Finding 520046 (2024-001)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-01-23
Audit: 339546
Organization: Transylvania University (KY)
Auditor: Blue & CO LLC

AI Summary

  • Core Issue: The University failed to report accurate enrollment statuses for graduates, leading to incorrect data for over 120 days.
  • Impacted Requirements: The University did not comply with 34 CFR 685.309(b)(2)(i) regarding timely notification of enrollment changes.
  • Recommended Follow-Up: Regularly review NSLDS data to ensure accuracy and implement oversight procedures to correct status errors promptly.

Finding Text

Finding 2024-001: Enrollment Reporting Information on the Federal Program: Federal Direct Student Loan Program, AL Number 84.268 (Student Financial Aid Cluster) - U.S. Department of Education Criteria: Per 34 CFR 685.309(b)(2)(i), unless the school expects to submit its next enrollment report within 60 days, the school must notify the lender or the guaranty agency within 30 days after the discovery that a student who received a loan under the Title IV Act either did not enroll or ceased to be enrolled on at least a half-time basis. Per the National Loan Student Database System (NSLDS) Enrollment Reporting Guide and the GEN-14-07 Dear Colleague Letter issued by the U.S. Department of Education, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Condition: For students who completed their graduation requirements in May 2024, their graduated status change was reported via a third-party servicer on June 2, 2024, but was then subsequently overwritten by the third-party servicer with a status of full-time on June 20, 2024. The status of full-time remained active until October 3, 2024 when it was then changed to a status of withdrawn. Questioned Cost: $ 0 Cause: The University did not ensure that enrollment information submitted to NSLDS by its third-party servicer reflected accurate student enrollment data. Effect: The enrollment status for students who completed their graduation requirements in May 2024 was incorrect for more than 120 days. Recommendation: We recommend the University regularly review NSLDS to ensure that the information for its students is accurate. Views of responsible officials and planned corrective actions: The University concurs with this finding and will implement oversight procedures to ensure any status errors in NSLDS are corrected timely.

Corrective Action Plan

January 16, 2025 U.S. Department of Education 400 Maryland Ave SW Washington, DC 20212 Transylvania University respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Blue & Company, LLC 250 West Main Street, Suite 2900 Lexington, Kentucky 40507 The findings from the schedule of findings and questioned costs (the Schedule) for the year ended June 30, 2024 are discussed below and are numbered consistently with the numbers assigned in the Schedule. Identifying Number: 2024-001 Finding: Enrollment Reporting. The enrollment status for students who completed their graduation requirements in May 2024 was incorrect for more than 30 days. Corrective Actions Taken or Planned: This issue occurred because enrollment and degree verify files sent to the National Student Clearinghouse (NSC) at the end of a term were processed in a particular order and student enrollment data overwrote student graduated status data. To correct the impacted students, the university registrar requested that NSC reprocess the May 2024 degree verify file, which should have been processed last. To prevent a future recurrence, the registrar has modified the file upload schedule to reflect the correct order of processing and has updated office procedures to clarify that the degree verify file should be uploaded last, following the submission of all term enrollment data. In addition to altering the file submission schedule, the registrar will ensure the end-of-term enrollment file has been processed by the NSC before the Degree Verify file is submitted each term. January 16, 2025 U.S. Department of Education 400 Maryland Ave SW Washington, DC 20212 Estimated Completion Date: November 11, 2024 Responsible Personnel: Michelle Robinson, Registrar If you have any questions or would like any additional information regarding these matters, please let us know and we will be happy to provide. Sincerely, Lisa Custardo, CPA Chief Financial Officer

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Other Findings in this Audit

  • 1096488 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $4.78M
84.063 Federal Pell Grant Program $1.42M
84.038 Federal Perkins Loans $479,854
84.033 Federal Work-Study Program $149,339
84.007 Federal Supplemental Educational Opportunity Grants $91,143
47.083 Integrative Activities $52,420