Finding 1201384 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-30
Audit: 395962
Organization: Southern Oregon University (OR)

AI Summary

  • Core Issue: The university failed to report student enrollment changes accurately and on time to the NSLDS, leading to significant deficiencies in internal controls.
  • Impacted Requirements: Compliance with 34 CFR 685.309 and 34 CFR 690.83 mandates accurate and timely reporting of enrollment information.
  • Recommended Follow-Up: Enhance policies and monitoring of third-party services to ensure accurate and timely enrollment reporting.

Finding Text

Special Tests – Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ASSISTANCE LISTING Number: 84.268 – Federal Direct Student Loans 84.063 – Federal Pell Grant Program Federal Award Identification: Various Award Period: June 1, 2024 to June 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). 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 Professional Access (NSLDSFAP) website. 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 must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, you may provide the updated data on that roster file. The University must also have an adequate process to internally review submissions to either the third-party servicer or directly to NSLDS. Additionally, Institutions are required to ensure adequate internal controls over compliance are established and maintained in accordance with 2 CFR 200.303. Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 student enrollment changes to test for timeliness and accurate reporting of student status changes to the National Student Loan Data System (NSLDS). Our testing resulted in the following items of noncompliance. 1. 1 student enrollment changes where the enrollment status effective date was not correctly reported to NSLDS. 34 CFR 685.309 (b)(1) and 34 CFR 690.83(b)(2) 2. 5 instances where a student’s enrollment status change was not reported timely to NSLDS. 34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2) 3. 1 student enrollment change where status change was not reported to NSLDS. 34 CFR 685.309(b)(1) and 34 CFR 690.83(b)(2) Questioned costs: N/A Context: Out of a sample of 40 enrollment changes selected for testing for the requirement noted above, we noted 6 students with exceptions. 1 student had multiple instances of noncompliance. Cause: The university was unaware of the errors which were caused by the transmission of date between their student information system and the third-party servicer. Effect: The NSLDS system could not be updated accurately or timely with student enrollment information. Repeat finding: Yes 2024-001 Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.

Corrective Action Plan

Special Tests - Enrollment Reporting Federal Direct Student Loans and Federal Pell Grant Program - Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: New registrar hired 9/2025 has enhanced policies and procedures regarding enrollment reporting by initiating regular and frequent (weekly/biweekly) contact with the National Student Clearinghouse (NSC) to ensure that reporting is completed accurately and timely. Names of the contact person responsible for corrective action: Jennifer Bratz Planned completion date for corrective action plan: Correction action plan involves ongoing regular communication with NSC and regular monitoring of reports for timeliness and accuracy, no completion date.

Categories

Student Financial Aid

Other Findings in this Audit

  • 1201383 2025-002
    Material Weakness Repeat
  • 1201385 2025-003
    Material Weakness Repeat
  • 1201386 2025-003
    Material Weakness Repeat
  • 1201387 2025-003
    Material Weakness Repeat
  • 1201388 2025-003
    Material Weakness Repeat
  • 1201389 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $16.41M
84.063 FEDERAL PELL GRANT PROGRAM $7.00M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $652,755
84.033 FEDERAL WORK-STUDY PROGRAM $438,090
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $404,871
84.042 TRIO STUDENT SUPPORT SERVICES $382,465
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $361,934
84.217 TRIO MCNAIR POST-BACCALAUREATE ACHIEVEMENT $261,204
84.425 EDUCATION STABILIZATION FUND $239,056
93.667 SOCIAL SERVICES BLOCK GRANT $146,257
15.945 COOPERATIVE RESEARCH AND TRAINING PROGRAMS – RESOURCES OF THE NATIONAL PARK SYSTEM $98,883
15.224 CULTURAL AND PALEONTOLOGICAL RESOURCES MANAGEMENT $94,274
15.611 WILDLIFE RESTORATION AND BASIC HUNTER EDUCATION AND SAFETY $60,535
93.224 HEALTH CENTER PROGRAM (COMMUNITY HEALTH CENTERS, MIGRANT HEALTH CENTERS, HEALTH CARE FOR THE HOMELESS, AND PUBLIC HOUSING PRIMARY CARE) $59,961
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $45,676
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $33,171
10.310 AGRICULTURE AND FOOD RESEARCH INITIATIVE (AFRI) $31,438
47.078 POLAR PROGRAMS $24,833
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $10,060
47.083 INTEGRATIVE ACTIVITIES $8,030
84.011 MIGRANT EDUCATION STATE GRANT PROGRAM $7,600
15.233 FOREST AND WOODLANDS RESOURCE MANAGEMENT $5,409
47.070 COMPUTER AND INFORMATION SCIENCE AND ENGINEERING $2,361
43.001 SCIENCE $13