Finding 1191138 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-27
Audit: 395313
Organization: Antioch University (OH)
Auditor: RSM US LLP

AI Summary

  • Core Issue: The University inaccurately reported withdrawal dates for several students, violating federal regulations.
  • Impacted Requirements: Compliance with 34 CFR 685.309(b) and FSA Handbook guidelines for timely and accurate enrollment reporting.
  • Recommended Follow-Up: Review and improve current procedures to ensure all enrollment status changes are reported correctly and promptly.

Finding Text

Finding 2025-001 Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.033, 84.007, 84.379, 84.268 Federal Agency: Department of Education Award Year: 2025 Criteria: The University is required to ensure proper controls are present to report enrollment information accurately and on a timely basis as required through specific regulations at 34 CFR 685.309(b). Condition: During the course of our special tests and provisions, we identified 3 students from our sample of 25 whose withdraw date was reported to National Student Loan Data System (NSLDS) as the day after the withdraw began. We also identified 2 students whose withdraw date was reported as the end of the semester in which the student was attending and 1 student whose withdraw date did not correlate with the last date of attendance. Cause: Administrative oversight by personnel in reporting the status accurately and timely did not operate as designed. Context: Controls did operate properly for the University to notify NSLDS accurately and within the required time frame. Effect: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to report enrollment status changes accurately and timely. Questioned Costs: None Repeat Finding: Yes Recommendations: The University should evaluate sufficiency of current procedures to ensure that all status changes are reported in a timely and accurate manner for students who receive federal loans. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan on pages 40-41.

Corrective Action Plan

Corrective Action Taken or Planned: A. Correction of "Day After" Reporting Logic The University previously identified a practice where the withdrawal (W) status was made effective the day following the student's notification. ● Process Update: This process was officially updated in April 2025 to align with the regulation, ensuring the withdrawal start date and the date of official notification are the same. The three findings all occurred prior to the April adjustment. ● Ongoing Diligence: The Registrar’s team is actively monitoring current and future records to ensure this logic is applied consistently going forward. B. Reporting Withdrawal Dates for Late-Term Requests To address students reported as withdrawn on the last day of the term rather than their actual date of request: ● Manual Tracking: For students who request a withdrawal between the official University withdrawal deadline and the end of the term, the Financial Aid Office will create a new process where they track students needing NSC manual corrections and share that information with the RO Team member doing the NSC reporting. ● NSC Overrides: The NSC reporting processor will utilize this information to perform manual date changes for these students, ensuring the reported date reflects the official date of notification rather than the term end date. C. Correlation of Withdrawal Date and Last Date of Attendance (LDA) To address findings where withdrawal dates did not correlate with the LDA: ● Faculty LDA Requirement: Although the University is a non-attendance-taking institution, a new requirement has been implemented for faculty to enter the Last Date of Attendance (LDA) for any student receiving a non-passing grade. ● Reporting Sync: The latest of the reported LDAs will be used by both the Financial Aid office (for calculations) and the NSC processor (for reporting) if a student is withdrawing from the University for the subsequent term and the student received all non-passing grades in the prior term. The Financial Aid office will notify the Registrar’s office if there are students with no passing grades and a LDA prior to the official withdrawal date to update their withdrawal date to match that LDA. ● Verification Workflow: The Registrar’s office will verify withdrawal information with the student, including the notification date, to ensure accuracy before manual NSC corrections are made. D. Internal Audit and Collaborative Controls To prevent recurrence and ensure compliance with federal reporting timelines: ● Collaborative Review: The Registrar and the Executive Director of Financial Aid & Scholarships will meet on a recurring basis to jointly review enrollment reporting procedures and ensure data alignment. ● Spot Checks: An internal audit process has been implemented to spot-check each submission file to verify that enrollment and withdrawal dates are accurate. The shared spreadsheet of manual dates will also be checked to ensure those dates are being changed. ● Petition and Request Review: The Registrar Team will carefully review all petitions and requests to determine which date to use as the original notification. ________________________________________ Person(s) Responsible for Corrective Action: University Registrar and Executive Director of Financial Aid & Scholarships. ________________________________________ Anticipated Completion: June 30, 2026 ________________________________________

Categories

Special Tests & Provisions Student Financial Aid Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1191134 2025-001
    Material Weakness Repeat
  • 1191135 2025-001
    Material Weakness Repeat
  • 1191136 2025-001
    Material Weakness Repeat
  • 1191137 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $65.75M
84.033 FEDERAL WORK-STUDY PROGRAM $1.15M
84.063 FEDERAL PELL GRANT PROGRAM $748,200
93.191 GRADUATE PSYCHOLOGY EDUCATION $423,024
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $375,123
93.732 MENTAL AND BEHAVIORAL HEALTH EDUCATION AND TRAINING GRANTS $319,644
94.013 AMERICORPS VOLUNTEERS IN SERVICE TO AMERICA 94.013 $80,909
66.950 NATIONAL ENVIRONMENTAL EDUCATION TRAINING PROGRAM $65,371
10.684 INTERNATIONAL FORESTRY PROGRAMS $53,591
47.083 INTEGRATIVE ACTIVITIES $43,583
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $15,088
15.945 COOPERATIVE RESEARCH AND TRAINING PROGRAMS – RESOURCES OF THE NATIONAL PARK SYSTEM $7,893
93.104 COMPREHENSIVE COMMUNITY MENTAL HEALTH SERVICES FOR CHILDREN WITH SERIOUS EMOTIONAL DISTURBANCES (SED) $3,364
11.431 CLIMATE AND ATMOSPHERIC RESEARCH $1,703