Finding 1211081 (2025-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-04-30
Audit: 400332
Organization: Ana G. Mendez University, Inc. (FL)

AI Summary

  • Core Issue: Student enrollment changes were not reported accurately to the National Student Loan Data System (NSLDS), leading to potential inaccuracies in loan repayment statuses.
  • Impacted Requirements: Compliance with 34 CFR Section 690.83 (b)(2) and 685.309 regarding timely enrollment reporting.
  • Recommended Follow-Up: The University should enhance processes and controls for enrollment reporting to prevent future issues and ensure compliance.

Finding Text

Finding Student Financial Assistance Cluster, ALN 84. 268 Federal Direct Student Loans, ALN 84.063 Federal Pell Grant Program, ALN 84.007 Federal Supplemental Educational Opportunity Grants, U.S. Department of Education Program Year 2024-2025 Criteria or specific requirement: Special Tests: Enrollment Reporting 34 CFR Section 690.83 (b)(2) and 685.309 Condition: There were student enrollment changes during the year that were not properly communicated to the National Student Loan Data System (NSLDS). Cause: Incomplete implementation, configuration, and automation within the AGMU’s information system (Anthology). This situation was exacerbated by several personnel changes within the Financial Aid Office and the Bursar’s Office. Finally, the Institution did not perform internal audits or similar reviews to confirm student eligibility once initial determinations of eligibility were made. Effect or potential effect: Untimely reporting of enrollment status changes may result in incorrect loan repayment statuses for borrowers. Questioned costs: N/A Context: Out of a population of 3,027 student enrollment status changes requiring notification transmitted to NSLDS, a sample of 60 student enrollment status changes were selected for testing. Our sample was not and was not intended to be statistically valid. 7 students had enrollment changes that were not properly reported. Errors include not reporting within the 60-day requirement. Identification as a repeat finding: N/A Recommendation: The University should review processes and controls around enrollment reporting and consider changes to address this finding. Views of responsible officials and planned corrective actions: Management agrees with this finding based on the above criterion. Please refer to the Corrective Action Plan.

Corrective Action Plan

Due to challenges related to the implementation and reporting functionality of the Anthology Student system, AGMU temporarily experienced difficulties in identifying enrollment status changes and reporting the changes to NSLDS. Errors and delays related to enrollment reporting were primarily due to AGMU’s delay in identifying withdrawn students (discussed in Finding 2025-2) and identifying the withdrawal date used in the R2T4 calculation so that the date could be reported to NSLDS. AGMU agrees with the auditor’s recommendation that implementing additional processes and controls around enrollment reporting will improve compliance. To resolve this issue and prevent recurrence, AGMU is completing the corrective actions described below. Corrective Action 1: Confirming and reporting withdrawal dates for award years 2023-24 and 2024-25 As part of the withdrawn students file review described in the corrective actions for Finding 2025-2, AGMU is confirming the withdrawal date for students who did not complete the payment period. Once the withdrawal dates have been confirmed (and/or previous withdrawal dates are confirmed), enrollment statuses for impacted students will be updated in NSLDS as appropriate. Corrective Action 2: Monitoring for enrollment status changes To identify enrollment status changes timely, AGMU developed a report (“Customized Enrollment Status Change” report) that identifies students with enrollment status changes, the effective date of enrollment status changes, and potential Title IV adjustments related to enrollment status changes (e.g., Pell Grant recalculations). AGMU generates this report weekly to ensure that any student with an enrollment status change is reviewed, and timely Title IV award revisions are completed, if applicable. Corrective Action 3: Validation of the Enrollment Reporting Roster To validate the accuracy of the Enrollment Reporting Roster, AGMU will be developing a report to identify students with enrollment status changes and the effective date of enrollment status changes. AGMU is determining if it could use the existing report (“Customized Enrollment Status Change” report) for this process. Once AGMU has finalized its process and report, AGMU plans to generate this report monthly to confirm accurate information regarding student enrollment status is being extracted from the Anthology Student system and correctly transmitted to NSLDS via the Enrollment Reporting Roster. Corrective Action 4: Timely identification of ISIR comment codes Although AGMU had policies and procedures related to determining student eligibility, the procedures required revisions due to the Anthology Student implementation. To identify students for whom ISIR comment codes appear after Title IV aid is awarded and/or disbursed (i.e., on a subsequent ISIR), AGMU developed a report (“Customized Ineligible Funds” report) that identifies potentially impacted students, Title IV funds awarded and disbursed, and ISIR comment codes. AGMU generates this report weekly to ensure any student with an ISIR comment code is reviewed and any funds that must be returned are identified timely. Corrective Action 5: Review and revision of policies and procedures related to enrollment reporting. AGMU is in the process of revising its existing policies and procedures related to enrollment reporting to ensure they correctly describe processes in the Anthology system. Corrective Action 6: Ongoing monitoring by and support from system office personnel SUAGM central office financial aid personnel will perform and assist with quality assurance activities related to AGMU’s enrollment reporting such as: 1. Creating reports related to official and unofficial withdrawals to verify that enrollment status changes are identified on a timely basis and accurately reflected in student records in NSLDS. 2. In coordination with the Registrar, creating an enrollment reporting manual. 3. Developing NSLDS enrollment reporting training and requiring that all staff with enrollment reporting responsibilities attend the training. Corrective Action 7: Enrollment reporting file review AGMU is in the process of planning a comprehensive file review of enrollment reporting for the 2023-24 and 2024-25 award years. At this time, AGMU is prioritizing the withdrawn students file review so that unearned funds can be returned to the U.S. Department of Education as soon as possible. Once the withdrawn students file review is completed, AGMU will begin work on the enrollment reporting file review.

Categories

Student Financial Aid Reporting

Other Findings in this Audit

  • 1211076 2025-002
    Material Weakness Repeat
  • 1211077 2025-002
    Material Weakness Repeat
  • 1211078 2025-002
    Material Weakness Repeat
  • 1211079 2025-003
    Material Weakness Repeat
  • 1211080 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $93.18M
84.063 FEDERAL PELL GRANT PROGRAM $25.88M
84.120 MINORITY SCIENCE AND ENGINEERING IMPROVEMENT $170,982
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $146,895