Audit 44218

FY End
2022-05-31
Total Expended
$23.51M
Findings
12
Programs
6
Organization: King University (TN)
Year: 2022 Accepted: 2023-01-15

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
43034 2022-001 Significant Deficiency - N
43035 2022-002 Significant Deficiency - N
43036 2022-004 Significant Deficiency - N
43037 2022-001 Significant Deficiency - N
43038 2022-002 Significant Deficiency - N
43039 2022-003 Significant Deficiency - N
619476 2022-001 Significant Deficiency - N
619477 2022-002 Significant Deficiency - N
619478 2022-004 Significant Deficiency - N
619479 2022-001 Significant Deficiency - N
619480 2022-002 Significant Deficiency - N
619481 2022-003 Significant Deficiency - N

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $15.48M Yes 3
84.063 Federal Pell Grant Program $3.36M Yes 3
84.425 Covid-19 - Education Stabilization Fund $1.86M Yes 0
84.038 Federal Perkins Loan Program $761,213 Yes 0
84.007 Federal Supplemental Educational Opportunity Grants $146,493 Yes 0
84.033 Federal Work-Study Program $119,414 Yes 0

Contacts

Name Title Type
RCWNUH9DNQE4 Lettie Jackson Auditee
4236524719 Chad Kisner Auditor
No contacts on file

Notes to SEFA

Title: Note A: Federal Loan Programs Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. During the year ended May 31, 2022, the University processed the following amount of new loans under the Federal Perkins Loan Program and the William D. Ford Federal Direct Loan Program (which includes Graduate Plus Loans and Parent Plus Loans for Undergraduate Students): $15,479,168.
Title: Note B: Basis of Presentation Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The schedule of expenditures of federal awards (the Schedule) includes the federal award activity of King University under programs of the federal government for the year ended May 31, 2022. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of King University, it is not intended to, and does not present, the financial position, changes in net assets or cash flows of King University.
Title: Note D: Federal Perkins Loan Program Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The University administers the Perkins Loan Program. For purposes of the schedule, the amount reported includes the outstanding loan balance at the beginning of the fiscal year. Due to regulation changes, no further loans can be made from the program and no administrative cost allowance can be taken from the loan fund. The balance of the federal loans outstanding at May 31, 2022 and 2021 consists of $729,423 and $761,213, respectively. Schools have the option of continuing to collect on outstanding loan balances or can voluntarily liquidate the program. The University has no current plans to begin the Perkins liquidation process, however, is required to periodically return excess cash on hand from the program to the Department of Education.

