Finding 1123382 (2024-001)

Criteria or Specific Requirement Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). Although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). 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 certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Condition Found Of the 40 students selected for enrollment reporting testing, 3 students who had graduated from the University did not have the proper Graduation (G) status submitted to the NSLDS. This finding was identified in the prior year and management implemented a process as part of their corrective action plan from the fiscal year 2023 audit to remediate this condition. This implementation was completed in May 2024. All three students identified above were included in the period prior to the implementation. No conditions were found subsequent to May 2024. Cause and Possible Asserted Effect The University transmits student status changes to the National Student Clearinghouse (NSC) who then transmits the changes to the NSLDS. The University was submitting the status changes to the NSC, but these changes were sent back to the University on a Graduation Not Reported listing by the NSLDS. The University did not follow-up on these returned items in a timely manner. Questioned Costs None. Whether the Sample Was a Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding Was a Repeat Finding in the Immediately Prior Audit Yes, finding 2023-002. Recommendation We recommend the University continue to monitor its controls surrounding the review of student status changes that were not reported or were returned to ensure enrollment reporting requirements are accurately completed in a timely manner. View of Responsible Officials As noted, the three records identified in the fiscal year 2024 audit preceded full implementation of the fiscal year 2023 audit corrective action plan. The University continues to prioritize enhancement of its internal controls, including tighter procedures to ensure timely and accurate reporting. Additionally, not only has the Registrar’s Office instituted periodic internal reviews to ensure that the enrollment and graduation reporting process meet required standards, a duplicative review process for Worldwide enrollment and graduation report submissions has been operationalized.