Finding 547388 (2024-002)

Significant Deficiency Repeat Finding

Requirement

Questioned Costs

Year

2024

Accepted

2025-03-31

Audit: 351633

Organization: Point University, Inc. and Subsidiaries (GA)

Auditor: Cliftonlarsonallen LLP

AI Summary

Core Issue: The University failed to report student enrollment statuses accurately and on time, violating federal regulations.
Impacted Requirements: Compliance with 34 CFR 682.610, including timely certification of enrollment every 60 days and accurate reporting to NSLDS.
Recommended Follow-Up: Review and update enrollment reporting policies and procedures to ensure compliance and prevent future discrepancies.

Finding Text

Federal Agency: Department of Education Federal program title: Student Financial Aid ClusterAssistance Listing Number: 84.033, 84.063, 84.007, 84.379, 84.268 Award Period: July 1, 2023, through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level as well as the program begin date. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Condition: Incorrect or untimely reporting by the University of Students’ Changes in status during the 2023-2024 award year under audit. Questioned costs: Unknown. Context: Out of the 17 students tested noted 1 or more discrepancies, as follows: • 5 students’ status was incorrectly reported to NSDLS. • 4 student’s’ enrollment effective date was not reported correctly to NSLDS. • 20 students’ enrollment status change was not reported to NSLDS within 60 days. Cause: Lack of appropriate policy and procedure in place regarding NSLDS enrollment reporting for the year under audit. Effect: Noncompliance with federal regulations which could lead to untimely and incorrect reporting of enrollment information to NSLDS. Repeat Finding: Yes – 2023-02 Recommendation: We recommend that the University review their enrollment reporting policies and procedures to ensure accurate reporting. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.

Corrective Action Plan

Department of Education NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033 Auditors’ Recommendation: The University must review their enrollment reporting policies and procedures to ensure accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Point University uses National Student Clearinghouse (NSC) for the enrollment reporting process. The registrar’s office prepares a monthly enrollment change report which is sent to NSC. NSC processes the report and returns a file for any discrepancies and potential errors for the school to fix. The school reviews and makes any necessary updates and submits the report to NSC. NSC updates the enrollment information at NSLDS. For graduated students, the school also submits a degree verification file at the end of each term after graduated status is assigned by the school. This file is separate from the enrollment reporting file. The school inquired as to why the updates were not completed and found that updating enrollment status is not part of NSC’s process for the degree verification files. Moving forward, the registrar will submit a separate enrollment report file along with the degree verification to ensure that graduate status is updated at NSC and NSLDS after the school assigns them. During the 2024-2025 school year, while the school was reviewing FVT/GE reporting that was due in January of 2025, the school was able to review enrollment data that had been reported to NSC for the 2023-24 school year and make corrections to that data. Moving forward, the enrollment data is maintained in the new student information system and updated in real time by the registrar’s office prior to the enrollment reports being sent to NSC. Of the 33 students reviewed for NSLDS enrollment status, five had errors. All five students were graduates whose status errors were related to data migration. All five were corrected during the school’s review of enrollment statuses while reviewing data for the FVT/GE reporting, which was done November 2025 through January 2025. Documentation of corrected enrollment statuses with the dates of the certification corrections is attached as Appendix 2024-002A. Name(s) of the contact person(s) responsible for corrective action: Natalie Brown-Motes, Point University Registrar, natalie.brown@point.edu Planned completion date for corrective action plan: FVT/GE status review is completed. School has process in place moving forward for updating graduated students beginning with Spring 2025 semester.

Other Findings in this Audit

547389 2024-002

Significant Deficiency Repeat
547390 2024-002

Significant Deficiency Repeat
547391 2024-002

Significant Deficiency Repeat
1123830 2024-002

Significant Deficiency Repeat
1123831 2024-002

Significant Deficiency Repeat
1123832 2024-002

Significant Deficiency Repeat
1123833 2024-002

Significant Deficiency Repeat

Programs in Audit

ALN	Program Name	Expenditures
84.268	Federal Direct Student Loans	$3.95M
84.063	Federal Pell Grant Program	$3.56M
84.007	Federal Supplemental Educational Opportunity Grants	$59,441
84.033	Federal Work-Study Program	$4,326