Finding Details

2022-001 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, once the Enrollment Reporting roster file is received from the NSLDS, the institution must update the Enrollment Reporting roster file for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes to NSLDS. Statement of Condition: During the 2022 audit, it was noted that the University incorrectly reported student enrollment status at changes in enrollment or did not report an updated status whatsoever. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The 2022 audit included a detailed testing of 40 student files, of which this significant deficiency applies to 18, indicating an error rate of 45.00%. Cause and Effect: Due to lapses in communication between departments, in certain instances, the University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct withdrawal status is reported to NSLDS. View of Responsible Officials: King University uses the National Student Clearinghouse to report enrollment changes to NSLDS. We believe a portion of the untimely reporting to NSLDS is a result of the reporting delays between the National Student Clearinghouse and NSLDS, as documented in GENERAL-22-64 beginning July 25, 2022. The Dear Colleague letter and subsequent updates describe issues with enrollment functionality, which affected enrollment reporting. King conducted a review on a sample of students and found that students were reported correctly to the Clearinghouse but were not appearing in NSLDS. A more frequent enrollment schedule should remedy this issue. We also attribute these delays to changes in leadership/staffing during that timeframe. The enrollment reporting steps were outlined by the prior Registrar when this process transitioned to the Office of Institutional Research, but this staffing transition could have resulted in inaccurate data being captured and reported during a window of time in Fall 2021 (when the reporting responsibility transitioned). Additionally, it was discovered that incorrect coding in the CAMS database management system (DBMS) was causing exclusions based on a missing field. These exclusions began in Summer 2021 due to added majors that were not correctly created.
2022-002 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, 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 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. Statement of Condition: During the 2022 audit, it was noted that the University did not supply status updates to NSLDS in a timely manner, within the 60-day window. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The 2022 audit included a detailed testing of 40 student files, of which this significant deficiency applies to 4, indicating an error rate of 10.00%. Cause and Effect: Due to lapses in communication between departments, in certain instances, the University provided NSLDS with updates to student enrollment statuses outside of a timeframe that is considered to be reasonably appropriate, resulting in delayed representation within the NSLDS system. Recommendation: The University should ensure that any updates to enrollment status be reported to NSLDS within 60 days of the effective date of change. View of Responsible Officials: King University uses the National Student Clearinghouse to report enrollment changes to NSLDS. We believe a portion of the untimely reporting to NSLDS is a result of the reporting delays between the National Student Clearinghouse and NSLDS, as documented in GENERAL-22-64 beginning July 25, 2022. The Dear Colleague letter and subsequent updates describe issues with enrollment functionality, which affected enrollment reporting. King conducted a review on a sample of students and found that students were reported correctly to the Clearinghouse but were not appearing in NSLDS. A more frequent enrollment schedule should remedy this issue. We also attribute these delays to changes in leadership/staffing during that timeframe. The enrollment reporting steps were outlined by the prior Registrar when this process transitioned to the Office of Institutional Research, but this staffing transition could have resulted in inaccurate data being captured and reported during a window of time in Fall 2021 (when the reporting responsibility transitioned). Additionally, it was discovered that incorrect coding in the CAMS database management system (DBMS) was causing exclusions based on a missing field. These exclusions began in Summer 2021 due to added majors that were not correctly created.
2022-004 Significant Deficiency: Awarding Eligibility (Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 690.62, the amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year, factoring in student enrollment status, cost of attendance, and expected family contribution. Statement of Condition: During the 2022 audit, it was noted that students were disbursed the incorrect amount of Federal Pell based upon enrollment states, cost of attendance, and expected family contribution. Questioned Costs: This finding is monetary in nature. In the instances noted in testing, the total error identified is $1,142 in over-award. In extrapolating the error across the population of students who received Pell awards, potential error amounts to $43,262. Perspective Information: The 2022 audit included a detailed testing of 40 student files, of which this significant deficiency applies to 3, indicating an error rate of 7.50%. Cause and Effect: The University did not accurately account for the factors necessary in the calculation of Pell Grant awards, so multiple students were awarded and retained Pell Grant awards that were beyond eligibility. Recommendation: The University should utilize the appropriate information to ensure that to accurately award and disburse Pell Grant funds to students in line with the guidance provided by the Department. View of Responsible Officials: We concur. There were instances where King failed to calculate/disburse Federal Pell Grant funds appropriately based on their updated Enrollment Status/EFC. We found that the Pell distribution fund was locked, which prevented the Pell recalculation when the higher ISIR transaction was loaded. In addition, there was not a report in place to alert the Financial Aid office of students enrolled in both traditional and modular courses. As a result, those students were not being identified/monitored effectively for enrollment changes.
