Finding 1205768 (2025-002)

Finding 2025-002 Federal Programs: Student Financial Aid Cluster • Federal Direct Student Loans (ALN 84.268) • Federal Pell Grant Program (ALN 84.063) Federal Award #’s: P268K240395 and P063P230395 Federal Award Years: July 1, 2024 to June 30, 2025 Federal Agencies: U.S. Department of Education Pass Through Entity: None Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Criteria: Under the Pell grant and the Direct and Federal Family Education Loan programs, institutions are required to report enrollment information via the National Student Loan Data System (NSLDS) (OMB No.1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. 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. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record that the Department of Education (ED) considers high risk: (1) OPEID number, (2) enrollment effective date, (3) enrollment status and (4) certification date. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk: (1) OPEID number, (2) CIP code, (3) CIP year, (4) credential level, (5) published program length measurement, (6) published program length, (7) program begin date, (8) program enrollment status and (9) program enrollment effective date. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS within 15 days. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context: The University utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for transmissions of its enrollment reporting changes to the National Student Loan Data System (NSLDS). The University receives the Enrollment Reporting Roster and updates it for changes in student status. The file is sent to the Clearinghouse who transmits the updated information to NSLDS. For a sample of 60 students who were recipients of Direct Loans or Pell Grants between July 1, 2024, and June 30, 2025, who had been identified as having withdrawn, graduated, or modified their enrollment status as defined by the University’s Satisfactory Academic Progress Policy through a change in course load, the following were noted: • For seven out of the 60 students selected for testwork, the University did not report their enrollment status change within the 60 days of change. • For two out of the 60 students selected for testwork, the University inaccurately reported their enrollment status as half-time or full-time, whereas the University’s enrollment records indicated the students were enrolled at three-quarter-time. • For one out of the 60 students selected for testwork, the graduation enrollment status change was not reported to NSLDS. • For one out of the 60 students selected for testwork, the campus-level enrollment record was not updated to reflect half-time status, resulting in the enrollment status change not being reported to NSLDS within the required 60-day timeframe. Cause and Possible Asserted Effect: The University’s controls over its review of the recording and communication of these status changes did not operate consistently to ensure that individuals’ enrollment statuses are completely and accurately communicated to NSLDS. Identification of Questioned Costs: There are no questioned costs related to this finding. Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend that the University improve its IT processes and functionality so that enrollment statuses are reported completely and accurately. We also recommend strengthening controls over the accuracy and processing of student enrollment status changes. Identification of Repeat Finding: This audit finding is a repeat of Finding 2024-004 in the immediately prior year. Views of Responsible Officials: The University concurs with the finding. We will work with IT to enhance the information included in the Comprehensive Graduation Report to ensure complete, accurate and timely reporting.