Finding 1127833 (2024-004)

Current Year Finding: Number 2024 004 Federal Programs: Student Financial Assistance Cluster • Federal Direct Student Loans (ALN 84.268) • Federal Pell Grant Program (ALN 84.063) Federal Award #’s: P268K240395 and P063P230395 Federal Award Years: July 1, 2023 to June 30, 2024 Federal Agencies: U.S. Department of Education Pass Through Entity: None Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Criteria: Under the Pell grant and the Direct and Federal Family Education Loan programs, institutions are required to report enrollment information via the National Student Loan Data System (NSLDS) (OMB No. 1845 0035). 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 verify 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. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. Institutions are responsible for accurately reporting the following significant data elements under the Campus Level Record that the Department of Education (ED) considers high risk: • OPEID number, enrollment effective date, enrollment status and certification date Institutions are responsible for accurately reporting the following significant data elements under the Program Level Record that ED considers high risk • OPEID number, CIP code, CIP year, credential level, published program length measurement, published program length, program begin date, program enrollment status and program enrollment effective date Institutions are responsible for timely reporting, whether they report directly or via a third party servicer. Institutions must complete and return the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845 0002) mailboxes sent by ED via NSLDS within 15 days. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context: The University utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for transmissions of its enrollment reporting changes to the National Student Loan Data System (NSLDS). The University receives the Enrollment Reporting Roster and updates it for changes in student status. The file is sent to the Clearinghouse who transmits the updated information to NSLDS. For a sample of 60 students who were recipients of Direct Loans or Pell Grants between July 1, 2023 and June 30, 2024 who had been identified as having withdrawn, graduated, or modified their enrollment status as defined by the University’s Satisfactory Academic Progress Policy through a change in course load, the following were noted: • For 12 out of the 60 students selected for testwork, the University inaccurately reported their enrollment status as half time or full time when the University’s published policies and enrollment records indicated that they are enrolled as three-quarter time. The University updated the students’ NSLDS record in the final quarter of 2024. Additionally, for one of the 12 students, the University also incorrectly reported their spring enrollment status as less than half time rather than full time. This is due to a system limitation where only the student’s graduate courses enrollment status is reported when the student was also enrolled full-time in undergraduate courses. This student is in the Architecture program. • For one out of the 60 students selected for testwork, the University did not report their Campus-Level and Program-Level enrollment status in NSLDS. The individual was enrolled full time during the 2023-2024 school year and graduated at the end of the spring semester. • For two out of the 60 students selected for testwork, the University inaccurately reported their enrollment status as other than half time rather than full-time students. This is due to a system limitation of only reporting the student’s graduate courses enrollment status when the student was also enrolled in undergraduate courses for a full-time course load. These students are in the Architecture program. • For one out of the 60 students selected for testwork, the University inaccurately reported their enrollment status as less than half time rather than full time. This is due to a system limitation of reporting only the student’s online enrollment status when the student was also enrolled in main campus courses for a full-time course load. • For one of the 60 students selected for testwork, the University did not report their winter online enrollment status as half time. This is due to a system limitation of reporting only continuous enrollment based on the student’s main campus enrollment, rather than the online winter term enrollment status. • For one of the 60 students selected for testwork, the University did not report their withdrawn status within the 60 days of the change. • For one of the 60 students selected for testwork, the University did not report their enrollment status change from full time to less than half time during the spring semester within the 60 days of the change. This is due to a system limitation of reporting only the student’s main campus enrollment status when the student only enrolled in online courses for the spring semester Cause and Possible Asserted Effect: The University’s controls over its review of the recording and communication of these status changes did not operate consistently to ensure that individuals’ enrollment statuses are completely and accurately communicated to NSLDS. The University had a system limitation that does not allow enrollment statuses to be reflected as three-quarter time, which was not corrected until March 2024. Additionally, the University has a system limitation when students are enrolled in multiple campuses and program, causing the reporting of only one program or campus in NSLDS. Identification of questioned Costs: There are no questioned costs related to this finding. Sampling: The sample was not intended to be and was not a statistically valid sample. Recommendation: We recommend that the University improve its IT processes and functionality so that enrollment statuses, particularly enrollment statuses for students who are enrolled in multiple programs, are reported completely and accurately. We also recommend the University strengthens its controls over the accuracy of students enrollment status changes. Identification of Repeat Finding This finding is not a repeat of a finding in the prior year Views of Responsible Officials: The University concurs with the finding. The University is working with the Clearinghouse and consultants to correct system errors with Banner, so we do not have these concerns in the future. The Architect students mapping issues was corrected by the Registrars Office in March 2025. The Registrar's Office has created a new program code that will reflect next semester's registrations and uploaded majors.