Finding 1179155 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-12

AI Summary

  • Core Issue: The University failed to properly certify student enrollment statuses and report changes, leading to inaccuracies in the NSLDS database.
  • Impacted Requirements: Compliance with 34 CFR 685.309(b) and NSLDS guidelines regarding timely updates and verification of student enrollment information.
  • Recommended Follow-Up: The University should review and improve its reporting procedures to ensure accurate enrollment data is submitted to NSLDS as required.

Finding Text

Finding 2025-001: NSLDS Enrollment Reporting Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.033, 84.268, 84.007 Award Period: September 1, 2024, through August 31, 2025 Type of Finding:  Significant Deficiency in Internal Control over Compliance  Other Matters Criteria or Specific Requirement: In accordance with 34 CFR 685.309(b) and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools must review, update, and verify student 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 (NSLDSFAP) website. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Condition/Context: During our testing of 40 students, which is a statistically valid sample, we noted 20 instances where the student's enrollment status was not certified at least every 60 days, 5 instances where the published program length was improperly reported to the NSLDS system, 3 instances of late reporting of student status changes, 6 instances of the student record not being found in the NSLDS system, 5 instances where the student status change was improperly reported at the campus-level record, and 10 instances where the program begin date was not properly reported to the NSLDS system. Questioned Costs: None. Cause: The University's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information is reflected in the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. Repeat Finding: Yes, see finding 2024-001. Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Views of Responsible Officials: Please refer to the attached corrective action plan.

Corrective Action Plan

NSLDS Enrollment Reporting Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.033, 84.268, 84.007 Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately 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: A complete review of CIP code usage will be reviewed and ensure that there is alignment across academics, registrar, and financial aid. The last review was done in 2024 but with changes alignment fell out of sync. We are also working with our SIS vendor, Jenzabar, to continue to identify areas where the SIS is out of sync with compliance and how best to e􀆯ectively address them if it is a data issue or an issue with internal SIS logic. We are also actively engaging with the National Student Clearinghouse to identify issues and clean them up proactively. Registrar updated internal processes to ensure enrollment status reporting aligns with NSLDS guidance by using the Date of Determination (DOD), rather than the graduation or term end date, as the exit date for graduates. This approach is consistent with federal guidance and has been implemented. Name(s) of the contact person(s) responsible for corrective action: Robert Boggs, EdD, University Registrar Planned completion date for corrective action plan: 3/6/2026 for the CIP audit; 8/31/2026 for SIS and NSC; internal process changes are complete.

Categories

Student Financial Aid Reporting Significant Deficiency

Other Findings in this Audit

  • 1179152 2025-001
    Material Weakness Repeat
  • 1179153 2025-001
    Material Weakness Repeat
  • 1179154 2025-001
    Material Weakness Repeat
  • 1179156 2025-002
    Material Weakness Repeat
  • 1179157 2025-002
    Material Weakness Repeat
  • 1179158 2025-002
    Material Weakness Repeat
  • 1179159 2025-002
    Material Weakness Repeat
  • 1179160 2025-003
    Material Weakness Repeat
  • 1179161 2025-003
    Material Weakness Repeat
  • 1179162 2025-003
    Material Weakness Repeat
  • 1179163 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $57.12M
84.063 FEDERAL PELL GRANT PROGRAM $669,945
93.213 Acupuncture for Medicare Beneficiaries with Chronic LowBack Pain; Access,Utilization, and Outcomes Addressing Dose Effects for cLBP $622,173
84.033 FEDERAL WORK-STUDY PROGRAM $420,330
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $23,724
93.213 Spinal Manipulative Therapy vs. Prescription Drug Therapy for Care of Aged Medicare Beneficiaries with Neck Pain $19,344
93.279 Integrated Care for Chronic Pain and Opioid Use Disorder $13,867
93.213 RAND REACH Center $8,715