Fairfield UniversityHigher Education

Finding 2025-001 – NSLDS Reporting Federal Program: Student Financial Assistance Cluster Listing Number: 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Program Federal Agency: U.S. Department of Education Award Year: July 1, 2024 – June 30, 2025 Finding Type: Significant Deficiency and Noncompliance Criteria: Institutions are required to report enrollment information under the Pell Grant and the Direct Loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). 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 certify 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 Professional Access (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. 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. Institutions are responsible for accurately reporting all Campus-Level Record data elements. ED considers the following data elements to be high risk: • OPEID Number, Enrollment Effective Date, Enrollment Status, Certification Date Institutions are responsible for accurately reporting all Program-Level Record data elements. ED considers the following data elements to be high risk: • OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Effective Date Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. 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 (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309: Perkins 34 CFR 674.19(f). Additionally, in accordance with 2 CFR 200.303, the University shall maintain internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program. Condition and Context: The University utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for transmissions of its enrollment reporting changes to the National Student Loan Data System (NSLDS). The University receives the NSLDS Reporting Roster and updates it for changes in student status. The file is sent to the Clearinghouse who transmits the updated information to NSLDS. Of the 25 students with enrollment changes we selected for test work, we noted that for one student, the University did not report the student’s status or enrollment change accurately to NSLDS within the required 60 days period. The student identified was reported 110 days late. After further analysis provided by the University, there were a total of 21 students who were impacted by this issue. Cause: For the aforementioned 21 students, the University’s internal control processes did not operate consistently to ensure that all enrollment information were submitted timely to NSLDS. Effect: Untimely submission of student enrollment status information affects the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Questioned Costs: None noted. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Identification of whether the Audit Finding was a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the University review and revise its processes and internal controls to ensure that all enrollment information and status changes are reported to the NSLDS in a timely manner. View of Responsible Officials Management of the University agrees with the recommendation. The corrective action by Corry Unis, Vice President for Enrollment Management and Diana Draper, Executive Director of Financial Aid is as follows: The University has subsequently reported 12 of the 21 students to NSLDS. The University will update the enrollment reporting to NSLDS for the remaining 9 students impacted. The University will determine the principal cause of the discrepancy and implement a combination of controls, monitoring, and training to ensure accuracy and timeliness of future reporting.

Student Financial Assistance Cluster: U.S. Department of Education: Federal Pell Grant Program – ALN 84.063 Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement – Reporting Criteria Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD) system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method (see Federal Register, Volume 86, Number 119, June 24, 2021). The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition and Context We selected forty students who received a Pell Grant disbursement and the following exceptions. • For two Pell Grant disbursements, the disbursement was not reported within 15 days to the COD system. Both disbursements were reported 19 days late. Cause The students involved in this finding were students who received Pell Grant and were enrolled in the Winter and Spring 2024 semesters. The University identified an issue in reporting for the Spring 2024 semester and the reconciliation of Pell Grant disbursements for students that received Pell Grant for the Winter and Spring 2024 semester was delayed. The disbursements were correctly reported to the COD system, however, outside of the 15 day reporting requirement. Effect Disbursements not reported in a timely manner could result in discrepancies between University disbursement records and COD system disbursement records. Questioned Costs There were no questioned costs related to this finding. Recommendation We recommend the University reinforces its policies and procedures for persons responsible for reporting Pell Grant disbursements to the COD system to ensure compliance with the requirement of submitting disbursements in a timely manner. Views of Responsible Official Management of the University agrees with the recommendation. The corrective action by Corry Unis, Vice President for Enrollment Management and Diana Draper, Executive Director of Financial Aid is as follows: Initial corrective action was taken by Diana Draper, Financial Aid Director, in March 2024 when the student disbursements were reports to COD. Additional corrective actions included systematic controls, additional training, and greater internal monitoring and auditing have been put in place.

