Finding 2025-001 - Special Tests and Provisions - Enrollment Reporting (Noncompliance and Significant Deficiency) Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 840007, 84.033, 84.038, 84.063, and 84.268. Criteria - Institutions are required to report...
Finding 2025-001 - Special Tests and Provisions - Enrollment Reporting (Noncompliance and Significant Deficiency) Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 840007, 84.033, 84.038, 84.063, and 84.268. Criteria - Institutions are required to report enrollment information under the PELL grant and the Direct loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs depends heavily on the accurace and timeliness of the enrollment statuses, program information, and effective dates reported to NDLDS. Institutions are responsible for accurate reporting. According to 34 CFR 685.309(2), the University is required to notifly the Department of Education via the NDLDS if a "student has ceased to be enrolled on at least half-time basis for the period for which the loan was intended". Changes to status are required to be reported within 30 days of becoming aware of the status changing, or with the next schedule transmission of statuses if the scheduled transmission is within 60 days. Condition - A sample of 40 student were selected from the population of all students wo Identification of the Federal Program - Student Financial Aid Cluster - Assistance Listing Nos. 84.007, 84.033, 84.038, 84.063, and 84.268. Criteria - Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the National Student Loan Data System (NSLDS). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates reported to NSLDS. Institutions are responsible for accurate reporting. According to 34 CFR 685.309(2), the University is required to notify the Department of Education via the NSLDS if a “student has ceased to be enrolled on at least a half-time basis for the period for which the loan was intended”. Changes to status are required to be reported within 30 days of becoming aware of the status change, or with the next schedule transmission of statuses if the scheduled transmission is within 60 days. Condition - A sample of 40 students were selected from the population of all students who received federal student financial aid during the year ended May 31, 2025. We obtained the student records and tested compliance with federal regulations for the specific loans and grants. For 5 out of the 40 students selected for Enrollment Reporting testing, the status change was not reported within the 60-day reporting window after the status change was effective. For 9 out of the 40 students selected for Enrollment Reporting testing, the status change was not reported to NSLDS. For 9 out of the 40 students selected for Enrollment Reporting testing, the status change effective date was not accurately reported to NSLDS. For 2 out of the 40 students selected for Enrollment Reporting testing, the status of the student was not accurately reported to NSLDS. ause - The University’s processes of internal controls for reporting student status changes to NSLDS were not adequate. Effect - Student status changes were not reported to NSLDS within the required timeframe. Identification of Repeat Finding - Repeat finding of prior year finding 2024-001. Recommendation - We recommend the University revise its processes for reporting status changes to NSLDS. The University should implement a process to review, update, and verify enrollment statuses that appear on the Enrollment Reporting roster files. We also recommend that management implement controls to ensure reported changes are timely and correctly reported to the NSLDS. Views of Responsible Officials - Management agrees with the finding. Out of the 25 exceptions included in this finding, 8 were properly and timely reported by the University to the third-party service provider. The University has continued to work with its third-party service provider to identify the root cause of the reporting issues. The primary cause stems from varied start dates of academic modules (5-week, 8-week, and 16-week) within a semester. These overlapping start dates often cross the monthly NSLDS upload periods. As students adjust their schedules, changes in the current Student Information System (SIS) may inadvertently override previously reported data. The University’s current SIS has reached the end of its useful life and was not designed to handle the modular academic formats now essential for serving modern student needs. Additionally, the SIS lacks functionality to directly export enrollment data to the third-party service provider resulting in manual intervention and the aggregation of multiple files for upload. This manual process increases the risk for reporting errors. Corrective Action Plan for Finding 2025-001 – In May 2025, the University executed a contract to implement a new and modern Student Information System. This multi-year implementation project is expected to be completed by Fall 2029, with a possibility of early completion by Fall 2028. During the interim period, the University will continue to emphasize data validation and accuracy through staff training and monitoring. To further support the reporting process, the University engaged a former employee on a contractual basis during the fiscal year ended May 31, 2025. This individual brings extensive experience in enrollment reporting to both the National Student Clearinghouse (NSC) and the National Student Loan Data System (NSLDS), providing valuable expertise during this transitional phase.