Finding 1190947 (2025-002)

Finding 2025-002: NSLDS Reporting Federal Agency U.S. Department of Education Federal Program Student Financial Assistance Cluster (ALN # 84.268, 84.063) Federal Award Year July 1, 2024 through June 30, 2025 Federal Award Numbers P063P241963; P268K251963; P268K256998; P268K256953; P268K258670; P268K256952 Criteria or Requirement Per Sections 34 CFR 690.83(b)(2) and 34 CFR 685.309, a school shall update the student status confirmation report for changes in student status, report the date the enrollment status was effective and return the student status confirmation report to the Secretary within 30 days unless it plans to submit an enrollment report within the next 60 days of receipt. Per Sections 4.4.2 through 4.4.4 of the NSLDS enrollment reporting guide, institutions are responsible for accurately reporting all Campus-Level Record data elements and considers certain data elements to be high risk including OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. Per Section 4.4.8 of the NSLDS enrollment reporting guide, institutions are responsible for accurately reporting all Program-Level Record data elements and considers certain data elements to be high risk including OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides 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 For 22 out of the 520 data elements tested across a sample of 40 students, the data element was not reported accurately. The data elements not reported accurately included the student's enrollment status, OPEID number, program-level effective date, and the published program length. There were no exceptions related to the timeliness of NSLDS reporting identified. • For 1 out of 40 students, the student’s status was inaccurately reported as Withdrawn while studying abroad rather than Full-time at both the Campus-Level Record and the Program-Level Record. • For 8 out of 40 students, the incorrect OPEID Number was reported. • For 2 out of 40 students who had a status change from Withdrawn to Full-time, the effective date of the status change was not reported accurately within the Program-Level Record. The effective date was reported as 7/5/2022 rather than 2/10/2025. • For 7 out of 40 students, the effective date for the Graduated status reported to NSLDS at the Program-Level Record did not match the Campus-Level Record by 1-9 days. • For 2 out of 40 students, the effective date for the Half-time status reported to NSLDS at the Program- Level Record did not match the Campus-Level Record by 23-49 days. • For 1 out of 40 students, the Published Program Length was reported at 1.5 years rather than 1.1 years. Possible Cause and Asserted Effect The control that management reviews all reports for the accuracy of all data elements prior to submission was not operating at a level to ensure that enrollment status, enrollment effective date, published program length, and OPEID number were accurately and consistently reported to NSLDS. Questioned Costs None identified. Sampling The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the control around the review of accuracy of the enrollment statuses, program level data records, and campus level data records within the NSLDS reporting submissions. Views of Responsible Officials The University agrees with the finding and recommendation to enhance the precision of the control around the review of accuracy of the enrollment statuses, program level data records, and campus level data records within the NSLDS reporting submissions. To further strengthen oversight and prevent recurrence, the Office of Student Financial Aid will implement documented post-submission reconciliation procedures following National Student Clearinghouse reporting cycles. These reviews will focus on high-risk enrollment reporting elements, including campus changes, program status changes, and other updates affecting NSLDS reporting, and will validate the accuracy of OPEID assignments and program-level effective dates against institutional records.