Audit 393798

Criteria According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via NSLDS within 15 days of receipt. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS web site, certifying through the NLSDS’s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Per 2 CFR 200.303, a 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 terms and conditions of the federal award. Condition Found The University generally certifies its enrollment reports through rosters provided to the NSC. Of the forty (40) students with enrollment changes selected for testwork, we noted thirty-four (34) students whose changes in enrollment status were not transmitted to NSLDS within the required timeframe. For these students the students’ enrollment status changed from full-time to graduated in May 2025, when the students graduated. Accordingly, the status change should have been transmitted after the spring semester, within 60 days of being notified of the change. However, the University did not report status change until 79 days after the school became aware of the status change. Cause The University did not configure its file for submission to NSC correctly and therefore the submission was not properly processed by NSC and transmitted to NSLDS timely. The University did not have a control in place to monitor and verify that files sent to NSC were appropriately and timely transmitted to NSLDS. Possible Asserted Effect Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government's payment of interest subsidies. Questioned Costs No questioned costs identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding This was not a finding in the prior year. Recommendation We recommend that the University review its internal processes and controls to ensure that any enrollment changes are reported within the required 30 or 60 day time frame, including determining that changes submitted to NSC are timely and accurately transmitted to NSLDS. View of University Officials The University agrees with this finding. Upon identification of the configuration error, the University corrected its NSC file submission settings to ensure enrollment status changes are properly processed and transmitted to NSLDS. Additionally, effective immediately, the University has implemented a new monitoring control whereby an employee independent of the enrollment reporting function performs a review of NSLDS to verify that data submitted through NSC has been accurately and timely transmitted in accordance with required timeframes. This control is designed to provide timely detection of any future transmission failures and ensure corrective action is taken within the required reporting windows.