Finding 1186723 (2025-002)

Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: P063P241233 and P268K251233 – all grants were awarded within 2024-2025 Award Period: 7/1/2024 – 6/30/2025 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Assistance programs must have an arrangement to report student enrollment data to the National Students Loan Data System (NSLDS) through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610). A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303). Condition: Certain students’ enrollment information was not reported accurately and timely to the NSLDS. Questioned Costs: N/A Context: During the testing of enrollment status submissions, the following was noted: • 1 student out of a sample of 60 students tested was reported with the incorrect enrollment status and effective date at both the campus and program levels. • 1 student out of a sample of 60 students tested were reported with incorrect enrollment status. • 1 student out of a sample of 60 students tested was not certified every 60 days. • 2 students out of a sample of 60 students reported were reported outside the 30 or 60 day window. • 4 students out of a sample of 60 students tested were reported as a withdrawal status at both the campus and program levels but was graduated per Institution’s record, and student status was never subsequently updated. Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. Occasionally, the third-party servicer incorrectly communicates information to the NSLDS which results in discrepancies between the University's system and the NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. The Department responsible for NSLDS reporting at the University experienced turnover at a senior level. Effect: Incorrect reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin. Repeat Finding: Yes, 2024-003. Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.