Finding 1163407 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2025-12-03
Audit: 372939
Organization: Texas Wesleyan University (TX)

AI Summary

  • Core Issue: The University failed to report student enrollment status changes accurately and on time to the National Student Loan Data System (NSLDS).
  • Impacted Requirements: Compliance with federal regulations regarding enrollment reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309).
  • Recommended Follow-Up: Update internal controls and review processes to ensure timely and accurate reporting of enrollment status changes, addressing identified errors in the student information system.

Finding Text

Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2024-2025 Criteria or specific requirement – Special Tests and Provisions – Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information. Condition – The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Questioned costs – $0 Context – Out of the population of 580 students with changes in enrollment status, a sample of 25 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. There were 14 attributes tested for each student with at least one status change. Campus-Level Records: 1. OPEID Number 2. Enrollment Effective Date 3. Enrollment Status 4. Certification Date Program-Level Records 5. OPEID 6. CIP Code 7. CIP Year 8. Credential Level 9. Published Program Length Measurement 10. Published Program Length 11. Program Begin Date 12. Program Enrollment Status 13. Program Enrollment Effective Date Other Records 14. Student changed his or her permanent address The University did not report two student’s enrollment changes. The University did not timely report status changes for 20 students. Effect – The University reported incorrect statuses for students’ status changes and did not report the status changes timely. Cause – The University’s processes did not ensure status changes were reported timely and accurately. Additionally, an incorrect configuration within the University’s student system to cause errors in how enrollment status changes were reported, which resulted in the National Student Clearinghouse placing a temporary hold on all new submissions until the discrepancy was resolved. Identification as repeat finding, if applicable – 2024-002 and 2023-002 Recommendation – The University should update their controls to ensure changes in students’ enrollment status are reported in a timely and accurate manner. Views of responsible officials and planned corrective actions – The University concurs that errors occurred which resulted in the instances of untimely and/or inaccurate student status reporting to the National Student Loan Data System (“NSLDS”) identified during the audit review. Specifically, one parameter setting within the University’s student information system (“SIS”) had been inadvertently configured to populate a data field with information that did not correspond to the enrollment reporting fields accurately in National Student Clearinghouse (“NSC”) or NSLDS. The Registrar’s Office initiated a contemporaneous review of the internal systems working with the University’s service providers to determine the cause of the inaccurate data populating during the enrollment reporting process in award year 2024-2025. That review found that human error contributed to the inaccurate configuration and inaccurate and/or untimely reporting. This appeared to be due in part to a misinterpretation by staff of certain data field(s) in the University’s SIS and the reporting mechanisms between NSC and NSLDS, causing inaccurate and/or untimely enrollment reporting. As part of its response to this audit review, the University continues the review and investigation of its internal systems, service providers, and staff to ensure the root causes of any enrollment reporting deficiencies have been remedied. The University will include, as part of the supplemental Corrective Action Plan, details of that review, plans for analysis and remedial actions currently underway, as well as those corrective measures the University plans to take going forward.

