Finding Text
Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2025 Criteria Under the Federal Pell Grant Program and U.S. Department of Education (“ED”) loan programs, institutions are required to report accurate and timely student enrollment information to the National Student Loan Data System (“NSLDS”) (OMB No. 1845‑0035). The administration of Title IV programs relies on the precision and promptness of the enrollment data certified by institutions, as this information directly affects loan servicing, deferment, and repayment status determinations. Institutions are responsible for reviewing, updating, and validating enrollment statuses, effective dates, and related program‑level details appearing on the Enrollment Reporting Roster or the Enrollment Maintenance page of the NSLDS Professional Access website. NSLDS treats the data certified on these rosters as the institution’s official and most current enrollment information. Federal requirements mandate accurate reporting of both campus‑level and program‑level enrollment data, including but not limited to enrollment status, enrollment status effective date, program begin date, published program length, and Classification of Instructional Program (“CIP”) code. The NSLDS Enrollment Reporting Guide further requires institutions to report all enrollment status changes within the required 60‑day timeframe and to ensure that all reported statuses and effective dates reflect the institution’s official records. Condition During our testing of the Institution’s NSLDS Enrollment Reporting, we selected and tested a sample of 40 students and identified multiple instances of noncompliance with federal reporting requirements. Specifically, 27 students had enrollment status changes that were not reported to NSLDS within the required 60‑day timeframe, 33 students had enrollment status effective dates reported to NSLDS that did not correspond to the effective dates maintained in the Institution’s official records, and 6 students had enrollment statuses reported inaccurately. These exceptions collectively indicate deficiencies in the Institution’s processes for ensuring the accuracy and timeliness of enrollment information submitted to NSLDS. Cause These exceptions resulted from weaknesses in the Institution’s internal controls over the enrollment reporting process, including delays in updating student records, insufficient review of enrollment status changes prior to submission, and inadequate reconciliation procedures between the Registrar’s system and NSLDS reporting files. Effect Inaccurate or untimely enrollment reporting may result in incorrect loan servicing actions, inappropriate deferment or repayment status assignments, and delays or errors in borrower notifications. These conditions increase the risk of noncompliance with Title IV program requirements and may adversely affect students’ loan repayment obligations. Questioned Costs Not applicable. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 27 students (67.5% of the sample) had enrollment status changes that were not reported to NSLDS within the required 60‑day timeframe, 33 students (82.5% of the sample) had enrollment status effective dates that did not agree with the Institution’s official records, and 6 students (15% of the sample) had enrollment statuses reported inaccurately. The results of our testing cannot be projected to the population; however, the frequency of exceptions identified within the sample indicates notable weaknesses in the Institution’s enrollment reporting processes. Identification as a Repeat Finding, if applicable 2024-001 Recommendation We recommend that the Institution strengthen its internal controls over NSLDS Enrollment Reporting by implementing enhanced review and reconciliation procedures, ensuring timely updates of enrollment status changes, and establishing supervisory oversight to verify the accuracy of reported statuses and effective dates. The Institution should also consider periodic monitoring to confirm that all required reporting is completed within the mandated 60‑day timeframe. View of Responsible Officials The Company agrees with the finding.