Finding 31860 (2022-001)

Identifying number: 2022-001 Identification of the federal program: U.S. Department of Education Student Financial Aid Cluster Finding: Uniform Guidance for Student Financial Aid (SFA) Programs {III. Compliance Requirements, N. Special Tests and Provisions, 4. Enrollment Reporting ? Compliance requirements (34 CFR 685.309 (b)(2)(i))} stipulates that unless it expects to submit its next updated enrollment report to the secretary within the next 60 days, the school must notify the Secretary within 30 days after the date the school discovers that 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. The University did not properly provide to the National Student Loan Data System (NSLDS) notification for one student who withdrew or graduated during FY 2022. Anticipated Completion Date: Action Already Taken Person Responsible: Colin Hilton-MacFarlane, Executive Director of Institutional Research and Effectiveness Corrective Actions Taken or Planned: The Office of Institutional Research and Effectiveness reports graduated students to the National Student Clearinghouse upon degree conferral. The concern about solely relying on a third-party to submit to the National Student Loan Data System was identified in the FY2021 audit with a management response involving reconciling extracts directly from NSLDS to validate that all graduated students were successfully reported (and updating directly within NSLDS for any that failed to be submitted by NSC). The finding in this FY2022 audit occurred prior to the management response and associated business process implementation from the FY2021 audit. The institution remains confident this direct reconciliation within NSLDS will resolve future instances of a lack of timely reporting. This finding also involved a rare case of a student completing a master?s level degree program and immediately enrolling in a subsequent master?s level degree program. The institution believes this uncommon circumstance may have contributed to this specific failure in NSC reporting the graduated status to NSLDS, so although the new business process of reconciliation should prevent the general case of this issue, specific review within NSLDS of students immediately moving from one degree program to another upon graduation will be conducted to ensure no additional mitigations are necessary beyond what has already been implemented to address the general case.