Finding Text
FINDING 2025-004 Internal Control over Compliance and Compliance with Special Tests and Provisions – NSLDS Reporting (Material Weakness and Material Noncompliance) Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Number: Federal Pell Grant (84.063P) and Federal Direct Loans (84.268) Criteria: Institutions are required to report enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035, 34 CFR 690.83(b)(2), 34 CFR 682.610, 34 CFR 685.309, and 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Condition: During the audit, we tested twenty-five (25) students who had enrollment status changes during the fiscal year ended September 30, 2025. For four (4) of these students who graduated, the University did not report the graduation status within the required 60 days of the change. Effect or Potential Effect: Timeliness of reporting graduation status to the NSLDS could impact notification to loan servicers that a borrower has entered repayment status, the start of a borrower’s grace period, and/or deferment, repayment scheduling, and loan servicing. Context: This is a condition based on testing the University’s compliance with specific requirements. The prevalence of this finding is detailed in the condition above. The samples were selected using a non-statistical method. Cause: The University recently implemented a new enterprise planning system and certain reports used to identify enrollment status changes to be reported to NSLDS did not include all students who graduated. The system reports were not sufficiently reviewed to detect these omissions. Questioned Costs: None identified. Recommendation: We recommend that the University strengthen its procedures for identifying and reporting student enrollment status changes to the NSLDS to ensure that the submission of such enrollment information is accurate and timely. Views of Responsible Official: Management’s corrective action plan, including immediate remediation steps and enhancements to internal controls over Special Tests and Provisions – NSLDS reporting, is presented in the Corrective Action Plan section of this report.