Finding Text
FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Material Weakness in
Internal Control over Compliance (See Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): Unless it 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/context – A sample of 60 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per NU’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 60 students who had a change in address, graduated, or withdrew, 28 were not reported to the NSLDS within the required timeframe. Of the 60 students, 11 had an incorrect effective date reported to the NSLDS. Cause – NU does not have an effective process to review NSLDS submissions, performed by NU’s third-party administrator, for accuracy and completeness on a periodic basis. Several of the late submissions identified above were a result the unexpected termination of NU’s agreement with its third-party administrator in approximately July 2024 that prevented NSLDS submissions NU wide during the months of August 2024 and November 2024.
Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans.
Repeat finding – This is a repeat finding. See 2023-002. Recommendation – We recommend NU evaluate its current process to ensure consistent and accurate criteria are used when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend NU evaluate its current process to ensure NSLDS is reviewed for accuracy and completeness over its students on a regular basis in order to ensure compliance and meet reporting deadlines.