Iona UniversityHigher Education

Finding 2025-001 – N. Special Tests and Provisions – National Student Loan Data System Reporting Identification of the Federal Program(s) – Federal Direct Student Loan Program (Federal Assistance Listing #84.268) Criteria or Specific Requirement - Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). 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. Campus Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month. Program Level: Institutions are responsible for accurate and timely reporting of certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including OPEID number, CIP code, CIP year, credit level, program enrollment status, program enrollment effective date, program length, and program begin date. Condition – The University did not accurately report a student’s significant data elements under the Program-Level record on the NSLDS website. Cause – Administrative oversight over NSLDS reporting requirements. Effect or Potential Effect – The University was not in compliance with the NSLDS reporting requirements. Questioned Costs – None. Context – 1 of 40 students selected for Program-Level testing. Indication of Repeat Finding – This was reported as finding 2024-001 in the prior year. Recommendation – We recommend that the University enhance its procedures over NSLDS reporting requirements to ensure that Program-Level data elements are properly reported. Views of Responsible Officials – Management acknowledges the finding regarding the inaccurate reporting of student data elements under the Program-Level record on the NSLDS website. We also acknowledge that this is technically a repeat finding from the prior year; however, the finding identified for one student out of the forty students selected was prior to the implementation of the University’s Corrective Action Plan on January 31, 2025. The University previously addressed this issue and implemented a corrective action plan that included updating our reporting frequency and enhancing our data review processes as follows: Updated Reporting Frequency: As of January 2025, the University now includes the non-compulsory terms, summer 1 and winter sessions, in its reporting. The previous institutional practice did not include reporting program-level data for these terms given that said terms do not involve federal financial aid. This change ensures that all program-level data, regardless of federal financial aid involvement, is accurately reported. Secondary Check Process: Each month, the Compliance Officer reviews a sample of 100 students from NSLDS to verify significant data elements, including program enrollment effective dates. After the initial review, the Compliance Officer summarizes the findings and shares them with the Associate Registrar and Registrar for a secondary review. Any necessary edits are made, followed by a review of an additional 25 students to ensure accuracy. We believe the corrective action steps are critical in ensuring accurate reporting and preventing this issue in the future, and we believe they have been effectively implemented. We believe that the fact that only one of forty students selected was reported incorrectly is an indication that our corrective action plan has been effective.

Finding 2024-001 – N. Special Tests and Provisions – Enrollment Reporting Information on Federal Program(s) – Federal Direct Student Loan Program (Federal Assistance Listing #84.268) Criteria or Specific Requirement - Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). 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. Campus Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month. Program Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including OPEID number, CIP code, CIP year, credit level, program enrollment status, program enrollment effective date, program length, and program begin date. Condition – The University did not accurately report a student’s significant data elements under the Program-Level record on the NSLDS website. Cause – Administrative oversight in internal controls over enrollment reporting requirements. Effect or Potential Effect – The University was not in compliance with the enrollment reporting requirements. Questioned Costs – None. Context – 1 of 25 students selected for testing. Indication of Repeat Finding – No similar finding identified during the prior year. Recommendation – We recommend that the University enhance its procedures and internal controls over enrollment reporting requirements. Views of Responsible Officials – Management acknowledges the finding regarding the inaccurate reporting of student data elements under the Program-Level record on the NSLDS website. To address this issue, the University has implemented a corrective action plan that includes updating our reporting frequency and enhancing our data review processes: Updated Reporting Frequency: As of January 2025, the University now includes the non-compulsory terms, summer 1 and winter sessions, in its reporting. Previous institutional practice did not include reporting program level data for these terms given that said terms do not involve federal financial aid. This change ensures that all Program-Level data, regardless of federal financial aid involvement, is accurately reported. Secondary Check Process: Each month, the Compliance Officer will review a sample of 100 students from NSLDS to verify significant data elements, including program enrollment effective dates. After the initial review, the Compliance Officer will summarize the findings and share them with the Associate Registrar and Registrar for a secondary review. Any necessary edits will be made, followed by a review of an additional 25 students to ensure accuracy. We believe these corrective action steps are critical to ensuring accurate reporting and preventing this issue in the future.

Federal Program Information: Federal Direct Student Loans (ALN# 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions ? Disbursements to or on Behalf of Students - An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to the U.S. Department of Education no later than 240 days after the date the school issued the check. Condition: The College did not pay a certain student his Title IV credit balance within the required timeframe. Cause: An administrative oversight resulted in the College erroneously crediting a student?s account with Federal Direct Loans program funds prior to the student having received entrance counseling. This matter was resolved subsequent to the 14-day refund requirement. Effect or Potential Effect: The College was not in compliance with the Title IV credit balance payment requirements. Questioned Costs: None. Context: For 1 of 25 credit balances tested, the College did not refund the student within the required 14-day timeframe. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College enhance its procedures to ensure that Title IV credit balances are paid timely. Views of Responsible Officials: Management of the College agrees with the finding. In this instance, there was a manual intervention which caused a loan to credit to the student account. A decision was made to leave the credit but not refund as a motivation for the student to complete the required Entrance Counseling. The student subsequently completed the Entrance Counseling when the loan credit was reversed. As soon as the Entrance Counseling was completed the loan was recredited and the refund was processed within the appropriate timeframe. The individual who made the decision to not refund is no longer with the University. Staff have been trained that, unless the borrower has completed all requirements, loans cannot be credited to an account and the ?do not refund? option is not an appropriate tool in such an instance.

