Finding 387815 (2023-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-28
Audit: 299868
Organization: Hodges University, Inc. (FL)

AI Summary

  • Core Issue: The University failed to comply with federal regulations regarding timely and accurate NSLDS enrollment reporting.
  • Impacted Requirements: Noncompliance with 34 CFR 685.309 (b) and NSLDS Enrollment Reporting Guide, leading to discrepancies in enrollment data.
  • Recommended Follow-Up: Review and update policies and procedures to ensure accurate and timely reporting to NSLDS.

Finding Text

2023–002 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.268 – Federal Direct Loan Program Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 (b) outlines that schools must update the secretary with pertinent information within 30 days (unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days) after the date the school discovers a student changed enrollment from half time/full time/graduate/withdrawal/etc. Section 4.4.2 of the NSLDS Enrollment Reporting Guide (Circa November 2018) establishes the definition of the effective date, certification date, and received date. Condition: During our detail testing of NSLDS Enrollment Reporting we noted instances where the University did not comply with the requirements noted above. Questioned costs: None. Context: During our detail testing of NSLDS Enrollment Reporting we noted the following discrepancies in our sample of 13 students: • 8 instances in which the program enrollment effective date did not match the program-level enrollment effective date per NSLDS • 10 instances for which the student's status was not reported timely • 13 instances in which the student's enrollment was not certified timely • 11 instances where the enrollment effective date was incorrect per NSLDS • 6 instances for which the student's status was not reported to NSLDS Cause: the University’s policies and procedures did not detect and correct these errors to ensure compliance. Effect: Noncompliance with federal regulations which could lead to untimely reporting of enrollment information to NSLDS. Repeat Finding: Yes, prior year finding 2022-003. Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters to NSLDS. Views of responsible officials: See Corrective Action Plan prepared by the University.

Corrective Action Plan

2023-002 National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: Hodges University's enrollment and withdrawal policies did not align with the department of education requirements. In addition, internal controls in place were insufficient. Action taken in response to finding: Hodges University is updating its policies to follow the federal policies and best practices in order to remain compliant; that update will reflect as an addendum to the catalog. We have implemented additional internal controls to ensure the timeliness and accuracy of future reporting, and compliance. Name(s) of the contact person(s) responsible for corrective action: Nicole Hurley, Director of University Registrar, Olker Alva, Director of Students Financial Services, and Diana Schultz, SVP of Student Affairs and Financial Services and Provost. Planned completion date for corrective action plan: Effective immediately

Categories

Student Financial Aid Reporting Material Weakness Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 387816 2023-003
    Significant Deficiency Repeat
  • 387817 2023-003
    Significant Deficiency Repeat
  • 387818 2023-003
    Significant Deficiency Repeat
  • 387819 2023-004
    Significant Deficiency
  • 387820 2023-005
    Significant Deficiency
  • 387821 2023-005
    Significant Deficiency
  • 964257 2023-002
    Material Weakness Repeat
  • 964258 2023-003
    Significant Deficiency Repeat
  • 964259 2023-003
    Significant Deficiency Repeat
  • 964260 2023-003
    Significant Deficiency Repeat
  • 964261 2023-004
    Significant Deficiency
  • 964262 2023-005
    Significant Deficiency
  • 964263 2023-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $3.96M
84.063 Federal Pell Grant Program $1.86M
84.007 Federal Supplemental Educational Opportunity Grants $104,800