Finding Text
Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification Number and Year: P268K252058-2025, P063P242058-2025, P007A253479-2025, P033A253479-2025, P379T262058-2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Compliance, Other Matter Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to ensure reasonable compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the University did not report the effective date and enrollment status correctly or timely. In addition, the University did not have a control in place to ensure timely and accurate reporting to NSLDS. Questioned costs: None Reported. Context: During our testing, we noted that the enrollment effective date of 6 of the 60 students tested was not reported correctly to NSLDS. We also noted that the change in enrollment status of 3 of the 60 students tested was not reported timely to NSLDS. We also noted the program enrollment effective date of 2 of the 60 students tested did not match the enrollment effective date. Additionally, we did not note evidence of a key control occurring for enrollment reporting. Cause: The University did not have proper controls or procedures in place to verify students' status in NSLDS matched the institution’s records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2024-002. Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status, and effective dates within NSLDS match the records of the institution and are reported timely, and to store evidence of the key control having occurred. View of Responsible Official: There is no disagreement with the audit finding.