timeline, for which this same condition applied. For 1 out of 40 students, the three-quarter time status was reported to NSLDS 120 days after the date the school became aware of the status change. For 1 out of 40 students, the half-time status with an effective date of 8/21/2024 was not reported to NSLDS Program-Level Record data. For 1 out of 40 students, the effective date for the half-time status reported to NSLDS per the Program-Level Record data does not match the Campus-Level Record data by 19 days. Possible Cause and Asserted Effect The control that management reviews all reports for the accuracy of all data elements prior to submission was not operating at a level to identify all discrepancies. Questioned Costs None identified. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the control around the review of accuracy and timeliness of the enrollment statuses, program level data records, and campus level data records within the NSLDS reporting submissions. Views of Responsible Officials The University agrees with the finding as written. Responsibility for NSLDS reporting submissions of enrollment statuses, program level data records, and campus level data records lies within the Office of the Registrar. For the three instances of enrollment status change and consistency with program-level record data, these relate to the omission of changing a program-level effective date but not a campus-level effective date. Procedures are being updated and appropriate review and reporting for any status changes will have secondary review going forward. The graduation date reporting errors relate to students whose graduation certification occurred outside the normal bounds of semester-end graduation cycles, again requiring a more manual human intervention to ensure timely reporting. The Office of the Registrar is implementing procedures for system reporting and a secondary reviewer of all graduation status changes on a monthly basis to ensure timely filing, and procedures also are updated to ensure manual updating of Clearinghouse to NSLDS records immediately upon logging any off-cycle graduation in the Office of the Registrar. This ensures a double review - at the time of the off-cycle record change, and in the monthly reporting of all status changes which will be reviewed and sent to NSLDS via Clearinghouse.