Identifying Number: 2024-002
Finding:
Federal Program: U.S. Department of Education - Student Financial Aid Cluster: Federal Direct Loan Program, 84.268
Criteria: The University is required to comply with 36 CFR Section 685.309(b).
Condition: During our testing of unofficial withdrawals and stu...
Identifying Number: 2024-002
Finding:
Federal Program: U.S. Department of Education - Student Financial Aid Cluster: Federal Direct Loan Program, 84.268
Criteria: The University is required to comply with 36 CFR Section 685.309(b).
Condition: During our testing of unofficial withdrawals and student status changes for graduates, we selected four and 22 samples, respectively, and we noted one instance in each testing section where a student’s status change was not timely reported to the National Student Loan Database System (NSLDS).
Cause: The University did not have controls in place to ensure students' classification were being properly reported to the NSLDS.
Effect: Student status changes were not reported within the required timeframe under federal regulations. The provisions of 34 CFR Section 685.309(b) were not followed and thus two students were not reported timely and subsequently not placed into loan repayment status in a timely manner.
Questioned Costs: There were no questioned costs associated with this finding.
Recommendation: We recommend that the University implement a control to ensure data is being reviewed for accuracy by the appropriate personnel before roster files are submitted to the NSLDS. In addition, we recommend that the University submit roster files on a regular basis.
Corrective Actions Taken or Planned: Regarding the status change for the identified graduate, management implemented a new process for reporting student enrollments. The Office of Institutional Research reviews the specifications for reporting from the National Student Clearinghouse (NSC) and National Student Loan Data System (NSLDS) to ensure that the proper data is being reported. Reports are generated by Institutional Research and upon approval of the Registrar submitted to the NSC. Any errors are remediated by the Registrar. And the Financial Aid Office verifies that reports sent to the National Student Clearinghouse are accurately reported to the National Student Loan Data System, by auditing both systems with assistance from the Office of institutional Research and Office of the Registrar. This process was implemented in February 2023. However, the timing of that fix occurred after the student in question had already graduated, meaning they were not included in the corrective measures.
For the Return of Title IV (R2T4) calculation process, management has updated our procedures to ensure that student enrollment status is promptly updated when an R2T4 is completed. Specifically, a required step was added in the R2T4 process where a designated box is checked in the system, flagging the student’s account for withdrawal status reporting. This change helps ensure timely and accurate reporting of enrollment status to NSLDS.
Completion Date: October 1, 2024
Responsible Official: Robert Giesting, Executive Director of Institutional Assessment and Learning