Finding 1166643 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2025-12-24

AI Summary

  • Core Issue: The Seminary failed to report enrollment status changes for two out of three students accurately and on time to NSLDS.
  • Impacted Requirements: Institutions must report enrollment information within 15 days and changes within 60 days as mandated by the Department of Education.
  • Recommended Follow-Up: Enhance policies to ensure timely and accurate enrollment reporting, especially during peak periods like graduation.

Finding Text

Special Tests – Enrollment Reporting Federal Assistance Listing Number: 84.268 Name of Program or Cluster: Federal Direct Student Loans (Student Financial Aid Cluster) Agency: Department of Education Criteria: Institutions are required to report enrollment information under the Federal Pell Grant and Federal Direct Student Loans programs via the National Student Loan Data System (“NSLDS”). Institutions must complete and return the Enrollment Reporting roster placed in their Student Aid Internet Gateway mailboxes sent by the U.S. Department of Education via NSLDS within 15 days of receipt of the roster. Additionally, institutions are required to report changes in student enrollment status via NSLDS within 60 days. Condition: Two of three students’ enrollment status changes were not recorded accurately and timely to NSLDS and during the year ended June 30, 2025. Cause: Due to turnover in the Seminary’s Registrar department, enrollment reporting during high volume periods, such as graduation, were delayed due limits in work capacity of the staff available during the fiscal year. Effect: The Seminary was not in compliance with enrollment reporting requirements. Questioned Costs: None. Repeat Finding: Yes, see prior year finding 2024-006. Recommendation: We recommend that the Seminary enhance existing policies to comply with enrollment reporting requirements. This policy should include a method for ensuring both timely enrollment updates as well as accuracy of the data reported. Views of Responsible Officials: See corrective action plan attached.

Corrective Action Plan

This Repeat Finding has been acknowledged. Union has taken several steps towards making the required changes to ensure compliance with our enrollment reporting responsibilities. This includes implementing process improvements related to our National Clearing House (NSC) submissions and reviewing our academic policies related to academic leaves of absence and withdrawals. Timeliness of Enrollment Reporting Rosters: As of January 2024, Union completed the setup and configuration of our enrollment reporting services with NSC as our third-party service provider. The new process is administered by the school Registrar, with back-up responsibilities handled by the Assistant Dean, Director of Financial Aid, and the Vice President of Admissions and Views of Responsible Officials: This Repeat Finding has been acknowledged. Union’s Academic Office is in the late stages of implementing a multi-year action plan to implement the required system, policy, and procedural changes to ensure compliance with all enrollment reporting regulations. As of January 2024, Union completed our migration to the National Clearinghouse (NSC) as our third service provider for enrollment reporting services. We have already experienced a strong positive impact on the timeliness of our enrollment reporting. For example, we have fully addressed the timeliness of our NSLDS Roster response, which is due within 15 days. This year’s testing sample yielded zero (0) errors, demonstrating our ability to successfully address enrollment reporting issues. The steps outlined below will allow us to address the enrollment reporting issue identified in this year’s testing sample. Earlier this academic year, Union revised both our Academic Leave of Absence and Term Withdrawal policies to ensure alignment with our compliance obligations. Due to these changes, Union has already noted a reduction in reporting errors and inconsistencies. The FY25 Single Audit finding is related to the reporting of withdrawal/dismissal actions that took place in summer, a non-required term for students in our programs. Our corrective action will be to: (1) further modify our policies and procedures to specifically address non-required and interim terms; and (2) increase the number of batch enrollment updates to NSC/NSLDS during non-required terms to ensure that all summer withdrawals are communicated within 60 days.

Categories

Student Financial Aid Reporting

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $1.62M
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $623,967
84.033 FEDERAL WORK-STUDY PROGRAM $64,058