Finding 1169053 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-01-14

AI Summary

  • Core Issue: The University failed to report student enrollment status accurately and on time, violating federal regulations.
  • Impacted Requirements: Institutions must certify enrollment every 60 days and ensure accurate reporting to NSLDS, including effective dates.
  • Recommended Follow-Up: The University should improve its reporting procedures to ensure compliance with enrollment status reporting requirements.

Finding Text

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: Various Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number: N/A Award Period: June 1, 2024 – May 31, 2025 Type of Finding: • Material Weakness in Internal Control over Financial Reporting • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus Level and the Program Level. In addition, at a minimum, schools are required to certify enrollment every 60 days and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: During our testing, we noted 33 out of the 60 students tested did not have enrollment data certified every 60 days. In 7 of the 60 students tested, the students’ status per the institution's records did not match what was reported to NSLDS. Furthermore, 24 out of the 60 students had an incorrect enrollment effective date. Questioned Costs: N/A Context: During our testing, it was noted the University does not have adequate processes in place to ensure timeliness and accuracy of NSLDS reporting. Cause: The University’s processes and controls did not ensure that student status changes were properly reported to NSLDS in a timely manner. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: Yes, finding 2024-002 Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Corrective Action Plan

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In response to these challenges, the University initiated corrective actions beginning in Summer 2025. 1. Dedicated Technical Resources: We have been assigned dedicated ITS staff members (managed by Dynamic Campus) specifically to the resolution of enrollment and graduation submission and compilation logic. 2. Submission Scheduling: A rigid schedule for monthly enrollment and graduation submissions has been established for both Branch 00 and Branch 76. 3. Staffing: An additional Registrar’s Office staff member has been shifted to assist with the NSC process, specifically focusing on the remediation of error reports. 4. Policy Revision: We have simplified the degree conferral policy to improve the accuracy of graduation reporting. We are also working to align end of term grade submission deadlines to allow for timely end of term processing and degree conferrals. This in turn will aid in more timely submissions especially as it affects graduation reporting. 5. Data Mapping: The Registrar’s Office has collaborated with ITS to audit the specific fields and tables used to generate Clearinghouse reports. This addresses the complexity of reporting on two branches involving multiple term codes. 6. Automation: We have implemented a timely and automated submission schedule. 7. Change Management Protocols: A protocol is being implemented to prevent ITS system upgrades or network maintenance during scheduled reporting windows. 8. Data Reconciliation: We will implement a strict monitoring of Clearinghouse records regarding graduation and withdrawal dates, reconciling them against the Student Information System (SIS) and NSLDS data. That will occur once we can gain NSLDS access for the two staff members. Discrepancies will be corrected immediately. Special attention will be paid to conferral dates since they may not align with the final day of the term or sub-term. 9. Cross-Departmental Alignment: We will continue regular consultations with the Financial Aid Office regarding complex registration changes to ensure consistent interpretation and reporting. 10. Ongoing Training: Staff will continue to utilize training opportunities provided by the Clearinghouse, Banner, and other relevant bodies. Name(s) of the contact person(s) responsible for corrective action: Cheryl Fisk, University Registrar Planned completion date for corrective action plan: March 1, 2026

Categories

Student Financial Aid Material Weakness Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1169048 2025-001
    Material Weakness Repeat
  • 1169049 2025-001
    Material Weakness Repeat
  • 1169050 2025-001
    Material Weakness Repeat
  • 1169051 2025-001
    Material Weakness Repeat
  • 1169052 2025-001
    Material Weakness Repeat
  • 1169054 2025-002
    Material Weakness Repeat
  • 1169055 2025-002
    Material Weakness Repeat
  • 1169056 2025-002
    Material Weakness Repeat
  • 1169057 2025-002
    Material Weakness Repeat
  • 1169058 2025-002
    Material Weakness Repeat
  • 1169059 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $18.75M
84.063 FEDERAL PELL GRANT PROGRAM $3.16M
84.033 FEDERAL WORK-STUDY PROGRAM $463,309
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $448,682
47.049 MATHEMATICAL AND PHYSICAL SCIENCES $79,585
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $71,274
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $66,269
47.074 BIOLOGICAL SCIENCES $26,177
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $600