Finding 1204847 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-30
Audit: 396472
Organization: Gannon University (PA)

AI Summary

  • Core Issue: The University failed to notify the NSLDS on time for 3 students with status changes and reported 1 student with an incorrect effective date.
  • Impacted Requirements: Compliance with Title IV regulations requires timely updates to student enrollment information to maintain accurate Title IV loan records.
  • Recommended Follow-Up: Review and improve procedures for reporting student status changes and ensure regular checks are in place for timely updates to the NSLDS.

Finding Text

Finding 2025-001: Significant Deficiency - Student Status Changes Repeat of Prior Year Finding 2024-001 Assistance Listing: 84.268 Student Financial Assistance Cluster, Federal Direct Student Loans Federal Award Year: June 30, 2024 Federal Award Agency: U.S. Department of Education Criteria: Title IV regulations (34 CFR Section 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution 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 institution, 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 institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for 3 students with status changes in our sample of 25 students. Additionally, 1 student was reported with an inaccurate effective date. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The University's procedures for reporting all students were not designed appropriately in order to allow for timely reporting to the NSLDS. Effect or Potential Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update and verify student enrollment statuses, effective dates of the enrollment status and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Recommendations: We recommend that the University review its procedures for student status changes and NSLDS notifications to ensure there are follow-up and review procedures being performed for all students with status changes at the University. Management Response: Management concurs with the finding and the University will periodically perform independent reviews of the information provided to the NSLDS to ensure the status change information has been updated in the NSLDS during the required time period. The University has also hired a new Assistant Registrar with experience submitting enrollment and graduate files to NSC and NSLDS that will help with ensuring status on NSLDS are reported timely.

Corrective Action Plan

Finding 2025-001 Condition The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for four students with status changes. Corrective Action Plan 1. Finding: Incorrect Status Date Reported to NSC/NSLDS for a withdrawn student Corrective Actions: • Root Cause Analysis: A review was conducted to determine why NSC/NSLDS received the incorrect date despite Colleague displaying the correct withdrawal date of 3/20/2025. The analysis confirmed that the Colleague reporting process pulls the date from the course drop/withdrawal field rather than the student status withdrawal date screen. According to system documentation, “SITX determines the enrollment status, enrollment status start date, and the anticipated graduation date for the students included in the extract. If the enrollment status changes during the reporting period since the last census date, the status change date is calculated from schedule changes and hiatus record information.” • Process Improvement: o Staff have been instructed to ensure that all relevant screens reflect the correct status change date prior to reporting. o Documentation is being developed outlining the withdrawal process workflow, including all screens requiring updates. This will promote consistency and serve as a reference for future staff transitions. 2. Finding: Failure to Report Three Graduates to NSLDS Within the 60 Day Requirement Corrective Actions: • Root Cause Analysis: The University Registrar contacted the NSC to investigate the delay. Although the NSC Degree Verify file was submitted within the required timeframe, it was determined that the “G Not Applied” process on the NSC site was not completed promptly by Registrar’s Office staff, resulting in the late NSLDS reporting. • Process Redesign: The University Registrar is working with Gannon IT Services to develop a “Graduates Only” reporting process directly from Colleague. This enhancement will eliminate reliance on the NSC “G Not Applied” step, which has been a recurring compliance challenge. This new process will be implemented no later than July 1, 2026. Until then, the “G Not Applied” list will be processed within 10 days of processing availability (at times the G Not Applied cannot be updated while an Enrollment file submission is pending acceptance). • Proactive Audit Measures: Given the significant staffing transitions and shifts in reporting responsibilities over the past year, an internal audit of the 2025–2026 reporting completed to date is underway, in collaboration with the NSC Audit Department, to determine the full extent of any additional reporting deficiencies that may have carried into the new academic year. 3. As previously stated in the Summary Schedule of Prior Audit Findings for the Year-Ended June 30, 2024 Update, the following corrective actions are being initiated: • Additional staff have been designated to ensure that at least three individuals possess the knowledge and system access required to submit reports and process corrections. • All designated staff are required to complete NSC-provided training to ensure full understanding of reporting requirements and procedures. • Each staff member must submit test reports and review resulting errors using the NSC test submission process, working closely with assigned NSC analysts to demonstrate competency in accurate reporting and effective error resolution. Name(s) of Contact Person(s) Responsible o Barbara Helms, University Registrar – primary responsibility for enrollment reporting submissions, back-up for G reporting o Heidi Thomas, Processing and Data Specialist – assists with enrollment error report cleanup, secondary for enrollment reporting submissions, additional back-up for G reporting o Ashley Dinger, Academic Records and Graduation Specialist – primary responsibility of the G reporting, additional back-up for enrollment reporting. • Although documentation exists from the previous corrective action plan, it has been determined that it is not sufficiently detailed. New documentation is being developed to ensure that any individual responsible for these processes in the future has the necessary tools and guidance to meet all regulatory requirements. Estimated timeline for corrective action to be implemented: April 2026

Categories

Student Financial Aid Reporting Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $36.62M
84.063 FEDERAL PELL GRANT PROGRAM $4.48M
93.364 NURSING STUDENT LOANS $871,003
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $807,311
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $368,063
23.001 APPALACHIAN REGIONAL DEVELOPMENT (SEE INDIVIDUAL APPALACHIAN PROGRAMS) $312,817
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $311,706
84.033 FEDERAL WORK-STUDY PROGRAM $288,575
84.044 TRIO TALENT SEARCH $286,417
84.217 TRIO MCNAIR POST-BACCALAUREATE ACHIEVEMENT $280,943
84.042 TRIO STUDENT SUPPORT SERVICES $266,835
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $180,731
84.031 HIGHER EDUCATION INSTITUTIONAL AID $149,258
59.037 SMALL BUSINESS DEVELOPMENT CENTERS $133,258
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $130,643
84.126 REHABILITATION SERVICES VOCATIONAL REHABILITATION GRANTS TO STATES $94,783
23.002 APPALACHIAN AREA DEVELOPMENT $93,590
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $50,051
14.850 PUBLIC HOUSING OPERATING FUND $48,245
15.662 GREAT LAKES RESTORATION $36,217
84.215 INNOVATIVE APPROACHES TO LITERACY; PROMISE NEIGHBORHOODS; FULL-SERVICE COMMUNITY SCHOOLS; AND CONGRESSIONALLY DIRECTED SPENDING FOR ELEMENTARY AND SECONDARY EDUCATION COMMUNITY PROJECTS $31,650
17.278 WIOA DISLOCATED WORKER FORMULA GRANTS $21,164
84.027 SPECIAL EDUCATION GRANTS TO STATES $15,571
93.124 NURSE ANESTHETIST TRAINEESHIP $15,538
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $14,888
93.288 NATIONAL HEALTH SERVICE CORPS SCHOLARSHIP PROGRAM $11,935
43.001 SCIENCE $9,550
43.008 OFFICE OF STEM ENGAGEMENT (OSTEM) $4,816