Finding 513130 (2024-002)

Significant Deficiency

Requirement

Questioned Costs

Year

2024

Accepted

2024-12-05

Audit: 331120

Organization: University of Western States (OR)

Auditor: Rsm US LLP

AI Summary

Core Issue: Three students had incorrect withdrawal dates reported in NSLDS, affecting their enrollment status.
Impacted Requirements: This misreporting violates federal guidelines, which could affect student repayment periods and future funding.
Recommended Follow-Up: UWS should review and improve policies and internal controls for accurate NSLDS withdrawal date reporting.

Finding Text

Finding 2024-002: Special Tests: Enrollment Reporting – Improper Reporting of Withdrawal Date Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster, Federal Direct Student Loans Assistance Listing Number: 84.268 Award Year: June 1, 2023 – May 31, 2024 Program Expenditures: $20,593,109 Questioned Costs: $0 Criteria: Per the National Student Loan Data System (NSLDS) enrollment reporting guide (Section 4.4.3) when a student withdraws during a term, the effective date for the withdrawn status is the withdrawal date used by the Institution in accordance with 34 CFR 668.22. Condition: During our enrollment testing, we noted that the effective date of withdrawal in NSLDS for 3 students tested was incorrectly listed as the date of determination by UWS instead of the withdrawal date determined in accordance with 34 CFR 668.22. Internal controls in place did not identify the errors. Cause: Three students with incorrect enrollment reporting dates were due to the student’s out of school status treated by the relevant University department as an unofficial withdrawal instead of an official withdrawal for enrollment reporting purposes. The Dates of Determination were therefore used incorrectly. Effect: Incorrect enrollment reporting could impact a student’s repayment period. Noncompliance with federal guidelines could impact future funding. Questioned Costs: $0 Context: 3 out of a total of 24 students tested for enrollment reporting in NSLDS had an incorrect date listed as the effective date of the student’s enrollment status. No other exceptions were noted in our enrollment testing. Repeat Finding: No. Recommendation: We recommend UWS review their policies and internal controls around NSLDS reporting of the withdrawal date to ensure compliance with the regulations. Views of Responsible Officials: Management agrees with the finding. Please see corrective action plan attached.

Corrective Action Plan

Identifying Number: 2024-002 Finding: Special Tests: Enrollment Reporting – Improper Reporting of Withdrawal Date Applicable Regulation: Per the National Student Loan Data System (NSLDS) enrollment reporting guide (Section 4.4.3) when a student withdraws during a term, the effective date for the withdrawn status is the withdrawal date used by the Institution in accordance with 34 CFR 668.22. Finding: 3 out of a total of 24 students tested for enrollment reporting in NSLDS had an incorrect date listed as the effective date of the student’s enrollment status. Summary: During our enrollment testing, we noted that the effective date of withdrawal in NSLDS for 3 students tested was incorrectly listed as the date of determination by UWS instead of the withdrawal date determined in accordance with 34 CFR 668.22. Internal controls in place did not identify the errors. Three students with incorrect enrollment reporting dates were due to the student’s out of school status treated by the relevant University department as an unofficial withdrawal instead of an official withdrawal for enrollment reporting purposes. The Dates of Determination were therefore used incorrectly. Corrective Action Planned or Taken: The University of Western States has updated its policy for all out of school and reporting for all out of school students. Additionally, an internal Decision Tree resource document has also been created for use when processing student withdrawals and reporting student statuses. All out of school students will have the appropriate out of school date selected and submitted for enrollment roster reporting based on the updated policy and the supplemental Decision Tree. UWS staff has also reviewed all students and confirms reporting statuses align with the updated policy. Contact Person: Michelle Miller, Senior Vice President of Enrollment Management mmiller10@tcsedsystem.edu Anticipated Completion Date: September 17, 2024

Other Findings in this Audit

513129 2024-001

Significant Deficiency
1089571 2024-001

Significant Deficiency
1089572 2024-002

Significant Deficiency

Programs in Audit

ALN	Program Name	Expenditures
84.268	Federal Direct Student Loans	$20.59M
84.038	Federal Perkins Loans Program	$771,994
84.033	Federal Work-Study Program	$56,085