FY 2022 SFA Audit Corrective Action Plan Audit Firm: RSM US LLP 30 S Wacker Drive, Suite 3300 Chicago, IL 60606 Audit Period: 1/1/2022 ? 12/31/2022 Comments on Findings and Recommendations: Finding 2022-001 ? Error in Reporting for NSLDS Finding: Herzing University did not properly report the studen...
FY 2022 SFA Audit Corrective Action Plan Audit Firm: RSM US LLP 30 S Wacker Drive, Suite 3300 Chicago, IL 60606 Audit Period: 1/1/2022 ? 12/31/2022 Comments on Findings and Recommendations: Finding 2022-001 ? Error in Reporting for NSLDS Finding: Herzing University did not properly report the student enrollment change for a student who received federal student aid to the National Student Loan Data System (NSLDS). Condition: The University did not report a student?s Program-Level or Campus-Level enrollment status change to NSLDS. Out of the 60 students tested, we noted 1 student (1.7%) whose status change at the Program-Level and Campus-Level was not reported to NSLDS. Action Taken: In this instance, the student identified was withdrawn from the University and was correctly reported to NSLDS as such through our standard enrollment reporting processes. The student then subsequently re-enrolled at the University in the subsequent academic period becoming an Active student, and then withdrew again prior to our next standard enrollment reporting process occurring (one month after the previously reported withdrawn status). At the point of the second standard enrollment reporting timeframe, the student status was once again withdrawn, therefore an update did not occur to their enrollment status. Our process did not have a mechanism to identify the student changing statuses in between those reporting periods so that the active enrollment status was reported and then changed back to withdrawn versus simply staying at a withdrawn status. In August 2022, Herzing University updated our enrollment reporting policy to send in enrollment reporting biweekly instead of monthly. This was done to ensure that each student?s enrollment status was accurately reported as soon as possible and to prevent issues that occur from delays in proper enrollment statuses being reported to NSLDS. This update inherently decreased the likelihood that status timing issues would occur given the condensed timeframe for reporting. In addition, as of May 1st, 2023 Herzing University has developed and implemented an exception reporting process that will identify any student that has status updates that occur but reverts back to the original status within the timeframe of the two enrollment reporting periods. Using the student identified in this finding as an example, if the student is at a withdrawn status at the first enrollment reporting period, then moves to an active status immediately after that but then withdraws again within that 2 week window and therefore goes back to a withdrawn status in the subsequent enrollment reporting period, while our standard reporting would still show the student withdrawn for both standard enrollment reporting timeframes, the exception report will flag that student for review since a status change occurred in between the two withdrawn statuses being reported out. Upon review of the exception report, all relevant status progressions will be correctly reported to NSLDS. The required corrective action for Finding 2022-001 listed in the SFA audit for the period 1/1/2022 ? 12/31/2022 was completed on 5/1/2023. The person responsible for completion of the corrective action was Kevin McShane, Vice President of Financial Aid & Compliance.