Monmouth University

2022-001 Enrollment Reporting Student Financial Assistance Cluster: U.S. Department of Education: Federal Direct Student Loan Program (ALN 84.268) Federal Pell Grant Program (ALN 84.063) Federal Grant Numbers: P063P210268 (07/01/2021-06/30/2022), P268K220268 (07/01/2021-06/30/2022) Statistically Valid Sample: No, and it was not intended to be Prior Year Finding: N/A Finding Type: Significant Deficiency and Noncompliance Criteria Under the Pell grant and the Direct and Federal Family Education Loan programs, institutions are required to report enrollment information 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 verify 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 information. 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 the following significant data elements under the Campus-Level Record that the Department of Education (ED) considers high risk: ? OPEID number, enrollment effective date, enrollment status and certification date Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk: ? OPEID number, CIP code, CIP year, credential level, published program length measurement, published program length, program begin date, program enrollment status and 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. Additionally, in accordance with Federal requirements, 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 Enrollment Reporting Roster and updates it for changes in student status. The file is sent to the Clearinghouse who transmits the updated information to NSLDS. There were 40 students selected for testwork, and the following exception was identified: ? For 1 of the 40 students selected for testwork, the University did not report the student?s status change as graduated to NSLDS on the Campus-Level Record. Cause There was an error when the University attempted to update the student?s status in the Campus-Level and Program-Level records in NSLDS. When taking action on the error, only the student?s Program-Level record was updated with the graduated enrollment status. The student?s status in the Campus-Level record was not updated to graduated. Effect Student status changes not reported in an accurate or timely manner will cause the student to not enter into repayment status on a timely basis. Questioned Costs No questioned costs were noted as a result of the audit procedures performed. Recommendation We recommend the University review its current policies and procedures to ensure that all status changes are reported to NSLDS correctly at both the Campus-Level and Program-Level, within the required timeframe. Views of Responsible Officials During fiscal year 2022, a student was found to have been reported as withdrawn, when they, in fact, graduated. The University determined that when it was notified by the Clearinghouse) that the student?s graduation status did not generate, the University made the correction to the Program-Level record status, but failed to update the Campus-Level record status. Therefore, when the ?First of Term? file for the Fall term was transmitted, the student was not included, and was incorrectly reported as withdrawn. As part of a corrective action, the University immediately corrected the Campus-Level Record status for the student to graduated and confirmed that the updated status was reported to NSLDS. Effective immediately, the University?s business practice will include using a two-person team to review the Clearinghouse error resolution reports to ensure that all corrections are made on both the Program-Level and the Campus-Level records to ensure that they are properly reflected in NSLDS.

Corrective Action Plan Year Ended June 30, 2022 Findings Related to the Financial Statements Reported in Accordance with Government Auditing Standards None Findings Related to Federal Awards 2022-001 Special Tests -Enrollment Reporting Federal Agency: U.S. Department of Education Program Titles and CFDA Numbers: Federal Direct Student Loan Program (ALN 84,268), Federal Pell Grant Program (ALN 84.063) Federal Grant Numbers: P063Pl90268 (07/0 l/2021-06/30/2022), P268K200268 (07/0l/2021-06/30/2022) Contact Person: Mary Byrne, A VP for Finance & Controller, (732) 571-3404 Corrective Action: During fiscal year 2022, a student was found to have been reported as withdrawn, when they, in fact, graduated. The University determined that when it was notified by the National Student Clearinghouse (the Clearinghouse) that the student's graduation status did not generate, the University made the correction to the Program-Level record status, but failed to update the Campus-Level record status. Therefore, when the first enrollment file for the Fall term was transmitted, the student was not included, and was incorrectly reported as withdrawn. As part of a corrective action, the University immediately corrected the Campus-Level Record status for the student to graduated and confirmed that the updated status was reported to the National Student Loan Data System (NSLDS). Effective immediately, the University's business practice will include using a two-person team to review the Clearinghouse error resolution to ensure that all corrections are made on both the Program-Level and the Campus-Level records to ensure that they are properly reflected in NSLDS. Anticipated Completion Date: January 2023

