Finding 519612 (2024-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-01-17
Audit: 338706
Organization: Cleary University (MI)
Auditor: Capincrouse LLP

AI Summary

  • Core Issue: Some students who withdrew were incorrectly reported as enrolled in the NSLDS.
  • Impacted Requirements: This violates 34 CFR 690.83(b) and 34 CFR 685.309 regarding accurate enrollment reporting.
  • Recommended Follow-Up: Implement a system to verify withdrawal statuses and conduct regular reconciliations and spot checks for NSLDS reporting.

Finding Text

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: The NSLDS enrollment status was not properly reported for some students, primarily those who withdrew from the University. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 77 students tested, 5 students who withdrew were still being reported as enrolled to NSLDS. 2 students were reported as “no record found” but both had federal direct loans disbursed during the year. Cause: The registrar's office was not completing timely reconciliations of enrollment statuses throughout the year. Effect: The incorrect reporting impacts the student's loan grace period, in school deferment eligibility, beginning loans payments, appropriate interest charges, etc. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the University put a system in place to ensure that students who withdraw either officially or unofficially during a term be checked for proper reporting to NSLDS as part of the R2T4 process. We also recommend that the University is periodically completing reconciliations of enrollment statuses and completing spot checks of enrollment statuses to NSLDS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: A new Registrar was hired in late May of 2024. A new process was implemented for the Fall semester of 2024 to ensure timely and accurate processing of official and unofficial withdrawals. Outcome: All student withdrawal requests both official and unofficial are processed daily and tracked in a shared workbook. This allows information about each individual withdrawal request to be captured and available for both the Business Office and Financial Aid. Date of Determination, Last Date of Attendance, Processed Date, withdrawal type, withdrawal reason, and credits impacted are all captured in the workbook to aid with R2T4 calculations. This workbook also serves as a document that can be audited in real-time to ensure accuracy of each student’s record. A Standard Operating Procedure was developed and used to train the team members effective on 8/12/2024. Person Responsible for Corrective Action Plan: Tonya Troka, University Registrar & Assistant Provost Anticipated Date of Completion: Completed and implemented for Fall 2024 Semester

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Eligibility Reporting Significant Deficiency

Other Findings in this Audit

  • 519609 2024-001
    Material Weakness Repeat
  • 519610 2024-001
    Material Weakness Repeat
  • 519611 2024-001
    Material Weakness Repeat
  • 519613 2024-002
    Significant Deficiency
  • 519614 2024-003
    - Repeat
  • 519615 2024-003
    - Repeat
  • 519616 2024-003
    - Repeat
  • 519617 2024-003
    - Repeat
  • 1096051 2024-001
    Material Weakness Repeat
  • 1096052 2024-001
    Material Weakness Repeat
  • 1096053 2024-001
    Material Weakness Repeat
  • 1096054 2024-002
    Significant Deficiency
  • 1096055 2024-002
    Significant Deficiency
  • 1096056 2024-003
    - Repeat
  • 1096057 2024-003
    - Repeat
  • 1096058 2024-003
    - Repeat
  • 1096059 2024-003
    - Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $5.49M
84.063 Federal Pell Grant Program $1.49M
84.007 Federal Supplemental Educational Opportunity Grants $74,929
84.033 Federal Work-Study Program $26,250