Finding No. 2023-001 Student Financial Assistance Cluster: U.S. Department of Education: Federal Pell Grant Program – ALN 84.063 Federal Direct Loan Program – ALN 84.268 Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement – Special Tests and Provisions – Enrollment Reporting – Significant Deficiency and Noncompliance Criteria Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the NSLDS (OMB No. 1845-0035). 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 certify 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 Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. 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 within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. 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 (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Condition and Context We selected twenty-five students who received a Federal Direct Loan or a Pell Grant and whose enrollment status changed during the year and noted the following exceptions. • For twenty-five enrollment status changes, the status change was not reported within 60 days. Twenty-four of these twenty-five were reported 85 days late, and the last was reported 193 days late. Cause The students involved in this finding were all students who graduated. The University uses the National Student Clearinghouse (NSC) to report enrollment information to the NSLDS. The University submitted graduation status changes through the degree verify file on a timely basis to the NSC. However, the NSC did not timely notify the University to file the graduates only enrollment report to the NSC and therefore, the NSLDS. The University subsequently provided the graduates only enrollment report to the NSC outside of the 60 calendar day reporting requirement. Effect Enrollment status changes not reported in a timely manner could impact the timeliness of the student entering repayment status. Questioned Costs There were no questioned costs related to this finding. Recommendation We recommend the University reinforces its policies and procedures for persons responsible for reporting status changes to the service provider to ensure compliance with the requirement of submitting accurate and complete enrollment reports in a timely manner to the NSLDS. Views of Responsible Official Management of the University agrees with the recommendation. Corrective action by the Provost for Graduate Continuing and Professional Studies and University Registrar is as follows: The graduates only enrollment report will be supplied to the NSC by the Registrar’s Office on a consistent schedule of submission within 60 days of each graduation period. Initial corrective action was completed by the University Registrar’s office in October, 2023 with the submission of a graduates only enrollment report to the NSC. A schedule for consistent submissions of a graduates only enrollment report has already been provided to the NSC.

Finding No. 2023-001 Student Financial Assistance Cluster: U.S. Department of Education: Federal Pell Grant Program – ALN 84.063 Federal Direct Loan Program – ALN 84.268 Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement – Special Tests and Provisions – Enrollment Reporting – Significant Deficiency and Noncompliance Criteria Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the NSLDS (OMB No. 1845-0035). 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 certify 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 Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. 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 within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. 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 (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Condition and Context We selected twenty-five students who received a Federal Direct Loan or a Pell Grant and whose enrollment status changed during the year and noted the following exceptions. • For twenty-five enrollment status changes, the status change was not reported within 60 days. Twenty-four of these twenty-five were reported 85 days late, and the last was reported 193 days late. Cause The students involved in this finding were all students who graduated. The University uses the National Student Clearinghouse (NSC) to report enrollment information to the NSLDS. The University submitted graduation status changes through the degree verify file on a timely basis to the NSC. However, the NSC did not timely notify the University to file the graduates only enrollment report to the NSC and therefore, the NSLDS. The University subsequently provided the graduates only enrollment report to the NSC outside of the 60 calendar day reporting requirement. Effect Enrollment status changes not reported in a timely manner could impact the timeliness of the student entering repayment status. Questioned Costs There were no questioned costs related to this finding. Recommendation We recommend the University reinforces its policies and procedures for persons responsible for reporting status changes to the service provider to ensure compliance with the requirement of submitting accurate and complete enrollment reports in a timely manner to the NSLDS. Views of Responsible Official Management of the University agrees with the recommendation. Corrective action by the Provost for Graduate Continuing and Professional Studies and University Registrar is as follows: The graduates only enrollment report will be supplied to the NSC by the Registrar’s Office on a consistent schedule of submission within 60 days of each graduation period. Initial corrective action was completed by the University Registrar’s office in October, 2023 with the submission of a graduates only enrollment report to the NSC. A schedule for consistent submissions of a graduates only enrollment report has already been provided to the NSC.