Federal Program Information: Federal Supplemental Education Opportunity Grants (ALN# 84.007), Federal Pell Grant Program (ALN #84.063), Federal Direct Student Loans (ALN# 84.268) Criteria or Specific Requirement: N. Special Test and Provisions ? Return of Title IV Funds: When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. Additionally, returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the U.S. Department of Education no later than 45 days after the date the institution determines the student has withdrawn. Condition: The College did not prepare certain students? return calculations properly. Cause: Administrative oversight in determining the school days to be used in calculating the percentage of refunds to be disbursed. Effect or Potential Effect: Over or underpayment of Title IV funds. Questioned Costs: Below reporting threshold. Context: For 3 of 3 students selected for testing, the amounts to return were not calculated in accordance with the requirements. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College enhance its procedures over the preparation and review of R2T4 calculations to ensure that the school days used in calculating the percentage of refunds are in accordance with the federal requirements. Views of Responsible Officials: Management of the College agrees with this finding. The Registrar?s office updated the Holiday Calendar schedules in PeopleSoft, the Student Information System, to ensure that institutionally scheduled breaks of 5 or more consecutive days are properly reflecting weekend days. These updates will be used to accurately calculate the percent of a term attended and federal aid earned for federal aid recipients who withdraw from the University during a term as part of the Return to Title IV aid mandatory calculations. The calendar entries will be made by the Associate Registrar and reviewed and approved by the Registrar during the academic year set up process each academic year.

FINDING 2020-001 Federal Program Information: Student Financial Assistance Cluster (various CFDA numbers) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Enrollment Reporting - Iona College (the ?College?) is required to update students? statuses on the National Student Loans Data System (?NSLDS?) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the College becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements, it is the school that must ensure that enrollment information is submitted timely, accurately and completely. Condition: The College did not submit timely notification to the NSLDS website for one student who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year ended June 30, 2020. Cause: Oversight with respect to enrollment reporting requirements. Effect or Potential Effect: The College was not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.Questioned Costs: None. Context: One student per our sample selection for status change testing for the year ended June 30, 2020 was not reported to the NSLDS within the required time frames. This was corroborated during our audit procedures. Identification as a Repeat Finding: In the prior year, finding 2019-001 contained 97 instances of status changes that were not reported to the NSLDS timely. The College implemented certain controls during the year ended June 30, 2020 over status changes. During the execution of these new controls, the 1 student mentioned in the context section above was identified by the College as being out of compliance. The College corrected this student's status change, however, the correction was made 3 days outside of the required time frames. Recommendation: We recommend that the College properly follow its policies and procedures over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe. Views of Responsible Officials: Finding 2019-001 ? Special Tests and Provisions - Enrollment Reporting Finding Prior-Year Finding: The College did not submit notification to the NSLDS website for certain students who graduated, withdrew or had change in their enrollment status (full time, half time or less than half time) during the year ended June 30, 2019 within the required time frames. Current-Year Status: The policies and procedures for enrollment reporting were updated during the year ended June 30, 2020 to incorporate an additional check on Clearinghouse submissions to NSLDS, specifically to address status change record file errors. In addition to the staff member assigned to process enrollment files, a second staff member was assigned to check that the files are transmitted, and corrections are made in a timely fashion. As a result of implementation of these procedures, 1 student with a status change was detected by the College to not have been properly reflected in the NSLDS as having graduated during the year ended June 30, 2020. The College corrected this status change during the year ended June 30, 2020, however the correction was outside the required time frame by 3 days. This 1 student is part of finding 2020-001.

FINDING 2019-001 Federal Program Information: Student Financial Assistance Cluster (various CFDA numbers) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions - Enrollment Reporting - The College is required to update students? statuses on the National Student Loans Data System (?NSLDS?) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the College becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements, it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Condition: The College did not submit timely notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year ended June 30, 2019. Cause: Oversight with respect to enrollment reporting requirements. Effect or Potential Effect: The College was not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: Prior to the commencement of our 2019 Single Audit, management self-reported that 97 students that received Student Financial Assistance Cluster aid and had student status changes during the year ended June 30, 2019 were not reported to the NSLDS within the required time frames. This was corroborated during our audit procedures, where we noted that 41 of 60 students sampled for status change testing were not reported by the College to the NSLDS within the required time frames. The 41 student exceptions noted in our sample testing were a part of the 97 student exceptions that were self-reported by management. Identification as a Repeat Finding: This is a not a repeat finding from the prior year. Recommendation: We recommend that the College properly follow its policies and procedures over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe. Views of Responsible Officials: Please refer to the accompanying management?s corrective action plan.

GSA_MIGRATION