Audit 4011

FINDING 2023-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control (See Section III - Federal Award Findings and Questioned Costs for table) Criteria – The National Student Loan Data System (NSLDS) is the Department of Education’s (ED’s) centralized database for students’ enrollment information. It is the University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes. 34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that 1. 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 halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or 2. A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/context – From a system generated population of 144 students who received federal aid and either graduated, withdrew, or dropped during the six-month period ended June 30, 2023, we selected a sample of 20 students. The enrollment information and withdrawal or graduation date per the University’s records were compared to the information reported to NSLDS in order to determine if status changes were reported accurately and within the required timeframes. Of the 20 students who graduated or withdrew, 14 were not reported to the NSLDS within the required timeframe, 10 had an incorrect effective date reported to the NSLDS, and 2 had an incorrect status reported to the NSLDS. Cause – Although the University maintains well documented records regarding enrollment status changes, the University did not always have a process in place to ensure that NSLDS records were being updated routinely after a change. The University has historically not used a clearinghouse or other service for reporting changes, and instead, has relied on manual entries to make updates. Effect – The NSLDS database did not include all accurate information in the timeframe required by ED. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat finding – This is not a repeat finding. Recommendation – We recommend the University institute a process and control to ensure student enrollment information reflected in NSLDS is in agreement with University records. This may include a checklist that is followed after an enrollment status change occurs, along with scheduled reminders to submit the changes. Another option would be to ensure that on a monthly or biweekly basis, review all students with known status changes to ensure that updates have been made, or enlist the support of a third party. Views of responsible officials and planned corrective actions – Management agrees with the recommendation and has developed a corrective action plan to address the finding.

FINDING 2023-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control (See Section III - Federal Award Findings and Questioned Costs for table) Criteria – The National Student Loan Data System (NSLDS) is the Department of Education’s (ED’s) centralized database for students’ enrollment information. It is the University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes. 34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that 1. 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 halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or 2. A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/context – From a system generated population of 144 students who received federal aid and either graduated, withdrew, or dropped during the six-month period ended June 30, 2023, we selected a sample of 20 students. The enrollment information and withdrawal or graduation date per the University’s records were compared to the information reported to NSLDS in order to determine if status changes were reported accurately and within the required timeframes. Of the 20 students who graduated or withdrew, 14 were not reported to the NSLDS within the required timeframe, 10 had an incorrect effective date reported to the NSLDS, and 2 had an incorrect status reported to the NSLDS. Cause – Although the University maintains well documented records regarding enrollment status changes, the University did not always have a process in place to ensure that NSLDS records were being updated routinely after a change. The University has historically not used a clearinghouse or other service for reporting changes, and instead, has relied on manual entries to make updates. Effect – The NSLDS database did not include all accurate information in the timeframe required by ED. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat finding – This is not a repeat finding. Recommendation – We recommend the University institute a process and control to ensure student enrollment information reflected in NSLDS is in agreement with University records. This may include a checklist that is followed after an enrollment status change occurs, along with scheduled reminders to submit the changes. Another option would be to ensure that on a monthly or biweekly basis, review all students with known status changes to ensure that updates have been made, or enlist the support of a third party. Views of responsible officials and planned corrective actions – Management agrees with the recommendation and has developed a corrective action plan to address the finding.