Condition: The examination disclosed 11 out of 25 student status change files tested, in which NSLDS was not updated correctly. Eight of the eleven students’ Program Begin Date reported to NSLDS is the same date as the student's most recent effective status date, although the student has been enrolled in the program with the same CIP code with prior statuses such as Full time or Three-Quarter Time. The remaining three students were withdrawn students whose last day of attendance was not reported accurately. The auditor identified noncompliance and a significant deficiency in internal control over compliance related to the administration of Title IV federal financial aid. ________________________________________ Cause: After thorough review, it was discovered that programmatic data manipulation occurred as a result of attempts to circumvent or bypass National Student Clearinghouse enrollment system error messages, by the Information Technology department. This practice developed due to incomplete resolution of underlying system integration issues and insufficient supervisory review of the corrective steps being taken, in the past. Although no evidence of intentional misrepresentation was found, the manipulation of system data reduced the reliability of automated submissions from the Information Technology department. Furthermore, it was discovered that a Jenzabar system defect causing withdrawal dates to be incorrectly reported to the National Student Clearinghouse has occurred. Further review has discovered a default date was entered in the NSLDS system by National Student Clearinghouse, in place of the correct withdrawal date listed in the Jenzabar system. Corrective Action Plan: Action Step Responsible Persons Timeline for Completion Status/Follow-Up Identify and document all programmatic data manipulations performed to address error messages and assess impact on compliance reporting. Kylee Bump, Director of Financial Aid; Brandy Chasteen, Registrar; Raj Siddaraju, CIO November 2025 Complete Work with National Student Clearinghouse to resolve underlying system integration and understand error message issues. Kylee Bump, Director of Financial Aid; Brandy Chasteen, Registrar; Raj Siddaraju, CIO December 2025 Complete Implement formal data correction policy requiring supervisory approval for any system data adjustments. Sarah Gray, CFO & Raj Siddaraju, CIO January 2026 Completed Conduct staff training on proper error resolution procedures and reinforce internal control expectations. Sarah Gray, CFO & Raj Siddaraju, CIO January 2026 Completed Perform quarterly internal reviews of data integrity and system-generated compliance reports. Kylee Bump, Director of Financial Aid; Brandy Chasteen, Registrar; Raj Siddaraju, CIO In Place Ongoing To ensure accuracy moving forward, our Registrar will review a random sampling of our enrollment reporting through the National Student Clearinghouse throughout the semester and after degrees have been confirmed for each semester.