Subject: Corrective Action Plan for Federal Direct Student Loans Program Compliance The University of the Pacific acknowledges the findings outlined in the audit related to the reporting of student enrollment status to the National Student Loan Data System (NSLDS) for the Federal Direct Student Loan...
Subject: Corrective Action Plan for Federal Direct Student Loans Program Compliance The University of the Pacific acknowledges the findings outlined in the audit related to the reporting of student enrollment status to the National Student Loan Data System (NSLDS) for the Federal Direct Student Loans Program (Federal Assistance Listing Number: 84.268) for the award year July 1, 2024 – June 30, 2025. The audit identified a system-level transmittal configuration issue in which campus-level enrollment updates inadvertently overrode certain program-level enrollment status fields within NSLDS reporting. We take our responsibility to comply with the federal regulations under 34 CFR Section 685.309 very seriously and are committed to strengthening our internal controls and system governance processes to ensure accurate, complete, and timely reporting of enrollment changes at both the campus and program levels. Corrective Action Plan: To address the identified deficiency, Finding# 2025-001, related to program-level enrollment status reporting and to strengthen preventive controls over NSLDS submissions, the University has implemented the following measures, effective immediately (February 19, 2026): 1. Root Cause Isolation and System Logic Review: The University identified that a specific NSLDS transmittal file configuration resulted in campuslevel enrollment updates overriding program-level enrollment status fields. In collaboration with Information Technology, the Registrar’s Office has isolated the reporting logic and corrected the configuration to prevent program-level status fields from being overwritten by subsequent campus-level submissions. Documentation of the revised logic has been retained for audit purposes. 2. Full Population Review and Remediation: The University will conduct a comprehensive review of NSLDS records for the affected student population to confirm accuracy of program-level enrollment status. Where discrepancies are identified, corrected submissions will be transmitted promptly to NSLDS. Documentation of the review and any corrections will be maintained to ensure a complete audit trail. 3. Segregation of Campus-Level and Program-Level Reporting Logic: Enrollment reporting procedures have been updated to formally distinguish campus-level and program-level reporting workflows. Any future modifications to enrollment reporting logic will require documented change management review, regression testing, and joint approval from the Registrar’s Office and Information Technology prior to implementation. 4. Targeted Program-Level Monitoring Dashboard: In addition to existing monthly NSC and NSLDS reconciliations, the Registrar’s Office will implement a targeted monthly exception report specifically monitoring program-level enrollment status changes. This report will identify discrepancies between SIS records and transmitted data, including concurrent program records and recent status changes, to ensure ongoing data integrity. 5. Quarterly Compliance Sampling and Oversight: On a quarterly basis, an independent staff member not involved in file preparation will conduct a sampling review of transmitted NSLDS records to verify program-level status accuracy. Results will be documented and reviewed by the Registrar to ensure sustained compliance. 6. SOP Enhancement and Staff Training: The University has updated its Enrollment Reporting Standard Operating Procedures to incorporate explicit review steps for program-level data validation and transmission oversight. Targeted training has been provided to staff responsible for enrollment reporting to reinforce compliance expectations and system configuration awareness. The University remains committed to ensuring accurate and timely reporting of student enrollment data in full compliance with federal regulations. These enhanced preventive and governance controls build upon prior corrective actions and further strengthen the integrity of our Title IV reporting framework. Anticipated Completion Date: 6/30/26 Person Responsible: Michael Snyder, Associate University Registrar