Corrective Action Plan

Corrective Actions: The University has implemented the following measures with respect to enrollment reporting (“ER”) to strengthen internal controls and ensure full compliance with federal regulations, University policy, and the requirements of NSLDS: 1. Review of ER Systems and Updates Implemented: The University has contracted with external consultants to assist the University in reviewing and reinforcing its ER systems and processes. This work is ongoing and intended to supplement the prior review of the University’s SIS noted in the Response above, which determined a delay in the chronological processing of reports in NSC due to configuration issues in the SIS contributed to the untimely/inaccurate reporting. As a result, the University updated those parameters within its SIS to ensure accurate configuration in Spring 2025. Through this Finding response and the internal and external reviews initiated by the University, Texas Wesleyan has built upon that prior examination to include an analysis of the specific deficiencies noted by auditors and ensure the same have been cured, as well as to implement any necessary compliance measures to safeguard all future ER. In addition to completing any updates required to student-level data in NSC, the University reviewed each deficiency and corresponding student record to discern the cause of the inaccurate data and made necessary systems and/or procedural changes to cure each. First, the University determined that for two of the students with ER errors, additional processes were necessary to capture students enrolled in compressed terms. In collaboration with external consultants and NSC, the Registrar’s Office is developing new processes to ensure accurate ER for these students. This process development is being overseen by Registrar and Associate Provost with a target date for implementation during the initial Spring 2026 7-week compressed terms beginning on January 12th and March 23rd, respectively, subject to testing being conducted with NSC. Second, with respect to graduation status, the University has reviewed the students noted in this Finding with its external consultants and NSC. To ensure that graduation statuses are timely and accurately reported according to University policy and federal requirements, the University is adopting updated procedures to include reporting “G” or “W” status in accordance with guidance from the NSLDS Enrollment Reporting Guide, Section 4.4.4. These procedural updates are being made by the Registrar, overseen by the Associate Provost, and are expected to be finalized by December 5, 2025 Third, together with IT and external consultants, the Registrar’s Office is continuing its review and testing of parameter settings through a comparison of SIS and NSC data to confirm that parameters are accurately configured for ER. The data for this review has been compiled as of the date of this submission and the Registrar is reviewing the data to prepare a comparative report that will be provided to the Working Group (described in Section 2 below) overseen by the Associate Provost. The Registrar’s comparative report to the Working Group is expected to be delivered on January 20, 2026. Finally, as noted below, to ensure timely and accurate reporting and the reconciliation of error reports, the University has implemented several preventive and detective measures with ongoing monitoring and review measures to ensure its compliance. 2. Preventative Measures and Monitoring: The University has integrated, and continues to integrate, updated detective and preventative controls on ER to safeguard the University’s compliance for future reporting by expanding existing reporting controls through regular monitoring efforts to test and review compliance at each reporting level. These preventative measures, monitoring and reconciliation requirements are being overseen by the Associate Provost and include the establishment of a Working Group with external consultants and service providers, as well as stakeholders from the Provost, Registrar, Information Technology, and Financial Aid offices, that meets frequently to review ER, complete the work described in these Corrective Actions, and to ensure discrepancies are discovered and resolved timely and accurately. The Registrar and the Director of Financial Aid also meet monthly to conduct reconciliations of ER which is then reported to the Provost and Associate Provost. In addition to updating its graduation ER procedures, the University has updated its reporting schedule in NSC to provide additional reporting opportunities during the end of the term to ensure all graduation information is timely reported. Finally, the University has met with NSC to review this Finding and its ER practices generally. As a result of that meeting, the University has received from NSC its “Enrollment Reporting Compliance Best Practices Checklist” which the Registrar has provided to all staff in the Registrar’s Office as a guidance document and reference tool for ER. In addition, the Registrar is conducting an office-wide review of the NSC “Enrollment Reporting Compliance Best Practices Checklist” on December 4th, 2025. 3. Staff and Training: In conjunction with this Finding and the internal and external reviews, the University has and continues to review staffing within the Registrar’s Office to ensure appropriate changes have been made as deemed necessary by management. To ensure compliance and accuracy, beginning December 9, 2025, all personnel in the Registrar’s Office will participate in a weekly “Power-Hour” meeting wherein they will complete ER training through NSC, Federal Student Aid, and other resources. This training will continue in accordance with the 2026 training plan and schedule being developed by the Registrar. The training plan and schedule will be delivered to the Associate Provost by January 1, 2026, and is subject to their review and approval. All training and participation will be documented in a report to the Associate Provost. The University has also engaged external consultants to assist staff in ER to ensure compliance and provide secondary review for the Registrar’s Office as needed. Responsible Official: Dr. Helena Bussell, Associate Provost Estimated Completion Date: April 24, 2026

Categories

Reporting Student Financial Aid Special Tests & Provisions

Other Findings in this Audit

  • 1163401 2025-001
    Material Weakness Repeat
  • 1163402 2025-001
    Material Weakness Repeat
  • 1163403 2025-001
    Material Weakness Repeat
  • 1163404 2025-001
    Material Weakness Repeat
  • 1163405 2025-001
    Material Weakness Repeat
  • 1163406 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $28.58M
84.063 FEDERAL PELL GRANT PROGRAM $6.81M
84.047 TRIO UPWARD BOUND $1.18M
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $758,100
84.031 HIGHER EDUCATION INSTITUTIONAL AID $439,894
84.033 FEDERAL WORK-STUDY PROGRAM $324,027
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $305,706
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $66,923
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $11,316
45.310 GRANTS TO STATES $1,104