Finding 1186663 (2025-001)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-03-25
Audit: 394364
Organization: Regent University (VA)
Auditor: KPMG LLP

AI Summary

  • Core Issue: Regent failed to report student enrollment status changes accurately and within the required 60 days to the NSLDS, leading to a material weakness in compliance.
  • Impacted Requirements: Compliance with federal regulations for enrollment reporting under Title IV programs, specifically the accuracy and timeliness of data submitted to the NSLDS.
  • Recommended Follow-Up: Enhance internal controls to ensure timely and accurate reporting of enrollment changes, and address data transmission issues with the National Student Clearinghouse.

Finding Text

(1) Summary of Auditors’ Results Financial Statements a. Type of report issued on whether the financial statements were prepared in accordance with generally accepted accounting principles: Unmodified b. Internal control deficiencies over financial reporting disclosed by the audit of the financial statements: • Material weaknesses: No • Significant deficiencies: No c. Noncompliance material to the financial statements: No Federal Awards d. Internal control deficiencies over major programs disclosed by the audit: • Material weaknesses: Yes • Significant deficiencies: No e. Type of report issued on compliance for major programs: Qualified f. Audit findings that are required to be reported in accordance with 2 CFR 200.516(a): Yes g. Major programs: • Student Financial Assistance Cluster – Various ALNs h. Dollar threshold used to distinguish between Type A and Type B programs: $750,000 i. Auditee qualified as a low-risk auditee: No (2) Findings Relating to the Financial Statements Reported in Accordance with Government Auditing Standards None (3) Findings and Questioned Costs Relating to Federal Awards Finding Number: 2025-01 Program: Student Financial Assistance Cluster ALN #: 84.063 and 84.268 Federal Award #’s: P063P235372, P268K225372 Federal Award Years: July 1, 2024 to June 30, 2025 Federal Agencies: U.S. Department of Education Pass-Through Entity: N/A – Direct Award Compliance Requirement: Enrollment Reporting Finding Type: Material Weakness and Material Noncompliance Criteria: Under the Pell grant and the Direct and Federal Family Education Loan programs, institutions are required to report enrollment information via the National Student Loan Data System (NSLDS) (OMB No. 845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions 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 Financial Aid Professionals (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS within 15 days. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition found: During our testwork over student enrollment reporting, we noted Regent did not report all students' status changes accurately or within the required 60 days. For a sample of 60 students who were recipients of Direct Loans or Pell Grants between July 1, 2024 and June 30, 2025 and that had been identified as having withdrawn, graduated, or modified their enrollment status as defined by Regent’s Satisfactory Academic Progress Policy through a change in course load, the following was noted: For 24 students out of the 60 selected for compliance testing, Regent did not transmit the students’ status change to NSLDS within 60 days. For 9 students out of the 60 selected for compliance testing, Regent did not transmit the students’ status change to NSLDS within 60 days and failed to report the correct effective date of the status change. For 2 students out of the 60 selected for compliance testing, Regent failed to report the correct effective date of the status change. For 2 students out of the 60 selected for compliance testing, Regent failed to report the proper status to NSLDS. Additionally, while Regent has controls in place to ensure that enrollment changes are reported timely to the National Student Clearinghouse (NSC), the control does not ensure that any required correspondence with NSC to resolve data matters is happening accurately and timely. Cause: For the students noted above, management communicated that there were delays in the data transmission from the NSC and the NSLDS. While the data was provided to the NSC in a timely manner, there were issues with the data that needed to be resolved between Regent and the NSC in order to proceed with the submission to NSLDS. For the reasons noted above, we determined the related control in place at Regent, which is designed to address the accuracy and timeliness of the transmission reports, is not designed at a sufficient level to verify the accuracy and timeliness of the data transmission to the NSC. Nor does Regent have a control to ensure that any subsequent issues are resolved timely and that the data is ultimately submitted to the NSLDS timely. Proper perspective: Regent’s policy is to submit enrollment data to the NSC on a predetermined schedule that allows Regent to comply with the enrollment reporting requirements. For our sample of 60 students with status changes, we identified 37 students where either the status change was not reported within 60 days, improper status was reported, or the effective date was not accurately reported which indicates a systemic issue. Possible asserted effect: Untimely submission of student enrollment information affects the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, graces periods, and repayment schedules, as well as the federal government’s payment and interest schedules. Questioned costs: None noted. Statistical sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat finding: A similar finding was reported in the prior year. The prior year finding number was 2024-001 Recommendation: We recommend Regent evaluate its processes and procedures when submitting data to the NSC to mitigate the number of errors in data transmissions in order to expedite the accuracy and timeliness of the NSLDS enrollment reporting. Views of responsible officials: Regent agrees with this finding. Regent intends to strengthen its controls and quality assurance measures over the timeliness of enrollment information to NSLDS.

Corrective Action Plan

Regent University agrees with this finding. The University will engage with the National Student Clearinghouse audit support office to further understand the analyst processing timelines to strategize effective submission and error resolution dates to ensure output is captured in the monthly NSC batches. The University will continue to engage the established working group with appropriate Regent stakeholders to review suggested changes made by the NSC to reporting methods, time buffers between reports, reporting frequency, and other “upstream” preventative measures that may be taken to prevent file backlogs. Internally, the University will establish a customized and shared enrollment reporting tracker available to all stakeholders in the working group. This will transparently represent the dates to maintain the 60-day compliance window and allow us to manually intervene where possible. Regent University will implement the plan by June 30, 2026. Name of responsible parties: Elizabeth Bayless (University Registrar) & Tameka Lyons (Senior Associate Registrar)

Categories

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1186662 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $121.21M
84.063 FEDERAL PELL GRANT PROGRAM $18.46M
84.033 FEDERAL WORK-STUDY PROGRAM $287,254
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $83,912