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FINDING 2022-002 ? Special Tests and Provisions ? Enrollment Reporting: Significant Deficiency in Internal Control: See Schedule of Findings and Questioned Costs for chart/table" in place of the chart or table within the text. - 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 48 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 NCU?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. Three of the 48 students whom had a change in address, graduated, or withdrew were not reported to the NSLDS within the required timeframe. One student whom had withdrawn during the 2021-2022 academic year was reported timely, however, had an incorrect effective date reported to the NSLDS. Cause ? The queries written to identify students with status changes did not capture all withdrawn students. In addition, existing internal controls did not prevent late or incorrect reporting within the required timeframe resulting in non-compliance. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by the United States Department of Education, 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 2021-001. Recommendation: We recommend that the University develop additional procedures to monitor the accuracy of information provided by its third-party servicer on behalf of the University to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate. Each institution has access to correct information directly within NSLDS at any time. Views of Responsible Officials and Planned Corrective Actions ? Management agrees with the importance of ensuring timely and accurate NSLDS reporting in accordance with 34 CFR section 685.309(b)(2)(i)). The NCU Quality Assurance team now reviews enrollment reporting on a regular basis 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. Management agrees with the importance of communicating with the Department of Education when an enrolled student ceases to be enrolled at least half-time.