Finding 1181872 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-23

AI Summary

  • Core Issue: Significant deficiencies in internal controls over compliance with federal reporting requirements for student enrollment status changes.
  • Impacted Requirements: Enrollment status changes must be reported to NSLDS within 30 or 60 days, and schools must certify enrollment every 60 days.
  • Recommended Follow-Up: Universities should revise their reporting procedures to ensure timely updates to NSLDS as mandated by federal regulations.

Finding Text

Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2023-24 and 2024-25 award years. Award Period: July 1, 2024, through June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria The Code of Federal Regulations, consisting of 2 CFR 200.303, 34 CFR 685.309, and 34 CFR 690.83(b)(2), requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Additionally, schools are required to certify enrollment at a minimum of every 60 days or every other month. Condition and Context During our testing of NSLDS Enrollment Reporting on the State System, we noted: 1) Status change received by NSLDS was outside of the 60-day time frame.• Cheyney University (P268K242131, P268K252131, P063P232131, and P063P242131): 1 of the 8 students tested for award year 2024-25 • Kutztown University (P268K242135, P268K252135, P063P232135, and P063P242135): 19 of the 27 students tested for award year 2024-25 2) Enrollment was not certified at a minimum of every 60 days or every other month. • Cheyney University (P268K242131, P268K252131, P063P232131 and P063P242131): 3 of the 8 students tested for award year 2024-25 Questioned costs: N/A Cause The Universities’ policies and procedures were not designed to ensure that student status changes were timely reported to NSLDS. Effect The NSLDS system is not updated with the student information which can cause over-awarding should the student transfer to another institution and the student may not properly enter the repayment period. Repeat Finding Cheyney University – Yes – Finding 2024-001 Kutztown University – Yes – Finding 2024-001 Recommendation The Universities should review their reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by Federal regulations. Views of Responsible Officials There is no disagreement with the audit finding.

