Finding 529410 (2024-001)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-03-21
Audit: 347392
Organization: University of the Pacific (CA)
Auditor: Kpmg

AI Summary

  • Core Issue: The University failed to report enrollment changes for 19 out of 40 students to the NSLDS within the required 60-day timeframe.
  • Impacted Requirements: Compliance with 34 CFR Section 685.309, which mandates timely and accurate enrollment reporting to the Department of Education.
  • Recommended Follow-Up: Improve internal controls to ensure accurate and timely submission of enrollment data to NSLDS, including regular reviews of reporting processes.

Finding Text

Finding 2024-001 Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.268 Federal Direct Student Loans Program Federal Agency: Department of Education Award Year: July 1, 2023 - June 30, 2024 Criteria: Per 34 CFR Section 685.309, institutions with direct loan programs must report enrollemnt information within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who 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 in which the loan was intended. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the National Students Loan Data System (NSLDS) website, or certifying through NSLDS's batch enrollment reporting process. Additionally, there are two categories of enrollment information within NSLDS. "Campus level" and "Program level" both of which need to be reported accurately and have separate record types. Condition and Context: Of the 40 students with enrollment changes we selected for testwork, we noted that for 19 students, the University did not report the student's status or enrollment change accurately to the NSLDS within the required 60-day period. Cause and effect: The University's internal control failed in ensuring the required report was posted to the NSLDS website timely. Questioned Costs: None noted Sampling: The sample was not intended to be and was not a statistically valid sample. Repeat Finding: No Recommendation: We recommend that the University enhance its internal controls to ensure all information submitted to NSLDS is reviewed for accuracy on a timely basis. View of Responsible Officials: University of the Pacific concurs with this finding. The University utilizes the services of National Student Clearinghouse to report student status data to NSLDS. Of the 19 students, 12 had status records that did not match between the program and campus level records. They remained listed as enrolled in the undergraduate program when they had actually progressed to the pharmacy school graduate program after their junior year. Of the 19 students, seven graduated from a program at the University, but their status was not properly reported within the 60-day requirement. To address this, the registrar will review system generated reports to match NSLDS reporting guides and closely monitor when files are processed and reported to NSLDS.

Corrective Action Plan

Subject: Corrective Action Plan for Federal Direct Student Loans Program Compliance The University of the Pacific acknowledges the findings outlined in the audit related to the reporting of student enrollment status to the National Student Loan Data System (NSLDS) for the Federal Direct Student Loans Program (Federal Assistance Listing Number: 84.268) for the award year July 1, 2023 - June 30, 2024. We take our responsibility to comply with the federal regulations under 34 CFR Section 685.309 very seriously and are committed to strengthening our internal controls to ensure accurate and timely reporting of enrollment changes. Corrective Action Plan: To address the identified deficiencies and enhance our reporting processes, the University has implemented the following measures: 1. Monthly Reconciliation with National Student Clearinghouse (NSC): The Registrar’s Office will conduct a monthly audit of the NSC transmittal files to verify that all reported enrollment data matches the records in NSC and NSLDS. Any discrepancies will be promptly addressed to prevent inadvertent omissions of student enrollment changes. 2. Enhanced Monitoring and Error Resolution: The Registrar’s Office will review and resolve all NSC-generated error reports within 10 business days of receipt. This process will ensure that discrepancies between campus-level and program-level reporting are corrected promptly to meet the 60-day reporting requirement. 3. Regular Compliance Checks: System-generated reports will be reviewed to align with NSLDS reporting guidelines. Additionally, a designated staff member in the Registrar’s Office on the three-campuses will oversee the timely processing and submission of enrollment status changes to NSLDS. 4. Training and Process Improvement: The Registrar’s Office will conduct periodic training sessions for staff involved in enrollment reporting to reinforce compliance requirements and best practices for NSLDS data submission. Internal reporting procedures will also be refined to prevent delays or errors in enrollment reporting. 5. Ongoing Review and Oversight: The University will establish a formalized review process to assess the effectiveness of these corrective actions. Progress reports will be reviewed quarterly to ensure sustained compliance and continuous improvement in our enrollment reporting processes. The University remains committed to ensuring accurate and timely reporting of student enrollment data in compliance with federal regulations. We appreciate your guidance and support in maintaining the integrity of our Title IV reporting obligations. Please do not hesitate to reach out if additional clarification or documentation is required. Sincerely, Karen Johnson University Registrar

Categories

Student Financial Aid Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1105852 2024-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $164.48M
93.342 Health Professions Student Loans, Including Primary Care Loans and Loans for Disadvantaged Students $12.60M
84.063 Federal Pell Grant Program $6.83M
84.038 Federal Perkins Loan Program_federal Capital Contributions $5.83M
84.033 Federal Work-Study Program $1.50M
84.007 Federal Supplemental Educational Opportunity Grants $1.23M
16.575 Crime Victim Assistance $911,591
93.279 Drug Use and Addiction Research Programs $459,475
84.042 Trio Student Support Services $330,888
93.914 Hiv Emergency Relief Project Grants $309,690
84.047 Trio Upward Bound $284,247
47.049 Mathematical and Physical Sciences $235,012
47.050 Geosciences $150,465
93.859 Biomedical Research and Research Training $136,136
47.074 Biological Sciences $103,380
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $102,366
84.184 School Safely National Activities $86,456
93.084 Prevention of Disease, Disability, and Death by Infectious Diseases $82,890
12.300 Basic and Applied Scientific Research $73,594
93.043 Special Programs for the Aging, Title Iii, Part D, Disease Prevention and Health Promotion Services $59,458
47.076 Stem Education (formerly Education and Human Resources) $36,413
93.059 Training in General, Pediatric, and Public Health Dentistry $36,084
93.113 Environmental Health $11,219
93.121 Oral Diseases and Disorders Research $9,307
93.761 Evidence-Based Falls Prevention Programs Financed Solely by Prevention and Public Health Funds (pphf) $2,584
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $156