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FINDING 2022-002 ? Special Tests and Provisions ? Enrollment Reporting: Material Weakness in Internal Control - SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR TABLE/CHART. - Criteria ? 34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/context ? A sample of 75 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2021-2022 academic year. The enrollment information and withdrawal, address change, or graduation date per NU?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Of the 75 students whom had a change in address, graduated, or withdrew, 19 were not reported to the NSLDS within the required timeframe. Of the 75 students, 3 had an incorrect effective date reported to the NSLDS. Cause ? The attendance queries periodically used for change of status purposes were incomplete and failed to identify several students whom had stopped attending class prior to completion of a payment period. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat finding ? This is a repeat finding. See 2021-002. Recommendation ? We recommend NU establish consistent and accurate criteria when developing and running report queries to identify students who have stopped attending prior to the end of the payment period. We also recommend testing of the queries at established intervals to ensure they are consistently identifying the appropriate students. Views of responsible officials and planned corrective actions ? In January of 2023, NU updated its NSLDS reporting policies and procedures overseen by Jorge Salas from our registrar team. The Quality Assurance, under Brandy Baker, team began reviewing enrollment reporting on a regular basis in February of 2023 to confirm the reporting process is consistent with the Title IV regulation. In the event that the Quality Assurance review yields inaccurate reporting, the Quality Assurance team will lead the investigation to determine the cause of the inaccurate reporting and will work with the appropriate departments and teams to ensure that any required corrections to process, reporting, reporting code or systems is rectified. NU reviewed and confirmed that the revised reporting logic would accurately report enrollment statuses, effective dates, and locations.