Finding Text
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our testing, we noted that the enrollment effective date of 1 of the 60 students tested was not reported correctly to NSLDS. Additionally, we did not note evidence of a key control occurring for enrollment reporting.
Questioned costs: None reported.
Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment effective date of 1 of the 60 students tested. Additionally, the University was unable to provide evidence of a control having occurred.
Cause: The University did not manually report the retroactive withdrawal date for one selection. NSC would not allow for the backdate prior to the last date of the term as the term had already concluded. Additionally, no evidence was available for a key control for the enrollment reporting process.
Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding: Yes, 2023-002.
Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely, and to store evidence of the key control having occurred.
View of Responsible Official: The University agrees with the finding.