Finding 1241624 (2026-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2026
Accepted
2026-11-04
Audit: 415682
Organization: Clark University (MA)
Auditor: GRANT THORNTON

AI Summary

  • Core Issue: The University failed to report a student's withdrawal to NSLDS on time, missing the 60-day deadline by 51 days.
  • Impacted Requirements: Compliance with federal regulations for accurate and timely enrollment reporting is essential for universities participating in the Direct Loan program.
  • Recommended Follow-Up: Improve communication between decision-making offices and the Registrar's Office to ensure timely updates to student status in the system.

Finding Text

SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS | Finding 2026-001 – Enrollment Reporting | U.S. Department of Education | Award Year 2025-2026 | Student Financial Assistance Cluster (ALN: 84.268) | Compliance Requirement: Special Tests and Provisions – Enrollment Reporting | Type of Finding: Noncompliance; reported as noncompliance material to a compliance requirement (2 CFR 200.516(a)(2)) | Criteria - Universities that participate in the Direct Loan program must report student enrollment information to the National Student Loan Data System (NSLDS) accurately and on time. Universities must report any changes to student status in their next updated Enrollment Reporting Roster file, which is due within 60 days of the change (34 CFR 685.309). Universities must also review, update, and certify student enrollment information on the Enrollment Reporting Roster at least every 60 days. | Condition - We tested a sample of 40 students who received Title IV aid and had an enrollment status change during fiscal year 2026. For one student, the University gave the student written notice of a withdrawal decision in May 2026. The University did not certify the withdrawal to NSLDS until September 2026, which was 111 days after the decision. In the meantime, the University kept reporting the student as full-time in its enrollment roster certifications to NSLDS in July and August 2026. | Cause - The withdrawal was a required withdrawal for academic performance initiated by the University, rather than a student-initiated withdrawal processed directly through the Registrar's Office. Because the decision was made by the University, it fell outside the University's standard in-term withdrawal process. The student received written notice of the outcome in May 2026. However, due to an administrative delay, a copy of the decision letter did not reach the Registrar's Office until the end of the summer, with a request to code the withdrawal for the fall 2026 term. | Effect - The student's status in NSLDS was not reported within the required 60-day window. The withdrawal was certified 51 days past the deadline, and the student's record showed full-time during that time. | Questioned Costs - None. | Recommendation - We recommend that the University strengthen communication between the offices that make student status decisions and the Registrar's Office, so that status changes are recorded in Banner and reported to NSLDS on time. | Views of Responsible Officials and Planned Corrective Action - See Corrective Action Plan. | Repeat Finding - No.

Corrective Action Plan

Finding 2026-001 – Management’s Corrective Action Plan | To whom it may concern: | U.S. Department of Education | Award Year 2025-2026 | Student Financial Assistance Cluster (ALN: 84.268) | Management concurs with the finding. The student's required withdrawal for academic performance was a University-initiated decision that fell outside the standard withdrawal process managed by the Registrar's Office. Because the decision letter was not forwarded to the Registrar's Office at the time the student was notified, the withdrawal was not recorded in Banner or reported to NSLDS within the required 60 days. The student's status has since been corrected in NSLDS. | To prevent this from recurring, the University will require that any office issuing a student status decision, including required withdrawals for academic performance, send a copy of the decision to the Registrar's Office on the same day the student is notified. Steps are being taken to automate the notification process. The Registrar's Office will record the change in Banner so that it is included in the next Enrollment Reporting Roster submission. In addition, the Registrar's Office will compare academic standing decisions against enrollment status before each roster certification to confirm that all University-initiated withdrawals have been reported. | The anticipated completion date of June 1, 2027, reflects the implementation of the automated notification process and the completion of roster certifications under the new review procedure. | Leadership Responsible: Andy Marx, Ph.D., University Registrar, Clark University, 508-793-7426 | Anticipated Completion Date: June 1, 2027

Categories

Student Financial Aid Special Tests & Provisions

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $13.18M
84.063 FEDERAL PELL GRANT PROGRAM $3.04M
17.268 H-1B JOB TRAINING GRANTS $2.16M
84.033 FEDERAL WORK-STUDY PROGRAM $592,435
47.074 BIOLOGICAL SCIENCES $536,834
94.006 AMERICORPS STATE AND NATIONAL 94.006 $503,267
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $453,343
59.037 SMALL BUSINESS DEVELOPMENT CENTERS $410,911
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $381,721
10.310 AGRICULTURE AND FOOD RESEARCH INITIATIVE (AFRI) $376,734
47.083 INTEGRATIVE ACTIVITIES $232,788
47.041 ENGINEERING $179,224
66.437 GEOGRAPHIC PROGRAMS €“ LONG ISLAND SOUND PROGRAM $173,548
93.262 OCCUPATIONAL SAFETY AND HEALTH PROGRAM $167,411
15.232 JOINT FIRE SCIENCE PROGRAM $144,871
47.078 POLAR PROGRAMS $143,414
47.049 MATHEMATICAL AND PHYSICAL SCIENCES $141,932
11.431 CLIMATE AND ATMOSPHERIC RESEARCH $71,958
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $64,611
15.820 NATIONAL AND REGIONAL CLIMATE ADAPTATION SCIENCE CENTERS $56,707
47.075 SOCIAL, BEHAVIORAL, AND ECONOMIC SCIENCES $55,577
47.070 COMPUTER AND INFORMATION SCIENCE AND ENGINEERING $50,078
47.050 GEOSCIENCES $46,304
93.136 INJURY PREVENTION AND CONTROL RESEARCH AND STATE AND COMMUNITY BASED PROGRAMS $39,855
93.279 DRUG USE AND ADDICTION RESEARCH PROGRAMS $17,320
47.079 INTERNATIONAL SCIENCE AND ENGINEERING $16,424
10.215 SUSTAINABLE AGRICULTURE RESEARCH AND EDUCATION $14,001
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $11,487
12.800 AIR FORCE DEFENSE RESEARCH SCIENCES PROGRAM $5,941
66.456 NATIONAL ESTUARY PROGRAM $4,583
93.307 MINORITY HEALTH AND HEALTH DISPARITIES RESEARCH $4,098
43.001 SCIENCE $3,314
10.664 COOPERATIVE FORESTRY ASSISTANCE $1,573