Finding 1175388 (2025-006)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-02-25
Audit: 389114
Organization: Norwich University (VT)

AI Summary

  • Core Issue: The University failed to report enrollment status changes for one out of 25 sampled students within the required 15-day timeframe.
  • Impacted Requirements: Compliance with federal regulations for timely enrollment reporting under the Federal Pell Grant and Direct Loan Programs.
  • Recommended Follow-Up: Implement a monthly quality control review process to ensure all student status changes are accurately reported and reconciled.

Finding Text

Finding Number: 2025-006 Federal Program: Federal Agency: U.S. Department of Education (ED) Program Name: Student Financial Assistance Cluster AL: 84.063, 84.268 Federal Award Identification Numbers: N/A Federal Award Year: 2025 Specific Requirement: Under the Federal Pell Grant and Federal Direct Loan Programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via National Student Loan Data System (NSLDS). Institutions must review, update and verify enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access website. Also, an institution must notify NSLDS within 30 days after the date that the institution discovers that a direct loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended (PELL, 34 CFR section 690.83(b)(2), and Direct Loans, 34 CFR section 685.309). Condition Found: The University did not submit status changes for one student out of 25 students sampled within the required timeframe. Context: During our testing of 25 students, we identified one student tested whose enrollment status was either not timely reported, not updated to graduate from withdrawn, not reported with correct enrollment status, not reported with correct effective date, or a combination of the above to NSLDS due to the lack of a reconciliation between registrars reports and rosters reported to the NSLDS. Questioned Costs: None noted Cause and Effect: The University was aware of the requirement to submit student status changes timely. Due to lack of a reconciliation process within the University’s student financial services department, student status changes were missed. The effect of the noted conditions results in an inaccurate last date of attendance reported to NSLDS which is used to determine the date a student is to be placed into repayment status and begin making payments on student loans. Identification as a Repeat Finding, if Applicable: A repeat finding, see finding 2024-001 Recommendation: We recommend the University review the system generated report to verify all students are included in addition to implementing a quality control review process to be completed monthly to ensure all student changes are reviewed in a timely manner to help ensure compliance with the 60 day requirement. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

The errors noted in the finding resulted from a missing step in the reconciliation process. The Registrar’s office relied on an error report from NSC to help identify any issues that might be noted in the student files. The findings noted, reinforced that this process alone was not sufficient to capture all errors. To ensure that these types of errors do not recur, subsequently, the registrar’s office team has initiated an additional monthly reconciliation between the NSLDS and internal student management system. This reconciliation will show any status variance or date mismatches. Any variances noted will be updated in the NSC/NSLDS system. This process was implemented in December 2024 when the issue was found as part of the 2024 audit. The 2025 finding relates to an individual who withdrew from the University prior to December 2024 with the new procedures in place. Responsible party: Sarah Harris, Director, Office of Financial Aid; (802) 485-2679 Anticipated Completion Date: December 2024

Categories

Student Financial Aid Reporting

Other Findings in this Audit

  • 1175387 2025-006
    Material Weakness Repeat
  • 1175389 2025-007
    Material Weakness Repeat
  • 1175390 2025-007
    Material Weakness Repeat
  • 1175391 2025-007
    Material Weakness Repeat
  • 1175392 2025-007
    Material Weakness Repeat
  • 1175393 2025-007
    Material Weakness Repeat
  • 1175394 2025-007
    Material Weakness Repeat
  • 1175395 2025-007
    Material Weakness Repeat
  • 1175396 2025-007
    Material Weakness Repeat
  • 1175397 2025-007
    Material Weakness Repeat
  • 1175398 2025-007
    Material Weakness Repeat
  • 1175399 2025-007
    Material Weakness Repeat
  • 1175400 2025-007
    Material Weakness Repeat
  • 1175401 2025-007
    Material Weakness Repeat
  • 1175402 2025-007
    Material Weakness Repeat
  • 1175403 2025-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $14.00M
84.063 FEDERAL PELL GRANT PROGRAM $4.41M
12.905 CYBERSECURITY CORE CURRICULUM $1.91M
11.617 CONGRESSIONALLY-IDENTIFIED PROJECTS $1.91M
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $1.56M
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $1.42M
93.310 TRANS-NIH RESEARCH SUPPORT $821,454
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $680,256
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $607,483
84.033 FEDERAL WORK-STUDY PROGRAM $411,687
93.364 NURSING STUDENT LOANS $137,062
20.701 UNIVERSITY TRANSPORTATION CENTERS PROGRAM $124,996
12.910 RESEARCH AND TECHNOLOGY DEVELOPMENT $89,874
81.008 CYBERSECURITY, ENERGY SECURITY & EMERGENCY RESPONSE (CESER) $62,515
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $49,772
15.814 NATIONAL GEOLOGICAL AND GEOPHYSICAL DATA PRESERVATION $32,635
43.008 OFFICE OF STEM ENGAGEMENT (OSTEM) $22,808
93.493 CONGRESSIONAL DIRECTIVES $13,864
12.903 GENCYBER GRANTS PROGRAM $12,722
47.083 INTEGRATIVE ACTIVITIES $11,007
12.902 INFORMATION SECURITY GRANTS $6,965
93.859 Biomedical Research and Research Training $4,718