2022-001 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, once the Enrollment Reporting roster file is received from the NSLDS, the institution must update the Enrollment Reporting roster file for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes to NSLDS. Statement of Condition: During the 2022 audit, it was noted that the University incorrectly reported student enrollment status at changes in enrollment or did not report an updated status whatsoever. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The 2022 audit included a detailed testing of 40 student files, of which this significant deficiency applies to 18, indicating an error rate of 45.00%. Cause and Effect: Due to lapses in communication between departments, in certain instances, the University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct withdrawal status is reported to NSLDS. View of Responsible Officials: King University uses the National Student Clearinghouse to report enrollment changes to NSLDS. We believe a portion of the untimely reporting to NSLDS is a result of the reporting delays between the National Student Clearinghouse and NSLDS, as documented in GENERAL-22-64 beginning July 25, 2022. The Dear Colleague letter and subsequent updates describe issues with enrollment functionality, which affected enrollment reporting. King conducted a review on a sample of students and found that students were reported correctly to the Clearinghouse but were not appearing in NSLDS. A more frequent enrollment schedule should remedy this issue. We also attribute these delays to changes in leadership/staffing during that timeframe. The enrollment reporting steps were outlined by the prior Registrar when this process transitioned to the Office of Institutional Research, but this staffing transition could have resulted in inaccurate data being captured and reported during a window of time in Fall 2021 (when the reporting responsibility transitioned). Additionally, it was discovered that incorrect coding in the CAMS database management system (DBMS) was causing exclusions based on a missing field. These exclusions began in Summer 2021 due to added majors that were not correctly created.
2022-002 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, 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 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. Statement of Condition: During the 2022 audit, it was noted that the University did not supply status updates to NSLDS in a timely manner, within the 60-day window. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The 2022 audit included a detailed testing of 40 student files, of which this significant deficiency applies to 4, indicating an error rate of 10.00%. Cause and Effect: Due to lapses in communication between departments, in certain instances, the University provided NSLDS with updates to student enrollment statuses outside of a timeframe that is considered to be reasonably appropriate, resulting in delayed representation within the NSLDS system. Recommendation: The University should ensure that any updates to enrollment status be reported to NSLDS within 60 days of the effective date of change. View of Responsible Officials: King University uses the National Student Clearinghouse to report enrollment changes to NSLDS. We believe a portion of the untimely reporting to NSLDS is a result of the reporting delays between the National Student Clearinghouse and NSLDS, as documented in GENERAL-22-64 beginning July 25, 2022. The Dear Colleague letter and subsequent updates describe issues with enrollment functionality, which affected enrollment reporting. King conducted a review on a sample of students and found that students were reported correctly to the Clearinghouse but were not appearing in NSLDS. A more frequent enrollment schedule should remedy this issue. We also attribute these delays to changes in leadership/staffing during that timeframe. The enrollment reporting steps were outlined by the prior Registrar when this process transitioned to the Office of Institutional Research, but this staffing transition could have resulted in inaccurate data being captured and reported during a window of time in Fall 2021 (when the reporting responsibility transitioned). Additionally, it was discovered that incorrect coding in the CAMS database management system (DBMS) was causing exclusions based on a missing field. These exclusions began in Summer 2021 due to added majors that were not correctly created.
2022-003 Significant Deficiency: Exit Counseling (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Criteria: In accordance with 34 CFR 682.604(a)(1), a school must ensure that exit counseling is conducted with each borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is provided or conducted within 30 days after learning that the student borrower has withdrawn from school or dropped below half-time enrollment. Statement of Condition: During the 2022 audit, it was noted that certain students who had dropped below half-time enrollment or who had left the University were not provided with exit counseling in relation to outstanding federal direct loan balances. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The 2022 audit included a detailed testing of 40 student files, of which this significant deficiency applies to 7, indicating an error rate of 17.50%. Cause and Effect: Due to a process failure within the Student Financial Aid department, the University did not provide students with the required exit counseling materials related to federal direct loans, resulting in the potential that students may have been under-informed or had false expectations about their liabilities. Recommendation: The University should verify that appropriate communication is made to students leaving the University or lowering enrollment to less than half time, who also have outstanding federal direct loans balances, to provide each with the exit counseling resource. View of Responsible Officials: We now have established clear policies and procedures to correct this finding. As part of the withdrawal process, the financial aid counselors will send exit letters within the required timeframe upon receiving notification from the Office of Registration and Records that a student has withdrawn from the University. The counselors will also utilize the Daily Load Report and a series of selection sets to identify students who have dropped below halftime enrollment, and will send the exit letters as required by federal regulations. The Financial Aid Office has reviewed all students who have withdrawn or dropped below halftime enrollment status in the 2022-23 award year to ensure that exit letters were sent.
