Finding 1175762 (2025-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-02-27
Audit: 389674
Organization: Briar Cliff University (IA)

AI Summary

  • Core Issue: The school failed to report changes in enrollment status for 10 out of 40 students within the required 60 days, leading to inaccuracies in federal loan records.
  • Impacted Requirements: Noncompliance with 34 CFR 685.309(b) regarding timely updates to the National Student Loan Data System (NSLDS) affects loan repayment accuracy.
  • Recommended Follow-Up: Implement policies to ensure accurate reporting of enrollment changes and effective dates to NSLDS, including regular reviews of student status updates.

Finding Text

Program: Federal Direct Student Loans CFDA Number: 84.268 Federal Agency: U.S. Department of Education Federal Award Identification Number P268K221428 Federal Award Year: June 30, 2024 Repeat of Prior Year Finding 2024-003 Criteria: 34 CFR 685.309(b) states that upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary in the manner and format prescribed by the Secretary and within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, 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. Condition: For 10 students tested, the change in enrollment status was not reported to NSLDS within 60 days. For 1 student tested, the enrollment status reported to the National Student Loan Data System (NSLDS) did not match the University’s records during the fiscal year 2025. Question Costs: Not applicable. Context: Noncompliance with federal regulations was noted for 11 of the 40 students who were tested. 10 of the students did not have their change in enrollment status reported to NSLDS within 60 days. 1 student did not show the correct change of status, and thus also did not have their change in enrollment status reported timely to NSLDS. A total of 575 students who were issued Federal Direct Student Loans separated from the University or had a change in enrollment status during fiscal year 2025. The sample was not considered statistically valid. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and other information, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Cause: It does not appear that there are proper processes in place surrounding enrollment reporting in order to verify that the correct dates, enrollment statuses, or other information are reported to NSLDS within the required timeframes. Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates and status changes are reported to NSLDS within required time frames. This could include a review of withdrawal or graduation dates compared to the effective dates reported to NSLDS to make sure they are accurate.

Corrective Action Plan

Management’s Response: The University has undertaken several initiatives to enhance compliance and accuracy: Management acknowledges the material weakness related to enrollment reporting for the Federal Direct Student Loan Program and recognizes the importance of timely and accurate reporting to the National Student Loan Data System (NSLDS). During fiscal year 2025, the University experienced challenges related to enrollment reporting accuracy and timeliness. In response, management implemented significant corrective actions to strengthen accountability, improve cross-department coordination, and enhance monitoring controls. Key actions taken during and subsequent to fiscal year 2025 include: • Strengthened Leadership and Accountability: A new Financial Aid Director was hired in March 2025 and has prioritized the resolution of this repeat audit finding. Clear responsibility for enrollment reporting oversight has been established. • Improved Cross-Department Coordination: The Financial Aid Office now works closely with the Registrar’s Office and Information Technology to ensure alignment between institutional enrollment records and federal reporting systems. • System Configuration Review: Enrollment reporting processes and system configurations within the Colleague system were reviewed to ensure that student enrollment statuses and effective dates are captured and reported accurately. • Identification and Correction of Reporting Issues: Management identified discrepancies in enrollment reports generated by Colleague that resulted in inaccurate federal reporting for certain students. Corrective solutions have been identified and implemented to address these issues. Enhanced Monitoring and Review: The Financial Aid Director now performs regular reviews of all withdrawn and graduated students to verify consistency between Colleague, the National Student Clearinghouse, and NSLDS prior to and after submission. • Improved Timeliness of Corrections: Any discrepancies identified are promptly reviewed and corrected in coordination with the Registrar’s Office to ensure compliance with required reporting timeframes. • Policy and Training Enhancements: Policies and procedures related to enrollment reporting are being refined, and additional staff training has been implemented to reinforce compliance requirements and internal controls. Management believes these actions have materially improved the accuracy and timeliness of enrollment reporting. Continued monitoring and application of these controls are expected to result in sustained compliance and resolution of this finding in a future audit period. These initiatives demonstrate the University’s commitment to maintaining accurate student enrollment records and ensuring compliance with federal regulations, thereby safeguarding the interests of its students and the institution.

Categories

Student Financial Aid Reporting

Other Findings in this Audit

  • 1175763 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $8.53M
84.063 FEDERAL PELL GRANT PROGRAM $1.32M
84.038 FEDERAL PERKINS LOAN PROGRAM $1.04M
84.044 TRIO TALENT SEARCH $551,485
84.042 TRIO STUDENT SUPPORT SERVICES $358,385
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $151,286
84.033 FEDERAL WORK-STUDY PROGRAM $81,461
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $9,430