Finding No. 2023-001 Student Financial Assistance Cluster: U.S. Department of Education: Federal Pell Grant Program – ALN 84.063 Federal Direct Loan Program – ALN 84.268 Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement – Special Tests and Provisions – Enrollment Reporting – Significant Deficiency and Noncompliance Criteria Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the NSLDS (OMB No. 1845-0035). 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 certify 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 Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. 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 within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. 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 (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Condition and Context We selected twenty-five students who received a Federal Direct Loan or a Pell Grant and whose enrollment status changed during the year and noted the following exceptions. • For twenty-five enrollment status changes, the status change was not reported within 60 days. Twenty-four of these twenty-five were reported 85 days late, and the last was reported 193 days late. Cause The students involved in this finding were all students who graduated. The University uses the National Student Clearinghouse (NSC) to report enrollment information to the NSLDS. The University submitted graduation status changes through the degree verify file on a timely basis to the NSC. However, the NSC did not timely notify the University to file the graduates only enrollment report to the NSC and therefore, the NSLDS. The University subsequently provided the graduates only enrollment report to the NSC outside of the 60 calendar day reporting requirement. Effect Enrollment status changes not reported in a timely manner could impact the timeliness of the student entering repayment status. Questioned Costs There were no questioned costs related to this finding. Recommendation We recommend the University reinforces its policies and procedures for persons responsible for reporting status changes to the service provider to ensure compliance with the requirement of submitting accurate and complete enrollment reports in a timely manner to the NSLDS. Views of Responsible Official Management of the University agrees with the recommendation. Corrective action by the Provost for Graduate Continuing and Professional Studies and University Registrar is as follows: The graduates only enrollment report will be supplied to the NSC by the Registrar’s Office on a consistent schedule of submission within 60 days of each graduation period. Initial corrective action was completed by the University Registrar’s office in October, 2023 with the submission of a graduates only enrollment report to the NSC. A schedule for consistent submissions of a graduates only enrollment report has already been provided to the NSC.

Finding No. 2023-001 Student Financial Assistance Cluster: U.S. Department of Education: Federal Pell Grant Program – ALN 84.063 Federal Direct Loan Program – ALN 84.268 Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement – Special Tests and Provisions – Enrollment Reporting – Significant Deficiency and Noncompliance Criteria Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the NSLDS (OMB No. 1845-0035). 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 certify 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 Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. 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 within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. 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 (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). Condition and Context We selected twenty-five students who received a Federal Direct Loan or a Pell Grant and whose enrollment status changed during the year and noted the following exceptions. • For twenty-five enrollment status changes, the status change was not reported within 60 days. Twenty-four of these twenty-five were reported 85 days late, and the last was reported 193 days late. Cause The students involved in this finding were all students who graduated. The University uses the National Student Clearinghouse (NSC) to report enrollment information to the NSLDS. The University submitted graduation status changes through the degree verify file on a timely basis to the NSC. However, the NSC did not timely notify the University to file the graduates only enrollment report to the NSC and therefore, the NSLDS. The University subsequently provided the graduates only enrollment report to the NSC outside of the 60 calendar day reporting requirement. Effect Enrollment status changes not reported in a timely manner could impact the timeliness of the student entering repayment status. Questioned Costs There were no questioned costs related to this finding. Recommendation We recommend the University reinforces its policies and procedures for persons responsible for reporting status changes to the service provider to ensure compliance with the requirement of submitting accurate and complete enrollment reports in a timely manner to the NSLDS. Views of Responsible Official Management of the University agrees with the recommendation. Corrective action by the Provost for Graduate Continuing and Professional Studies and University Registrar is as follows: The graduates only enrollment report will be supplied to the NSC by the Registrar’s Office on a consistent schedule of submission within 60 days of each graduation period. Initial corrective action was completed by the University Registrar’s office in October, 2023 with the submission of a graduates only enrollment report to the NSC. A schedule for consistent submissions of a graduates only enrollment report has already been provided to the NSC.