Audit 393900

Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: • 84.268 – Federal Direct Loans • 84.063 – Federal Pell Grant Program Federal Award identification Number • P063P240063 - 2025 • P268K250063 – 2025 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 690.83(b)(2) and 685.309, an institution must report any enrollment status changes, including the date of the change per the institution’s reporting system, to the National Student Loan Data System (NSLDS) for participating students within 60 days of the change. Per the NSLDS Enrollment Reporting Guide Chapter 1.4, at a minimum, schools are required to certify enrollment every 60 days. Condition: As part of the August 6, 2025, roster submission of enrollment status changes, the University reported an enrollment status change of Full-Time to Graduated with an effective date of December 18, 2024, for a student who received a Direct Student Loan during the fiscal year. We measured the results of our testing against the Department of Education's 60-day timeframe for submitting roster files. The University reported the enrollment status change for this student 231 days after the effective date, or 171 days after the 60-day timeframe for submitting roster files. Questioned costs: None Context: We tested 40 students that were disbursed a Federal Pell Grant and/or a Federal Direct Loan and had an enrollment status change during the fiscal year to determine the University’s compliance with enrollment reporting. We noted one student within our sample whose enrollment status change was not reported within 60 days and whose enrollment was not being certified every 60 days. Cause: The University of Denver did not have adequate internal controls in place to ensure that it fully complied with federal student enrollment reporting requirements for the Student Financial Aid program. During the Gainful Employment/Financial Value Transparency reporting period, a discrepancy was identified regarding a student incorrectly reported to NSLDS as “withdrawn” rather than “graduated”. Upon investigation, the Office of the Registrar determined that the Autumn 2024 graduation file for the College of Law had not been submitted to the National Student Clearinghouse. This omission was due to a process gap: the College of Law’s degree conferral timeline differs from the University’s standard Undergraduate and Graduate schedules, and previous protocols relied on passive notification rather than active coordination. Effect: Enrollment reporting assists in the determination of whether a borrower should be moved into loan repayment status or if they are eligible for an in-school deferment. If an institution fails to accurately report effective enrollment status changes, a borrower’s repayment responsibilities may be reported incorrectly and result in either a lack of timely repayments by the borrower or the student being inappropriately moved into loan repayment status. For recipients of Pell Grants, timely enrollment reporting by institutions assists with their eligibility, future disbursements amounts, and continued access to Student Financial Aid. Repeat finding: No Recommendation: We recommend that the University strengthen its internal controls over reporting student enrollment changes to NSLDS to ensure that enrollment effective dates are reported to NSLDS within 60 days of an enrollment status change and that enrollment is being properly certified every 60 days. This could include requiring protocols to include an active coordination of graduation files, including those with differing conferral timelines. Views of Responsible Officials: The University agrees with the audit finding.