Finding 2025‐001 Special Tests and Provisions – Enrollment Reporting Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal program: Student Financial Assistance Cluster: Federal Pell Grant Program, ALN 84.063 Federal Direct Student Loans, ALN 84.268 Award year: 2024‐2025 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). NSLDS Enrollment Reporting Guide Chapter 1.4: At a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the NSLDS sends a roster file to the school or its third-party servicer. This requirement also applies to schools that report exclusively online. When 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 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; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Condition: The University did not provide evidence of an effective review process to ensure accurate and timely reporting of student status changes to NSLDS. The University did not report program enrollment effective date or student status to the NSLDS for 1 of 60 students selected for testing. Cause: The University did not have effective internal controls and procedures in place to ensure status changes were reported to the NSLDS accurately and timely. Effect or potential effect: Lack of timely and accurate enrollment reporting results in inaccurate enrollment status. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Questioned costs: $0 Context: We issued a material weakness related to internal control over compliance with enrollment reporting requirements in the prior year. Based upon the implementation date for the corrective action of May 31, 2025, provided by management, the finding related to this internal control had not been remediated for the period under audit. As such, we did not test the operating effectiveness of this internal control and are issuing a material weakness consistent with the prior year finding. EY selected and tested 60 students from the combined population of 1681 students that withdrew, never attended (no shows), graduated, or had changes in attendance levels during the year ended May 31, 2025. The 60 students, randomly selected, consisted of 35 student graduates, 15 student withdrawals/no shows, and 10 student changes in attendance levels. Of the 10 student changes in attendance levels, 1 student change in attendance level was not reported to the NSLDS. As a result, campus and program level data for program enrollment effective date and status was not reported for this student. For the 35 student graduates and 15 student withdrawals/no shows, the student status changes were reported accurately and timely to NSLDS. Total Student Financial Assistance Cluster expenditures for the year ended May 31, 2025, were $138,008,610, of which $14,477,268 were for Pell and $118,404,580 were for Direct Loans. Identification as a repeat finding, if applicable: Yes – 2024-001; 2023-001; 2022-001; 2021-001; 2020-001; 2019-002 Recommendation: The University should review, revise and implement internal controls and procedures surrounding the accurate and timely reporting of student status changes to the NSLDS. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan which includes the Registrar’s Office and the Office of Financial Assistance working together to eliminate reporting issues and provide for successful data processing for enrollment reporting. The corrective action will be implemented by May 31, 2026.