Finding Text
FINDING 2024-001 – Special Tests and Provisions – Enrollment Reporting
Significant Deficiency in Internal Control over Compliance
Student Financial Assistance Cluster
U.S. Department of Education
Assistance Listing Number: 84.268
Federal Program Name: Student Financial Assistance Cluster
Award Year: 2023-24
Criteria: Direct Loan, Section 34 CFR Section 685.309(b) (2) Unless the institution expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address.
Condition and Context: A sample of 46 students who had address changes during the year were selected for our testing procedures. Our sample was selected using a random and judgmental sampling methodology, from a population of 935 total address changes. We noted that the process for reporting address changes did not take place regularly during the year. We noted that of 46 students sampled and tested, eight students did not have their address changes reported to NSLDS. Upon further investigation, we determined that internal controls were not in place and operating effectively to timely report address changes during the year. We did not expand our sample.
Questioned Costs: None
Effect: The University did not regularly report address changes to the National Student Loan Data System (NSLDS). As such, the address changes were not reported timely. This information is utilized by the U.S. Department of Education, the Federal Direct Loan program, lenders, and other institutions.
Cause: This occurred because the process in place was not designed effectively to timely report address changes to NSLDS.
Repeat Finding: No
Recommendation: We recommend the University implement a process to ensure address changes for all terms are timely reported to NSLDS.
Views of Responsible Officials and Planned Corrective Actions: Upon review of our process, we noted that the data we provided was not limited to Home/Permanent address changes. As a result, the selections did not demonstrate our timely reporting. Based upon the definition provided of Section 34 CFR Section 685.309(b) (2), it is our understanding that
we are required to report address changes only on enrolled students through the period where they are marked as either (W) Withdrawn or (G) Graduated status. Our policy is to report students’ most current home address with each enrollment submission a minimum of 14 dates per year (three of which are only for graduated students) which ensures compliance with the 60-day threshold. However, our current practices have not always ensured that the current main home address was the one supplied to the
National Student Clearinghouse. We will immediately implement processes to ensure that the main home address is the one sent to the National Student Clearinghouse. We consider this to be remediated.