Finding Text
Finding 2023-002 – Special Tests and Provisions – Enrollment Reporting – Significant Deficiency in Internal Control Over Compliance
(See Section III - Federal Awards Findings - Finding 2023-002 for included table)
Criteria: The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information. It is Woodbury University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes. Woodbury University is ultimately responsible for the timeliness and accuracy of this information even when a third-party servicer is used as an intermediary to report on the University’s behalf.
Woodbury University currently contracts with a third-party servicer and has elected to receive an Enrollment Reporting roster file every 30 days from NSLDS. At a minimum, institutions must certify the enrollment status of all students included on the roster file within 15 days of receiving the roster file. If errors are identified, the University has 10 days to resubmit a corrected response.
Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received federal aid either did not enroll or ceased to be enrolled on at least a half-time basis (34 CFR section 685.309).
Condition/context: We selected a sample of students identified by Woodbury University as having received some federal assistance and who either withdrew, took a leave of absence (LOA), or graduated during the year ended June 30, 2023. Our sample consisted of 2 students out of a population of 3 that withdrew or took a LOA during the year and a sample of 13 students out of a population of approximately 122 that graduated during the year. We then compared the enrollment information and withdrawal, LOA, or graduation date per Woodbury University’s records to the information reported to NSLDS. We believe this to be a representative sample of the population. We noted exceptions with all Spring 2023 graduates, of which there were 11 in our sample, whose status change was not reported within the required time frame.
Questioned Costs: No questioned costs were identified as part of this finding.
Effect: Enrollment status is utilized by students, ED, the Direct Loan program, lenders, and other institutions to determine in-school status. NSLDS also uses the newly submitted enrollment data to recalculate a student’s 150% limit for direct subsidized loans to determine if loss or protection of the subsidy should occur. Therefore, this significant deficiency in enrollment reporting could result in incorrect future eligibility for undergraduate aid, as well as impact future subsidy loss or protection related to the 150% limit.
Cause: The lack of timely reporting was caused by turnover in the Registrar’s office.
Repeat finding: This is not a repeat finding.
Recommendation: Woodbury University should develop additional procedures and controls to monitor the accuracy of information provided to its third-party servicer and to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate. Each institution has access to manually correct information directly within NSLDS at any time.
Views of responsible officials and planned corrective actions: Management agrees with the finding and recommendation and plans to implement additional controls.