Audit 397123

Finding 2025-001 – NSLDS Reporting Federal Program: Student Financial Assistance Cluster Listing Number: 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Program Federal Agency: U.S. Department of Education Award Year: July 1, 2024 – June 30, 2025 Finding Type: Significant Deficiency and Noncompliance Criteria: Institutions are required to report enrollment information under the Pell Grant and the Direct Loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). 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 certify 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. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. 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. Institutions are responsible for accurately reporting all Campus-Level Record data elements. ED considers the following data elements to be high risk: • OPEID Number, Enrollment Effective Date, Enrollment Status, Certification Date Institutions are responsible for accurately reporting all Program-Level Record data elements. ED considers the following data elements to be high risk: • OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Effective Date Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309: Perkins 34 CFR 674.19(f). Additionally, in accordance with 2 CFR 200.303, the University shall maintain internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program. Condition and Context: The University utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for transmissions of its enrollment reporting changes to the National Student Loan Data System (NSLDS). The University receives the NSLDS Reporting Roster and updates it for changes in student status. The file is sent to the Clearinghouse who transmits the updated information to NSLDS. Of the 25 students with enrollment changes we selected for test work, we noted that for one student, the University did not report the student’s status or enrollment change accurately to NSLDS within the required 60 days period. The student identified was reported 110 days late. After further analysis provided by the University, there were a total of 21 students who were impacted by this issue. Cause: For the aforementioned 21 students, the University’s internal control processes did not operate consistently to ensure that all enrollment information were submitted timely to NSLDS. Effect: Untimely submission of student enrollment status information affects the determinations that lenders and servicers of students’ 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: None noted. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Identification of whether the Audit Finding was a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the University review and revise its processes and internal controls to ensure that all enrollment information and status changes are reported to the NSLDS in a timely manner. View of Responsible Officials Management of the University agrees with the recommendation. The corrective action by Corry Unis, Vice President for Enrollment Management and Diana Draper, Executive Director of Financial Aid is as follows: The University has subsequently reported 12 of the 21 students to NSLDS. The University will update the enrollment reporting to NSLDS for the remaining 9 students impacted. The University will determine the principal cause of the discrepancy and implement a combination of controls, monitoring, and training to ensure accuracy and timeliness of future reporting.