Finding 209 (2023-001)

Information on the Federal Program: Student Financial Assistance Cluster, Assistance Listing Number 84.268 Federal Direct Student Loans, Assistance Listing 84.063 Federal Pell Grant Program, U.S. Department of Education Program Year 2022-2023 Criteria or Specific Requirement: Special Tests and Provisions - Enrollment Reporting Condition: Federal regulations provide that the University is responsible for notifying the National Student Loan Data System ("NSLDS") of changes in enrollment within 30 days or on an Enrollment Reporting roster file within 60 days. The University's internal control system did not prevent certain late or missed changes requiring reporting. Six student enrollment status changes tested were not communicated to the NSLDS either on a timely basis, or reported incorrectly, at the Program Level, or in certain instances, both the Program and Campus Level. Questioned Costs: None Context: Out of a population of 180 student enrollment status changes requiring NSLDS notification, a sample of 28 student enrollment changes were selected for testing. Six of the status changes had deviations from reporting requirements. Our sample was not and was not intended to be statistically valid. Effect: The University may not be able to timely detect when students are not being included within the Enrollment Reporting roster file which could result in the NSLDS not being properly notified of student enrollment changes for Direct Loan and Pell recipients in accordance with federal regulations. Cause: During fiscal year 2023, 4 of the 6 exceptions related to graduates where graduation was not reported to the University's third party servicer until after the 60 day period and then was reported incorrectly. In some of these cases, this was a Program Level only issue where the student was still attending the university in graduate studies and therefore campus level was correct. The remaining two exceptions related to students who ceased enrollment either temporarily or permanently and were not reported timely. Identification as a Repeat Finding, if Applicable: 2022-001 Recommendation: We recommend the University evaluate controls around monitoring enrollment reporting to determine changes, either on the electronic processes or review processes that should be made to properly capture enrollment status changes on a timely basis and to properly monitor its third party service provider for timely reporting as necessary. Views of Responsible Officials and Planned Corrective Action: Management concurs with the finding and recommendation. See further information on the corrective action plan provided by management.