Finding 1166452 (2025-001)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2025-12-23
Audit: 377462
Organization: Grand View University (IA)
Auditor: RSM US LLP

AI Summary

  • Core Issue: The University failed to accurately report changes in student enrollment status to the NSLDS for 8% of students tested, specifically regarding unofficial withdrawals.
  • Impacted Requirements: Compliance with CFR sections 685.309 and 690.83(b)(2) is necessary for timely reporting of student status changes, which was not met.
  • Recommended Follow-Up: Implement review procedures to ensure accurate reporting of effective dates for student withdrawals and status changes to the NSLDS.

Finding Text

Finding 2025-001 U.S. Department of Education Student Financial Aid Cluster (Federal Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 and 84.379) Federal Award Year 2024-2025 Criteria: CFR section 685.309 and 690.83(b)(2) requires the University to notify the NSLDS within 30 days of a change in student status or include the change in status in a response to an enrollment reporting roster within 60 days of the student’s date of determination of withdrawal. Condition: For two out of 25 students tested (8%) for properly reported enrollment changes at the University, the students' status change at the campus level and program level were not accurately reported to the National Student Loan Data System (NSLDS). Of these two students identified with noncompliance (both of which were unofficial withdrawals) one student's status change was not reported to the NSLDS, and one student was reported timely but with improper effective status change dates. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that enrollment status changes are reported timely. Cause: The University’s controls over unofficial withdrawals failed to either timely identify or identify at all unofficial withdrawals where students don’t go through the formal withdrawal process. This is a manual process primarily related to students that stop attending classes without official notice and the University is dependent on professors providing final date of attendance. Effect: Failure to report status changes accurately is noncompliance with Federal regulation and could result in loss of future funding. Questioned Costs: There were no questioned costs related to testing of enrollment reporting. Context: Two out of 25 students originally selected for testing. The University then reviewed all unofficial withdrawals and identified five additional students with reporting errors. Based on identified errors, an additional seven students were selected for testing and no errors were identified that weren’t already identified by the University. Recommendation: We recommend the University implement review procedures to ensure that the proper effective date is being reported to the NSLDS when a student withdraws or has an enrollment status change. A system of review procedures and/or controls will ensure the University is reporting status changes accurately. Views of responsible officials: We agree with this finding. See corrective action plan.

Corrective Action Plan

When processing unofficial withdrawals through the R2T4 process, an additional step to the withdrawal process has been added. Financial Aid staff will use the NSLDS Enrollment History Update feature to submit the unofficial withdrawal date directly to NSLDS. This ensures that the date has been reported to NSLDS avoiding any potential that the student being reported has missed the regular NSC enrollment reporting rosters.

Categories

Matching / Level of Effort / Earmarking Student Financial Aid Reporting

Other Findings in this Audit

  • 1166447 2025-001
    Material Weakness Repeat
  • 1166448 2025-001
    Material Weakness Repeat
  • 1166449 2025-001
    Material Weakness Repeat
  • 1166450 2025-001
    Material Weakness Repeat
  • 1166451 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $12.89M
84.063 FEDERAL PELL GRANT PROGRAM $4.46M
84.031 HIGHER EDUCATION INSTITUTIONAL AID $369,925
84.033 FEDERAL WORK-STUDY PROGRAM $153,017
84.038 FEDERAL PERKINS LOAN PROGRAM $110,468
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $58,566
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $26,404
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $21,321