(1) Summary of Auditors’ Results
Financial Statements
a. Type of report issued on whether the financial statements were prepared in accordance with generally
accepted accounting principles: Unmodified
b. Internal control deficiencies over financial reporting disclosed by the audit of the financial statements:
• Material weaknesses: No
• Significant deficiencies: No
c. Noncompliance material to the financial statements: No
Federal Awards
d. Internal control deficiencies over major programs disclosed by the audit:
• Material weaknesses: Yes
• Significant deficiencies: No
e. Type of report issued on compliance for major programs: Qualified
f. Audit findings that are required to be reported in accordance with 2 CFR 200.516(a): Yes
g. Major programs:
• Student Financial Assistance Cluster – Various ALNs
h. Dollar threshold used to distinguish between Type A and Type B programs: $750,000
i. Auditee qualified as a low-risk auditee: Yes
(2) Findings Relating to the Financial Statements Reported in Accordance with Government Auditing
Standards
None
(3) Findings and Questioned Costs Relating to Federal Awards
Finding Number: 2024-001
Program: Student Financial Assistance Cluster
ALN #: 84.063 and 84.268
Federal Award #’s: P063P235372, P268K225372
Federal Award Years: July 1, 2023 to June 30, 2024
Federal Agencies: U.S. Department of Education
Pass-Through Entity: N/A – Direct Award
Compliance Requirement: Enrollment Reporting
Finding Type: Material Weakness and Material Noncompliance
Criteria:
Under the Pell grant and the Direct and Federal Family Education Loan programs, institutions are required
to report enrollment information via the National Student Loan Data System (NSLDS) (OMB No. 845-0035).
The administration of the Title IV programs depends heavily on the accuracy and timeliness of the
enrollment information reported by institutions. Institutions must review, update and verify student
enrollment statuses, program information and effective dates that appear on the Enrollment Reporting
Roster file or on the Enrollment Maintenance page of the NSLDS Financial Aid Professionals (NSLDSFAP)
website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is
what NSLDS has as the most recently certified enrollment information. There are two categories of
enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately
and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and
guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer.
Institutions must complete and return the Enrollment Reporting roster file placed in their Student Aid
Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS within 15 days. An
institution determines how often it receives the Enrollment Reporting roster file with the default set at a
minimum of every 60 days. Once received, the institution must update for changes in the data elements for
the Campus Record and the Program Record identified above, and submit the changes electronically
through the batch method, spreadsheet submittal or the NSLDS website.
Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal
control over federal awards that provide reasonable assurance that the non-federal entity is managing the
federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal
award.
Condition found:
During our testwork over student enrollment reporting, we noted Regent did not report all changes to
students’ status within the required 60 days. For a sample of 40 students who were recipients of Direct
Loans or Pell Grants between July 1, 2023 and June 30, 2024 and that had been identified as having
withdrawn, graduated, or modified their enrollment status as defined by Regent’s Satisfactory Academic
Progress Policy through a change in course load, the following was noted:
For 33 students out of the 40 selected for compliance testing, Regent did not transmit the students’ status
change to NSLDS within 60 days.
Additionally, based on management’s further investigation, it was determined that there were multiple
submissions during the year that were delayed and resulted in enrollment reporting being outside of the 60-
day window.
Additionally, while Regent has controls in place to ensure that enrollment changes are reported timely to
the National Student Clearinghouse (NSC), the control does not ensure that any required correspondence
with NSC to resolve data matters is happening timely.
Cause:
For the students noted above, management communicated that there were delays in the data transmission
from the NSC and the NSLDS. While the data was provided to the NSC in a timely manner, there were
issues with the data that needed to be resolved between Regent and the NSC in order to proceed with the
submission to NSLDS.
For the reasons noted above, we determined the related control in place at Regent, which is designed to
address the timeliness of the transmission reports, is not designed at a level to verify the timeliness of the
data transmission to the NSC nor ensure that any subsequent issues are resolved timely and that the data
is ultimately submitted to the NSLDS timely.
Proper perspective:
Regent’s policy is to submit enrollment data to the NSC on a predetermined schedule that allows Regent to
comply with the enrollment reporting requirements. For our sample of 40 students with status changes, we
identified 33 students where the status change was not reported within 60 days.
Upon further review by management, there were a total of 13 submissions for which the delay in the
resolution of issues between Regent and the NSC resulted in the enrollment information being reported
outside of the 60-day reporting requirement. As a result of these delays, there were a significant number of
changes that were not reporting timely.
Possible asserted effect:
Untimely submission of student enrollment information affects the determinations that lenders and
servicers of students’ loans make related to in-school status, deferments, graces periods, and
repayment schedules, as well as the federal government’s payment and interest schedules.
Questioned costs:
None noted.
Statistical sampling:
The sample was not intended to be, and was not, a statistically valid sample.
Repeat finding:
A similar finding was not reported in the prior year.
Recommendation:
We recommend that Regent implement additional controls to ensure that the transmission reports are
received by NSLDS timely. Additionally, we recommend Regent evaluate its processes and procedures
when submitting data to the NSC to ensure that any data issues impacting the timeliness of the
transmissions are resolved.
Views of responsible officials:
Regent agrees with this finding. Regent intends to strengthen its controls and quality assurance measures
over the timeliness of enrollment information to NSLDS.