Corrective Action Plan

2025-001 Student Financial Aid Cluster – Assistance Listing Numbers 84.063 and 84.268 In general, Cheyney University continues its trajectory of cross-functional and interrelated institutional improvements, particularly those impacting the National Student Loan Data System (NSLDS) that is reported through National Student Clearinghouse (NSC). Cited in the CLA Single Audit, nonetheless, are instances of inaccurate, late, or not reported enrollment and program level data to NSLDS. This response is intended to explain these reporting deficiencies and offer a corrective plan of action including timelines. Point Of Contact: • Dr. Denise Pearson, Provost – dpearson@cheyney.edu • Stephanie Stevens, Associate Registrar – sstevens@cheyney.edu • Jean Dixon, Associate Registrar – jedixon@cheyney.edu Explanations: This section represents Cheyney University’s effort to explain the causes for CLA Single Audit finding. Although the reporting deficiencies span multiple years, it is instructive to note that they are attributed to various and differing circumstances. While Cheyney University was on HCM2, the delay in Claims processing impacted the reporting in Common Origination and Disbursement (COD) and the reporting to NSLDS. The delays in approved claims caused an impact on NSLDS postings for enrollment reporting. This required Cheyney University administration to transfer from NSC to manual enrollment entry into NSLDS. The idea was to manually enter students’ records in NSLDS so that students’ enrollment could be reported more quickly. This is referenced in Single Audit Report, June 30, 2022; page 132. Cheyney is acutely focused on working toward compliance with NSLDS reporting requirements. Through this lens, it was discovered that during the 2024-2025 conversion to the Ellucian Banner system certain decisions were made regarding the conversion of student academic histories. During the research of errors and warning records received from the NSC upload, it was determined that program level information was not properly ported over to the new system. Cheyney University is pursuing a corrective course of action to improve this data to ensure accuracy in reporting. In May 2025, Cheyney University and NSC amended its agreement resulting in a shift in reporting student enrollment and program level data back to NSC from NSLDS that resulted in an additional delay in reporting. Due to these circumstances, the university dedicated significant resources to building capacity and capability in the Office of the Registrar, the functional area responsible for NSLDS reporting. These resources are being deployed in a variety of ways as noted in the Corrective Action Plan below. Corrective Action Plan Overview: 1. Hired a season University Registrar with superior, proven, leadership and technical skills. Emphasis has been placed on performance metrics that align with operational goals and objectives. STATUS: Anticipated March 2026. 2. Targeted professional development for Office of the Registrar and other staff including Banner training, NSC/NSLDS Reporting, and other dependencies. STATUS: Ongoing 3. Establishment of a dedicated compliance unit to support the university’s policies, standards, and procedures ecosystem. STATUS: Completed December 2025. 4. Hired a dedicated Chief Information and Technology Officer (as opposed to the use of third-party vendors). STATUS: Completed, March 2026. 5. Prioritized strengthening communication and collaboration with other enrollment management areas to establish cross-functional responsibilities and timelines (e.g., financial aid, admissions, and bursar offices). STATUS: Ongoing. Key Performance Indicators: During the Spring and Fall 2026 semesters: 1. The University Registrar will show outcomes-driven leadership practices that foster improved departmental performance, including audit citations. 2. Registrar and adjacent staff will demonstrate comprehensive capability and capacity in all areas related to NSC and NSLDS operations and reporting on a timely schedule. An organizational calendar is being developed to ensure this goal is met. 3. Utilizing the NSLDS instructional guide, train the Registrar and adjacent staff to improve the knowledge of the step-by-step process procedures for enrollment reporting, error correction, warning management, and internal audit review of NSLDS files. 4. Develop NSC instructional guide on reporting, error and warning management, and submission of monthly reporting data. 5. The Director of Policy and Compliance will collaborate with the Office of the Provost and Registrar Office staff to create and maintain a policy, procedures, and standards environment that supports operational excellence and efficiency (including more timely and accurate reporting). 6. The Chief Information and Technology Officer will conduct a comprehensive assessment of technology needs in the Office of the Registrar, including outcomes driven recommendations. 7. The Provost will establish Office of the Registrar protocols for collaboration with the Office of Communications to reinforce clarity, consistency, and transparency in all related matters. 8. The University Registrar will demonstrate that all staff have the requisite knowledge and skills to effectively mitigate future reporting deficiencies. Cheyney University acknowledges and affirms that this corrective action will be implemented, assessed, and become a standard operating procedure.

Categories

Student Financial Aid Reporting Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1181870 2025-001
    Material Weakness Repeat
  • 1181871 2025-002
    Material Weakness Repeat
  • 1181873 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $448.88M
84.063 FEDERAL PELL GRANT PROGRAM $153.48M
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $8.78M
84.033 FEDERAL WORK-STUDY PROGRAM $5.21M
93.917 HIV CARE FORMULA GRANTS $4.60M
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $3.99M
84.011 MIGRANT EDUCATION STATE GRANT PROGRAM $2.86M
17.504 CONSULTATION AGREEMENTS $1.04M
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $758,235
21.031 STATE SMALL BUSINESS CREDIT INITIATIVE TECHNICAL ASSISTANCE GRANT PROGRAM $733,936
93.191 GRADUATE PSYCHOLOGY EDUCATION $646,495
12.902 INFORMATION SECURITY GRANTS $618,451
84.407 TRANSITION PROGRAMS FOR STUDENTS WITH INTELLECTUAL DISABILITIES INTO HIGHER EDUCATION $601,616
12.905 CYBERSECURITY CORE CURRICULUM $574,713
84.149 MIGRANT EDUCATION COLLEGE ASSISTANCE MIGRANT PROGRAM $542,401
84.047 TRIO UPWARD BOUND $535,318
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $525,315
84.044 TRIO TALENT SEARCH $513,945
93.732 MENTAL AND BEHAVIORAL HEALTH EDUCATION AND TRAINING GRANTS $455,088
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $414,722
84.042 TRIO STUDENT SUPPORT SERVICES $408,827
11.008 NOAA MISSION-RELATED EDUCATION AWARDS $344,808
84.031 HIGHER EDUCATION INSTITUTIONAL AID $340,726
93.364 NURSING STUDENT LOANS $329,608
16.540 JUVENILE JUSTICE AND DELINQUENCY PREVENTION $308,531
12.002 PROCUREMENT TECHNICAL ASSISTANCE FOR BUSINESS FIRMS $277,535
84.325 SPECIAL EDUCATION - PERSONNEL DEVELOPMENT TO IMPROVE SERVICES AND RESULTS FOR CHILDREN WITH DISABILITIES $269,878
93.247 ADVANCED NURSING EDUCATION WORKFORCE GRANT PROGRAM $234,572
19.408 ACADEMIC EXCHANGE PROGRAMS - TEACHERS $231,127
47.074 BIOLOGICAL SCIENCES $229,512
12.006 NATIONAL DEFENSE EDUCATION PROGRAM $221,925
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $198,118
84.264 REHABILITATION TRAINING TECHNICAL ASSISTANCE CENTERS $196,524
16.550 STATE JUSTICE STATISTICS PROGRAM FOR STATISTICAL ANALYSIS CENTERS $191,236
93.600 HEAD START $179,986
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $177,608
84.215 INNOVATIVE APPROACHES TO LITERACY; PROMISE NEIGHBORHOODS; FULL-SERVICE COMMUNITY SCHOOLS; AND CONGRESSIONALLY DIRECTED SPENDING FOR ELEMENTARY AND SECONDARY EDUCATION COMMUNITY PROJECTS $153,427
93.275 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES-ACCESS TO RECOVERY $147,909
84.351 ARTS IN EDUCATION $123,248
12.300 BASIC AND APPLIED SCIENTIFIC RESEARCH $114,500
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $113,058
17.289 COMMUNITY PROJECT FUNDING/CONGRESSIONALLY DIRECTED SPENDING $111,452
12.357 ROTC LANGUAGE AND CULTURE TRAINING GRANTS $110,666
17.280 WIOA DISLOCATED WORKER NATIONAL RESERVE DEMONSTRATION GRANTS $106,601
17.502 OCCUPATIONAL SAFETY AND HEALTH SUSAN HARWOOD TRAINING GRANTS $84,658
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $77,880
10.558 CHILD AND ADULT CARE FOOD PROGRAM $77,333
10.001 AGRICULTURAL RESEARCH BASIC AND APPLIED RESEARCH $74,981
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $71,327
45.312 NATIONAL LEADERSHIP GRANTS $70,055
16.575 CRIME VICTIM ASSISTANCE $69,050
93.674 JOHN H. CHAFEE FOSTER CARE PROGRAM FOR SUCCESSFUL TRANSITION TO ADULTHOOD $67,500
12.740 PAST CONFLICT ACCOUNTING $67,098
15.946 CULTURAL RESOURCES MANAGEMENT $66,251
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $60,719
47.049 MATHEMATICAL AND PHYSICAL SCIENCES $60,152
45.313 LAURA BUSH 21ST CENTURY LIBRARIAN PROGRAM $54,481
93.599 CHAFEE EDUCATION AND TRAINING VOUCHERS PROGRAM (ETV) $53,816
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $53,044
47.075 SOCIAL, BEHAVIORAL, AND ECONOMIC SCIENCES $52,768
93.279 DRUG USE AND ADDICTION RESEARCH PROGRAMS $52,663
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $52,157
17.259 WIOA YOUTH ACTIVITIES $48,189
93.262 OCCUPATIONAL SAFETY AND HEALTH PROGRAM $47,299
15.945 COOPERATIVE RESEARCH AND TRAINING PROGRAMS – RESOURCES OF THE NATIONAL PARK SYSTEM $45,663
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $45,348
84.334 GAINING EARLY AWARENESS AND READINESS FOR UNDERGRADUATE PROGRAMS $42,742
84.425 EDUCATION STABILIZATION FUND $42,074
15.904 HISTORIC PRESERVATION FUND GRANTS-IN-AID $41,666
15.634 STATE WILDLIFE GRANTS $41,077
93.173 RESEARCH RELATED TO DEAFNESS AND COMMUNICATION DISORDERS $40,767
12.903 GENCYBER GRANTS PROGRAM $39,568
84.287 TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS $39,454
47.041 ENGINEERING $36,678
93.273 ALCOHOL RESEARCH PROGRAMS $35,885
66.708 POLLUTION PREVENTION GRANTS PROGRAM $33,732
47.083 INTEGRATIVE ACTIVITIES $31,469
23.002 APPALACHIAN AREA DEVELOPMENT $30,022
20.U04 LITTLE DANIELS RUN MITIGATION $28,332
10.310 AGRICULTURE AND FOOD RESEARCH INITIATIVE (AFRI) $27,105
15.815 NATIONAL LAND REMOTE SENSING EDUCATION OUTREACH AND RESEARCH $25,708
84.335 CHILD CARE ACCESS MEANS PARENTS IN SCHOOL $25,662
81.087 RENEWABLE ENERGY RESEARCH AND DEVELOPMENT $25,523
47.079 OFFICE OF INTERNATIONAL SCIENCE AND ENGINEERING $23,030
15.255 SCIENCE AND TECHNOLOGY PROJECTS RELATED TO COAL MINING AND RECLAMATION $20,931
45.162 PROMOTION OF THE HUMANITIES TEACHING AND LEARNING RESOURCES AND CURRICULUM DEVELOPMENT $18,996
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $18,100
47.050 GEOSCIENCES $15,463
45.025 PROMOTION OF THE ARTS PARTNERSHIP AGREEMENTS $13,750
81.123 NATIONAL NUCLEAR SECURITY ADMINISTRATION (NNSA) MINORITY SERVING INSTITUTIONS (MSI) PROGRAM $13,592
16.835 BODY WORN CAMERA POLICY AND IMPLEMENTATION $13,386
93.124 NURSE ANESTHETIST TRAINEESHIP $13,226
45.024 PROMOTION OF THE ARTS GRANTS TO ORGANIZATIONS AND INDIVIDUALS $13,000
47.070 COMPUTER AND INFORMATION SCIENCE AND ENGINEERING $11,237
15.662 GREAT LAKES RESTORATION $11,217
84.027 SPECIAL EDUCATION GRANTS TO STATES $10,939
64.034 VA GRANTS FOR ADAPTIVE SPORTS PROGRAMS FOR DISABLED VETERANS AND DISABLED MEMBERS OF THE ARMED FORCES $10,765
59.050 PRIME TECHNICAL ASSISTANCE $10,019
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $9,386
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $8,814
93.847 DIABETES, DIGESTIVE, AND KIDNEY DISEASES EXTRAMURAL RESEARCH $8,133
93.630 DEVELOPMENTAL DISABILITIES BASIC SUPPORT AND ADVOCACY GRANTS $7,777
43.001 SCIENCE $6,394
20.U01 WETLANDS MITIGATION PROJECT $6,307
10.912 ENVIRONMENTAL QUALITY INCENTIVES PROGRAM $5,766
43.008 OFFICE OF STEM ENGAGEMENT (OSTEM) $5,069
12.330 SCIENCE, TECHNOLOGY, ENGINEERING & MATHEMATICS (STEM) EDUCATION, OUTREACH AND WORKFORCE PROGRAM $4,992
14.241 HOUSING OPPORTUNITIES FOR PERSONS WITH AIDS $4,932
19.009 ACADEMIC EXCHANGE PROGRAMS - UNDERGRADUATE PROGRAMS $4,738
16.525 GRANTS TO REDUCE DOMESTIC VIOLENCE, DATING VIOLENCE, SEXUAL ASSAULT, AND STALKING ON CAMPUS $4,235
15.670 ADAPTIVE SCIENCE $3,218
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $2,966
10.699 PARTNERSHIP AGREEMENTS $2,923
12.005 CONSERVATION AND REHABILITATION OF NATURAL RESOURCES ON MILITARY INSTALLATIONS $1,620
10.902 SOIL AND WATER CONSERVATION $755
59.037 SMALL BUSINESS DEVELOPMENT CENTERS $660
81.049 OFFICE OF SCIENCE FINANCIAL ASSISTANCE PROGRAM $658
11.457 CHESAPEAKE BAY STUDIES $341