Finding 1204632 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-30
Audit: 396382
Organization: Pacific Union College (CA)

AI Summary

  • Core Issue: Enrollment status updates for students were not reported accurately or within required timeframes to the NSLDS.
  • Impacted Requirements: Institutions must report enrollment changes within 30 days and certify enrollment every 60 days, as per 34 CFR 682.610.
  • Recommended Follow-Up: Review and improve policies for timely and accurate reporting of enrollment information to NSLDS.

Finding Text

Federal Program – Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268. Program Year – July 1, 2024 – June 30, 2025 Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the National Student Loan Data System (NSLDS) sends a Roster file to the school or its third-party servicer. 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. Condition – NSLDS did not reflect that proper status for certain students, or the status update was not made within the proper timeframe. Questioned Costs – None Context – Of the 25 students selected for testing, the following exceptions were identified: • No status update was made for four students • Nine students were reported as separated from the College, but not within the required timeframe • Six students were reported with incorrect status changes. Our sample was not intended to be statistically valid. Cause – The College experienced turnover in the Registrar’s office during the year, which could have contributed to the exceptions in the testing Effect – Status changes were not properly reported to NSLDS. Identification as a Repeat Finding – N/A Recommendation – We recommend that the College review its policies and procedures around reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Views of Responsible Officials and Planned Corrective Action – Pacific Union College transmits enrollment information to NSDLS through the National Student Clearinghouse (NCS), a third-party organization. PUC was faced with an unprecedented series of events related to data reporting to the National Student Clearinghouse between January and May 2025. During the month of February 2025, the College Registrar resigned without notice and the Director of Institutional Research tragically passed away within one ten day period. At that time the Director of College Admissions was asked to serve as the emergency Registrar and emergency IR Director. The above events led to some gaps in reporting to the NSC during the months noted above including some gaps in reporting that had occurred before the Registrar resigned. Communication with the NSC began immediately and during this time a series of reporting deadlines were “forgiven” by the NSC liaisons in support of PUC during a difficult series of one time events. Since the above dates PUC has been consistent and timely with all reporting to the NSC and the college anticipates that current staffing levels and cross training will prevent any such occurrences in the future.

Corrective Action Plan

Finding: 2025-001 CFDA #: 84.063 and 84.268 Recommendation: We recommend the College monitor and evaluate the schedule reporting dates to the NSLDS and confirm or modify existing policies, procedures, or processes from timely identification to ensure that status changes can be communicated to the NSLDS within the regulatory timeframes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding Corrective Action Plan: All graduate and withdrawn student files will be reviewed on a monthly basis to verify any status changes are reported to NSLDS within regulatory timeframes. Training and professional development will be required for responsible staff to ensure a compliance schedule is developed. Personnel will be evaluated to ensure existing policies, procedures, and processes are followed and supported through corrective action where needed. Name of Contact Responsible for Corrective Action: Joy Hirdler, Vice President of Financial Administration, Chief Financial Officer, 707-965-6699 Anticipated Completion Date: March 31, 2026

Categories

Student Financial Aid Special Tests & Provisions

Other Findings in this Audit

  • 1204631 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $4.56M
84.063 FEDERAL PELL GRANT PROGRAM $2.08M
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $1.16M
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $363,948
93.264 NURSE FACULTY LOAN PROGRAM (NFLP) $188,029
84.033 FEDERAL WORK-STUDY PROGRAM $107,332