Finding Text
Finding 2025-003 – Special Test and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance (See table in "Schedule of Findings and Questioned Costs"). Criteria – 34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/Context – Out of a population of approximately 1,000 student status changes and 230 permanent address changes, a sample of 74 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2024-2025 academic year. We believe this to be a representative sample although not a statistical sample. The enrollment information and withdrawal, address change, or graduation date per the University’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Questioned Costs – None. Effect – Although the University generally reported enrollment status changes to NSLDS accurately, it did not fully comply with timeliness requirements for two batches of students that graduated in May and June 2025, which were reported 30 days and 4 days, respectively beyond the 60-day requirement noted in the criteria above. In addition, we noted four other withdrawn students whose status change was not reported timely. Cause – The cause was due to no internal controls in place to report enrollment status changes within a timely manner, no internal controls related to review of effective dates, and unofficially withdrawn students Repeat Finding – Not a repeat finding. Recommendation – We recommend the University to establish a formal policy requiring a review of student status information submitted to the NSLDS, by a third-party intermediary on the University’s behalf, for completeness and accuracy. We also recommend the University establish a cadence of monitoring reporting deadlines, particularly those around classes of graduating students. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the finding. See the corrective action plan for further detail.