Recommendation: We recommend the University establish and implement a contingency process to ensure enrollment reporting continues during system access disruptions. This process should include monitoring NSC access status and developing alternative procedures to prevent reporting gaps, ensuring that...
Recommendation: We recommend the University establish and implement a contingency process to ensure enrollment reporting continues during system access disruptions. This process should include monitoring NSC access status and developing alternative procedures to prevent reporting gaps, ensuring that all student statuses are submitted accurately and within the required 60-day timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: National University agrees with the importance of ensuring accurate and timely enrollment reporting to NSLDS. The University has taken significant steps to improve its internal controls and compliance with enrollment reporting requirements. The University has identified a few items that have resulted in challenges to accurate and timely enrollment reporting during the audit year. National Student Clearing House (NSC) reporting: On October 18, 2024, the institution was notified by NSC that its access to process enrollment reporting on behalf of NU was revoked during July 2024, resulting in a reporting gap. The University took immediate action to restore access to NSC. Access issues were fully resolved on October 23, 2024. Additionally, NU revised its policies and implemented an internal control plan that monitors NSC activity allowing for proactive identification of future service interruptions. All 33 enrollment certification errors occurred during the disconnect noted above. The University believes its current enrollment certification processes are timely, accurate, and compliant. Timing of implemented enrollment reporting changes: During the audit period National University implemented several improvements to refine and enhance the timeliness of its enrollment reporting. NU established stronger alignment across both OPEIDs and adjusted its timelines to ensure consistent and timely submissions. As part of this effort, the University restructured its reporting schedule, so that finalized enrollment report is submitted by the 6th of each month, supporting a successful and expedited monthly transfer from NSC to NSLDS. Since implementing these revised timelines and deadlines, the University has observed significant improvements and consistency in its internal QA audit scores during the audit period (since January 2025). Four of the five late reporting instances occurred before the implementation date of the University’s enrollment reporting changes. The University believes its refined and enhanced process changes demonstrate its commitment to timely, accurate, and compliant enrollment certification processes. One of the five late reporting instances occurred after the implementation date, and that was related to the student’s status change from active, to pending graduate, to graduate, and then withdrawn. The University will evaluate its process for reporting student status changes from pending graduate, graduate, and withdrawal to ensure clear definitions and status flows are in place. The University will create and deliver focused training in this area to stress the importance of accurate enrollment reporting. In addition to the above, the University will continue to take the following steps: • Continued monitoring and refining of processes to maintain timely and accurate reporting. Including, but not limited to its monthly testing of enrollment reporting accuracy to NSLDS conducted by the quality assurance team. • Identification and timely delivery of training for areas of opportunity identified in the monthly reviews to the registrar and data operations teams. • Revise the internal changes and documentation processes to ensure clarity of policy and regulatory guidance in areas of identified risk/confusion during enrollment reporting processing. Name(s) of the contact person(s) responsible for corrective action: - Rob Conlon, AVP Financial Aid Compliance - Sarah Massey, AVP of Operations Student Support and Registrar Operations - Gabrielle Witruke, Associate Director Data Analytics Planned completion date for corrective action plan: November 2025