Finding Text
Finding 2024-013 - U.S. Department of Education (Title IV Student Financial Aid Programs - Inaccurate Enrollment Reporting to the National Student Loan Data System (NSLDS) (material weakness) Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2024; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2024; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2024; Federal Work-Study Program, FAL No. 84.033, June 30, 2024. Criteria – Per 34 CFR § 685.309(b) and 34 CFR § 690.83, institutions are required to report accurate and timely student enrollment information to National Student Loan Data System (NSLDS). The enrollment information must reflect each student’s current enrollment status and must be submitted within 60 days of any change in student status or in accordance with the schedule established by the U.S. Department of Education. Condition – During testing of enrollment reporting, we noted that one (1) out of six (6) sampled students had inaccurate enrollment information reported to the National Student Loan Data System (NSLDS). Enrollment status for the student was not updated correctly or timely in accordance with federal reporting requirements. Cause – It appears that the exception occurred because the University did not have adequate monitoring procedures in place to ensure compliance for updating and reconciling enrollment changes between the registrar’s system and the NSLDS submission system. Effect - Failure to accurately and timely report student enrollment statuses can result in incorrect loan deferment or grace period tracking for affected borrowers, potential early loan repayment obligations for students who are no longer enrolled, and findings in federal program reviews or compliance audits. There are also an increased risk of administrative capability concerns under 34 CFR § 668.16. Questioned Costs - $0 Perspective – Accurate enrollment reporting is critical because it directly affects borrowers’ repayment obligations and loan servicing timelines. Although only 1 of 6 students tested had an inaccurate record, this represents a material process weakness due to the high sensitivity and federal reliance on accurate enrollment data. The Department of Education treats even single enrollment reporting failures as significant because they disproportionately impact borrower rights and federal loan servicing. Repeat Finding - No Auditor’s Recommendation - The University should establish a formal reconciliation process to verify all student status changes are reported timely as well as conduct periodic reviews to ensure the accuracy of student status data. Management’s Response – Management has added secondary review and implemented periodic internal monitoring. View of Responsible Officials – Management agrees with the finding and acknowledges that student enrollment information was not consistently reported accurately and timely to NSLDS in accordance with federal reporting requirements.