2022-001 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, once the Enrollment Reporting roster file is received from the NSLDS, the institution must update the Enrollment Reporting roster file for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes to NSLDS. Statement of Condition: During the 2022 audit, it was noted that the University incorrectly reported student enrollment status at changes in enrollment or did not report an updated status whatsoever. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The 2022 audit included a detailed testing of 40 student files, of which this significant deficiency applies to 18, indicating an error rate of 45.00%. Cause and Effect: Due to lapses in communication between departments, in certain instances, the University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct withdrawal status is reported to NSLDS. View of Responsible Officials: King University uses the National Student Clearinghouse to report enrollment changes to NSLDS. We believe a portion of the untimely reporting to NSLDS is a result of the reporting delays between the National Student Clearinghouse and NSLDS, as documented in GENERAL-22-64 beginning July 25, 2022. The Dear Colleague letter and subsequent updates describe issues with enrollment functionality, which affected enrollment reporting. King conducted a review on a sample of students and found that students were reported correctly to the Clearinghouse but were not appearing in NSLDS. A more frequent enrollment schedule should remedy this issue. We also attribute these delays to changes in leadership/staffing during that timeframe. The enrollment reporting steps were outlined by the prior Registrar when this process transitioned to the Office of Institutional Research, but this staffing transition could have resulted in inaccurate data being captured and reported during a window of time in Fall 2021 (when the reporting responsibility transitioned). Additionally, it was discovered that incorrect coding in the CAMS database management system (DBMS) was causing exclusions based on a missing field. These exclusions began in Summer 2021 due to added majors that were not correctly created.
2022-002 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, 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 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. Statement of Condition: During the 2022 audit, it was noted that the University did not supply status updates to NSLDS in a timely manner, within the 60-day window. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The 2022 audit included a detailed testing of 40 student files, of which this significant deficiency applies to 4, indicating an error rate of 10.00%. Cause and Effect: Due to lapses in communication between departments, in certain instances, the University provided NSLDS with updates to student enrollment statuses outside of a timeframe that is considered to be reasonably appropriate, resulting in delayed representation within the NSLDS system. Recommendation: The University should ensure that any updates to enrollment status be reported to NSLDS within 60 days of the effective date of change. View of Responsible Officials: King University uses the National Student Clearinghouse to report enrollment changes to NSLDS. We believe a portion of the untimely reporting to NSLDS is a result of the reporting delays between the National Student Clearinghouse and NSLDS, as documented in GENERAL-22-64 beginning July 25, 2022. The Dear Colleague letter and subsequent updates describe issues with enrollment functionality, which affected enrollment reporting. King conducted a review on a sample of students and found that students were reported correctly to the Clearinghouse but were not appearing in NSLDS. A more frequent enrollment schedule should remedy this issue. We also attribute these delays to changes in leadership/staffing during that timeframe. The enrollment reporting steps were outlined by the prior Registrar when this process transitioned to the Office of Institutional Research, but this staffing transition could have resulted in inaccurate data being captured and reported during a window of time in Fall 2021 (when the reporting responsibility transitioned). Additionally, it was discovered that incorrect coding in the CAMS database management system (DBMS) was causing exclusions based on a missing field. These exclusions began in Summer 2021 due to added majors that were not correctly created.
2022-004 Significant Deficiency: Awarding Eligibility (Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 690.62, the amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year, factoring in student enrollment status, cost of attendance, and expected family contribution. Statement of Condition: During the 2022 audit, it was noted that students were disbursed the incorrect amount of Federal Pell based upon enrollment states, cost of attendance, and expected family contribution. Questioned Costs: This finding is monetary in nature. In the instances noted in testing, the total error identified is $1,142 in over-award. In extrapolating the error across the population of students who received Pell awards, potential error amounts to $43,262. Perspective Information: The 2022 audit included a detailed testing of 40 student files, of which this significant deficiency applies to 3, indicating an error rate of 7.50%. Cause and Effect: The University did not accurately account for the factors necessary in the calculation of Pell Grant awards, so multiple students were awarded and retained Pell Grant awards that were beyond eligibility. Recommendation: The University should utilize the appropriate information to ensure that to accurately award and disburse Pell Grant funds to students in line with the guidance provided by the Department. View of Responsible Officials: We concur. There were instances where King failed to calculate/disburse Federal Pell Grant funds appropriately based on their updated Enrollment Status/EFC. We found that the Pell distribution fund was locked, which prevented the Pell recalculation when the higher ISIR transaction was loaded. In addition, there was not a report in place to alert the Financial Aid office of students enrolled in both traditional and modular courses. As a result, those students were not being identified/monitored effectively for enrollment changes.
