Finding 572429 (2025-001)

Significant Deficiency Repeat Finding

Requirement

Questioned Costs

Year

2025

Accepted

2025-08-01

Audit: 363564

Organization: Regis University (CO)

Auditor: Rubinbrown LLP

AI Summary

Core Issue: The University failed to certify enrollment changes within the required 60 days, risking inaccuracies in reporting.
Impacted Requirements: Compliance with 34 CFR 682.610 and NSLDS guidelines for timely enrollment data reporting.
Recommended Follow-Up: Revise processes and controls to ensure all enrollment status changes are reported within the 60-day timeframe.

Finding Text

Finding 2025-001 - Significant Deficiency: Special Tests and Provisions - Compliance and Control Finding ALN 84.063 - Federal Pell Grant Program and 84.268 - Federal Direct Student Loan Program - Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 682.610 (and further clarified in the November 2022 National Student Loan Data System (NSLDS) Enrollment Reporting Guide), a University is required to certify changes in enrollment data for students within 60 days of the change. Universities are responsible for accurately reporting certain key information, such as the OPEID number, enrollment effective date, enrollment status, graduation status and certification date. Condition: The University has established several processes and procedures to ensure that enrollment reporting occurs on a timely basis. These processes and procedures rely on an internal reporting mechanism that assesses a multitude of factors, including the end date on programs with a future term. The end date on programs is a key data point to ensure that enrollment reporting is occurring in a timely manner. Cause: The process and related internal controls surrounding enrollment reporting related to degree verification through the National Student Clearinghouse (NSC) were not designed to ensure timely certification of enrollment reporting changes for graduation statuses, within the 60-day requirement period to NSLDS. Effect: The University’s controls may not prevent potential errors related to timely certification of enrollment reporting. Questioned Costs: Not applicable. Context: Our audit sample of 40 students, we noted 2 student that was updated in NSLDS outside of the 60-day requirement period. Identification As A Repeat Finding: 2024-002. Recommendation: The University should revise the process and internal controls surrounding enrollment reporting to ensure that all enrollment reporting status changes are certified to NSC and thereby NSLDS within the 60-day requirement period. Views Of Responsible Officials: The University acknowledges that the enrollment reporting controls need to be enhanced to ensure timely submission to NSLDS.

Corrective Action Plan

Finding 2025-001 Personnel Responsible for Corrective Action: Deborah Vinnola, Registrar Anticipated Completion Date: September 30, 2025 Corrective Action Plan: The Office of the Registrar has put into place a more detailed corrective action plan regarding the finding of delayed enrollment and non-enrollment reporting to NSLDS through NSC. The Office of the Registrar has adjusted the Degree Verify submission from every 45 days to every 30 days to NSC to ensure graduation dates are reported in a more timely fashion for NSLDS within the required 60 days for financial aid. Starting Summer 2025, the Office of the Registrar has begun inactivating academic programs for students who have not had registration activity within the last two to three academic years to ensure that they are not reported as enrolled to NSC/NSLDS. NSC Enrollment Reporting will continue to be submitted every 30 days and the Office of the Registrar has worked to review the reporting criteria using terms and not semesters to better report active enrollment in current courses. The Ellucian Graduation Application form and process is in the final stages of testing which will eliminate completely the need to add a pseudo course with a future date after the student’s current program has been inactivated or graduated. The Office of the Registrar will be more proactive with the colleges for identifying students who have not graduated within the six year (undergraduate), four year (graduate) and certificate time frames by working with the appropriate dean’s offices. This should eliminate those students who have completed their coursework; close to completing their coursework but were never reviewed by their advisor/program for graduation. Since Regis uses the end date of the last course completed, the Office of the Registrar will work with advising units to review the lists to increase a better reporting of degree completion.

Other Findings in this Audit

572430 2025-001

Significant Deficiency Repeat
1148871 2025-001

Significant Deficiency Repeat
1148872 2025-001

Significant Deficiency Repeat

Programs in Audit

ALN	Program Name	Expenditures
84.268	Federal Direct Student Loans	$43.72M
84.063	Federal Pell Grant Program	$6.69M
93.364	Nursing Student Loans	$1.22M
84.033	Federal Work-Study Program	$1.01M
84.038	Federal Perkins Loan Program_federal Capital Contributions	$665,727
84.007	Federal Supplemental Educational Opportunity Grants	$283,569
93.264	Nurse Faculty Loan Program (nflp)	$206,792
93.865	Child Health and Human Development Extramural Research	$96,239
84.379	Teacher Education Assistance for College and Higher Education Grants (teach Grants)	$82,513
47.049	Mathematical and Physical Sciences	$76,251
12.903	Gencyber Grants Program	$31,952