Hofstra UniversityHigher Education

Finding No. 2025-001 Special Tests and Provisions – NSLDS Reporting U.S. Department of Education: Student Financial Assistance Cluster: Federal Pell Grant (ALN 84.063) Federal Grant Number: P063P241851 Statistically Valid Sample: No and it was intended to be. Prior Year Finding: Not a repeat finding. 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 transmission of its enrollment reporting changes including, but not limited to withdrawals and graduate status to the NSLDS. The University receives the Enrollment Reporting Roster and makes necessary updates for changes in student status. A final file is then sent to the Clearinghouse who transmits information or corrections to NSLDS. For 1 student in our sample of 40, the effective status of graduation was not accurately reported to NSLDS within 60 days of the status change. The status change was submitted and certified by NSLDS 228 days late. This student received an error code of 253 or 290, which represents an error in the student’s social security number (SSN). Upon further review, the University identified 10 other students that had this same error code during fiscal year 2025. One of these students had a status change which was not reported to NSLDS timely, and it was submitted and certified by NSLDS 494 days late. Cause: This error was caused by an incorrect assumption in the Registrar’s procedures that students who returned this error from the Clearinghouse were non-Title IV aid students. While the Registrar worked to rectify these errors with the Clearinghouse, the Registrar’s Office did not update the student’s status in NSLDS independently because management believed these students did not receive Title IV aid. Effect: Student status changes not reported in a timely or accurate manner may cause the student to not enter repayment status for Federal Direct Student Loans on a timely basis. A change in status for a student receiving a Pell Grant will impact the amount they are eligible to receive Question Costs: None. Recommendation: We recommend that management incorporate procedures in their process to review the error reports received from the Clearinghouse specifically for this error code, which should include the determination of whether these students had received Title IV aid.   View of Responsible Officials: Management agrees with the finding. Students on the reject detail from the Clearinghouse enrollment submission who receive a 253 or 290 error will be reviewed using a Financial Aid provided report to determine if any have been awarded aid. Financial Aid will provide the FAFSA support to correct the Clearinghouse error for students who have received aid. We will also manually report those student statuses to the NSLDS while the errors are being corrected by the Clearinghouse for anyone receiving aid so status changes are reported timely. For students that do not have FAFSA information with Financial Aid, we will contact those students directly for documentation to correct or affirm their SSN information to try and resolve any future 253 or 290 errors.

2021 001 Significant Deficiency and Noncompliance: Eligibility Federal Program Student Financial Assistance Cluster: Federal Direct Loan Program ALN 84.268 Award Number: P268K201851 and P268K211851 Federal Agency U.S. Department of Education Federal Award Year September 1, 2020 to August 31, 2021 Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Criteria In accordance with 34 CFR 668.32(g)(2), institutions must ensure students do not obtain loans in excess of the annual or aggregate limits under any Title IV, Higher Education Act program. Additionally, awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need based aid) to ensure that total aid is not awarded in excess of the student?s financial need or cost of attendance. Direct Subsidized Loans and Direct Unsubsidized Loans have loan limits that vary based on the student?s grade level and dependency status. The annual loan limit is the maximum amount that a student may receive for an academic year while the aggregate loan limits for Direct Subsidized Loans and Direct Unsubsidized Loans is the maximum allowable outstanding loan debt, excluding capitalized interest, but including amounts borrowed under the Federal Family Education Loan program prior to 2010. Condition and Context KPMG tested a sample of 40 students who received various forms of Direct Loans. For 1 student in our sample, the aggregate Direct Loans provided, exceeded the aggregate limit by $3,750. Cause and Effect/Potential Effect As part of standard procedures, the Office of Financial Aid (OFA) produces a `Subsequent Transaction Report? (Report), which identifies students who receive a subsequent ISIR with C Flags. Receipt of a subsequent ISIR indicates that there is updated student information (such as those associated with aggregate loan limits). The Report is run by OFA weekly. Although the Report was run and appropriately identified the student as having a C Flag comment code requiring further investigation or resolution, the Report was not reviewed and therefore no corrective action was taken resulting in the over award of direct loans. Questioned Costs A review of students with similar C flags was performed and an additional four students were identified to have been awarded loans in excess of the established loan limits. The total amount of overpayments including the student in our initial sample, was approximately $36,000. Recommendation We recommend that the University reinforce its policies and procedures to ensure persons responsible for resolving issues in exception reports perform their duties in a timely manner. Such procedures should also include a formal review by management to ensure the resolution is appropriate and compliant with the respective requirements.

2021 002 Significant Deficiency and Noncompliance: Special Tests and Provisions ? Verification Federal Program Student Financial Assistance Cluster: Federal Work Study Program ALN 84.033 Federal Direct Loan Program ALN 84.268 Federal Pell Grant Program ALN 84.063 Federal Supplemental Education Opportunity Grant Program ALN 84.007 Federal Teacher Education Assistance for College and Higher Education (TEACH) ALN 84.379 Award Number Federal Work Study Program - P033A202815 and P033A212815 Federal Direct Loan Program - P268K201851 and P268K211851 Federal Pell Grant Program - P063P201851 and P063P211851 Federal Supplemental Education Opportunity Grant Program - P007A202815 Federal Teacher Education Assistance for College and Higher Education (TEACH) - P379T211851 Federal Agency U.S. Department of Education Federal Award Year September 1, 2020 to August 31, 2021 Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Criteria An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by the Department of Education (ED). The institution shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. The institution shall also require applicants to verify any information used to calculate an applicant?s EFC that the institution has reason to believe is inaccurate. Condition and Context KPMG tested a sample of 40 students who were selected for verification by ED. For 3 students in our sample, the University either (1) did not account for an education credit resulting in an overstatement of the student?s EFC (2) completed the verification based on the incorrect criteria or (3) incorrectly calculated the adjusted gross income resulting in an understatement of EFC. Cause and Effect/Potential Effect In each case, the cause of noncompliance was human error. The individuals responsible for verifying the students? information completed the process using incorrect information or based on the incorrect criteria. These errors resulted in the incorrect calculation of the students? EFC or improper completion of verification. Questioned Costs The overstatement of the EFC as noted above resulted in an overpayment of $1,550 of Pell grant to the student. Recommendation While there is a formal review performed by management, we recommend that the review be enhanced to ensure the findings noted are identified and resolved in a timely manner.

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