2022-001 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, once the Enrollment Reporting roster file is received from the NSLDS, the institution must update the Enrollment Reporting roster file for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes to NSLDS. Statement of Condition: During the 2022 audit, it was noted that the University incorrectly reported student enrollment status at changes in enrollment or did not report an updated status whatsoever. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The 2022 audit included a detailed testing of 40 student files, of which this significant deficiency applies to 18, indicating an error rate of 45.00%. Cause and Effect: Due to lapses in communication between departments, in certain instances, the University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct withdrawal status is reported to NSLDS. View of Responsible Officials: King University uses the National Student Clearinghouse to report enrollment changes to NSLDS. We believe a portion of the untimely reporting to NSLDS is a result of the reporting delays between the National Student Clearinghouse and NSLDS, as documented in GENERAL-22-64 beginning July 25, 2022. The Dear Colleague letter and subsequent updates describe issues with enrollment functionality, which affected enrollment reporting. King conducted a review on a sample of students and found that students were reported correctly to the Clearinghouse but were not appearing in NSLDS. A more frequent enrollment schedule should remedy this issue. We also attribute these delays to changes in leadership/staffing during that timeframe. The enrollment reporting steps were outlined by the prior Registrar when this process transitioned to the Office of Institutional Research, but this staffing transition could have resulted in inaccurate data being captured and reported during a window of time in Fall 2021 (when the reporting responsibility transitioned). Additionally, it was discovered that incorrect coding in the CAMS database management system (DBMS) was causing exclusions based on a missing field. These exclusions began in Summer 2021 due to added majors that were not correctly created.
2022-002 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, 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 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. Statement of Condition: During the 2022 audit, it was noted that the University did not supply status updates to NSLDS in a timely manner, within the 60-day window. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The 2022 audit included a detailed testing of 40 student files, of which this significant deficiency applies to 4, indicating an error rate of 10.00%. Cause and Effect: Due to lapses in communication between departments, in certain instances, the University provided NSLDS with updates to student enrollment statuses outside of a timeframe that is considered to be reasonably appropriate, resulting in delayed representation within the NSLDS system. Recommendation: The University should ensure that any updates to enrollment status be reported to NSLDS within 60 days of the effective date of change. View of Responsible Officials: King University uses the National Student Clearinghouse to report enrollment changes to NSLDS. We believe a portion of the untimely reporting to NSLDS is a result of the reporting delays between the National Student Clearinghouse and NSLDS, as documented in GENERAL-22-64 beginning July 25, 2022. The Dear Colleague letter and subsequent updates describe issues with enrollment functionality, which affected enrollment reporting. King conducted a review on a sample of students and found that students were reported correctly to the Clearinghouse but were not appearing in NSLDS. A more frequent enrollment schedule should remedy this issue. We also attribute these delays to changes in leadership/staffing during that timeframe. The enrollment reporting steps were outlined by the prior Registrar when this process transitioned to the Office of Institutional Research, but this staffing transition could have resulted in inaccurate data being captured and reported during a window of time in Fall 2021 (when the reporting responsibility transitioned). Additionally, it was discovered that incorrect coding in the CAMS database management system (DBMS) was causing exclusions based on a missing field. These exclusions began in Summer 2021 due to added majors that were not correctly created.
2022-003 Significant Deficiency: Exit Counseling (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Criteria: In accordance with 34 CFR 682.604(a)(1), a school must ensure that exit counseling is conducted with each borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is provided or conducted within 30 days after learning that the student borrower has withdrawn from school or dropped below half-time enrollment. Statement of Condition: During the 2022 audit, it was noted that certain students who had dropped below half-time enrollment or who had left the University were not provided with exit counseling in relation to outstanding federal direct loan balances. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The 2022 audit included a detailed testing of 40 student files, of which this significant deficiency applies to 7, indicating an error rate of 17.50%. Cause and Effect: Due to a process failure within the Student Financial Aid department, the University did not provide students with the required exit counseling materials related to federal direct loans, resulting in the potential that students may have been under-informed or had false expectations about their liabilities. Recommendation: The University should verify that appropriate communication is made to students leaving the University or lowering enrollment to less than half time, who also have outstanding federal direct loans balances, to provide each with the exit counseling resource. View of Responsible Officials: We now have established clear policies and procedures to correct this finding. As part of the withdrawal process, the financial aid counselors will send exit letters within the required timeframe upon receiving notification from the Office of Registration and Records that a student has withdrawn from the University. The counselors will also utilize the Daily Load Report and a series of selection sets to identify students who have dropped below halftime enrollment, and will send the exit letters as required by federal regulations. The Financial Aid Office has reviewed all students who have withdrawn or dropped below halftime enrollment status in the 2022-23 award year to ensure that exit letters were sent.