Claremont Graduate University Corrective Action Plan For the Fiscal Year Ended June 30, 2025 U.S. Department of Education FINDING 2025-001 – Special Tests and Provisions-Enrollment Reporting: Significant Deficiency in Internal Control over Compliance Condition – During the audit fieldwork, a sample ...
Claremont Graduate University Corrective Action Plan For the Fiscal Year Ended June 30, 2025 U.S. Department of Education FINDING 2025-001 – Special Tests and Provisions-Enrollment Reporting: Significant Deficiency in Internal Control over Compliance Condition – During the audit fieldwork, a sample of 20 federal aid recipient students were selected by auditors from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2024-2025 academic year. The enrollment information and withdrawal, address change, or graduation date per the University’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Of the 20 students who had a change in address, graduated, or withdrew, there were four student files with errors. There was one student file that had incorrect enrollment status reported and not reported within the required timeframe. A second student file was reported under the incorrect enrollment status but within the appropriate time requirement. Lastly, two additional student files were not reported within the required timeframe. Explanation of Deficiency On June 20, 2025, the Degree Verify transmission to the National Student Clearinghouse (NSC) failed. Additionally, an error was identified that caused all international student records to be rejected. In order to correct the omission of international students, the monthly transmission was temporarily stopped until the issue could be resolved. This process took longer than anticipated. While degree records were being manually updated in NSC, staff were not aware that the enrollment records also needed to be separately updated. The Degree Verify file had been configured with a flag that should have automatically updated enrollment records upon submission, but this was not recognized at the time. As a result, a sample of student files reviewed contained reporting errors related to incorrect enrollment statuses or reporting delays. These issues would have been avoided if regularly scheduled reports had been submitted to NSC without interruption. Corrective Action Plan To address these deficiencies and prevent recurrence, the following corrective measures have been implemented: 1. Resumption of Scheduled Transmissions – The Office of Information Technology has corrected the Degree Verify file rejection issue. Monthly transmissions of Degree Verify reports will resume beginning September 20, 2025. 2. Enhanced Enrollment Reporting Schedule – Enrollment reporting has been rescheduled to occur every three weeks throughout each term, ensuring that enrollment status changes are reported to NSC and NSLDS within required timeframes. 3. Manual Record Reconciliation – A comprehensive review of late degree conferrals has been completed. All enrollment records have been manually updated in NSC to align with the corresponding degree records. 4. Staff Training and Awareness – The Registrar’s Office staff have been trained on the functional differences between degree reporting and enrollment reporting. Emphasis was placed on the need to verify that enrollment records are updated when degree records are manually corrected. 5. Monitoring and Quality Control – A reconciliation process has been established between the Registrar’s Office and OIT to confirm the successful transmission and acceptance of NSC files. Reports of any rejected records will be reviewed within five business days and promptly corrected. Contact Person Responsible: Vannessa Alvarado, Registrar 909-621-8285 Anticipated/Projected Completion Date: Manual corrections completed on September 3, 2025. Automated processes to projected September 20, 2025.