2021 001 Enrollment Reporting Student Financial Assistance Cluster: U.S. Department of Education: Federal Direct Student Loan Program (ALN 84.268) Federal Pell Grant Program (ALN 84.063) Federal Grant Numbers: P063P190268 (07/01/2020-06/30/2021), P268K200268 (07/01/2020-06/30/2021) Statistically Valid Sample: No, and it was not intended to be Prior Year Finding: 2020-001 Finding Type: Significant Deficiency and Noncompliance Criteria: Under the Pell grant and ED loan programs, institutions are required to report enrollment information 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 verify 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 information. 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 the following significant data elements under the Campus-Level Record that ED considers high risk: ? OPEID number, enrollment effective date, enrollment status and certification date Institutions are responsible for accurately reporting the following significant data elements under the Program Level Record that ED considers high risk: ? OPEID number, CIP code, CIP year, credential level, published program length measurement, published program length, program begin date, program enrollment status and program enrollment effective date Published Program Length should be reported based on the definition of ?normal time? to completion in the regulations at 34 CFR 668.41(a), as follows: ? If the school has published, in its catalog, on its website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school has published. ? If the school has not published a program length and the program is an associate or bachelor?s degree program, the program length to be reported should be two years (associate) or four years (bachelor), respectively, unless the academic design of the program makes it longer or shorter than the typical. ? For all other programs for which the school has not published a program length, the program length is based on the school?s determination of how long, in weeks, months, or years, the program is designed for a full-time student to complete. 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. Unless an institution expects to submit its next updated enrollment report to the Department within the next 60 days, an institution must notify NSLDS within 30 days after the date that the institution discovers that (1) a Direct loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (2) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. (34 CFR 685.309(a)(2) and 34 CFR 682.610(c)(2)) Additionally, in accordance with Federal requirements, 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 Enrollment Reporting Roster and updates it for changes in student status. The file is sent to the Clearinghouse who transmits the updated information to NSLDS. There were 40 students selected for testwork, and the following exceptions were identified: ? For 9 of the 40 students selected for testwork, the University did not report the correct published program length based on the type of program that the student was enrolled in. The University does not publish program lengths for its programs, therefore the published program length should be reported based on the definition of ?normal time? to completion in the regulations at 34 CFR 668.41(a). For bachelor?s degree, the published program length should be reported as four years and the published program length reported by the University for 8 of the students selected in our testwork was 4.285 years. For all other programs for which the school has not published a program length, the program length is based on the school?s determination of how long, the program is designed for a full-time student to complete. The published program length reported by the University for one of the students selected for testwork was 60 weeks when the published program length should have been reported as 30 weeks. Cause: There was an error in calculating the published program length for undergraduate students and therefore the information was not properly transmitted to NSLDS for the exceptions noted. Effect: Published program length which is not reported accurately will result in an incorrect calculation of a student?s maximum and remaining eligibility periods under the 150% limit. The 150% limit states that in general, a student may not receive Direct Subsidized Loans for more than their maximum eligibility period which is 150% of the published length of their program. If the published program length is not reported correctly, the maximum eligibility period may not be properly calculated. Questioned Costs: No questioned costs were noted as a result of the audit procedures performed. Recommendation: We recommend the University review its current policies and procedures for calculating the published program length for each student and ensure that it is accurately reported to the NSLDS. Views of Responsible Officials: During the fiscal year 2020 audit, the University found that there was an error in the computer program used to calculate the published program length within the program level details for students who had not yet submitted an application for graduation at the time the program was executed. The University corrected the computer program in January 2021. In addition, as a result of the fiscal year 2020 finding, the University began reviewing its program length calculations for all of its graduate programs. As part of this review, in June 2021 the University identified and corrected the program length for the respective graduate program referenced in the finding. Students included in the fiscal year 2021 finding were all students who withdrew or took a leave of absence prior to the January 2021 computer program correction and prior to the University completing its internal review of graduate program lengths. As a result of the current year finding, the University has developed an internal program length calculation review and reconciliation that will be conducted prior to the start of each academic term.

Corrective Action Plan Year Ended June 30, 2021 Findings Related to the Financial Statements Reported in Accordance with Government Auditing Standards None Findings Related to Federal Awards 2021 001 Special Tests ? Enrollment Reporting Federal Agency: U.S. Department of Education Program Titles and CFDA Numbers: Federal Direct Student Loan Program (ALN 84.268), Federal Pell Grant Program (ALN 84.063) Federal Grant Numbers: P063P190268 (07/01/2020-06/30/2021), P268K200268 (07/01/2020-06/30/2021) Contact Person: Mary Byrne, AVP for Finance & Controller, (732) 571-3404 Corrective Action: During the fiscal year 2020 audit, the University found that there was an error in the computer program used to calculate the published program length within the program level details for students who had not yet submitted an application for graduation at the time the program was executed. The University corrected the computer program in January 2021. In addition, as a result of the fiscal year 2020 finding, the University began reviewing its program length calculations for all of its graduate programs. As part of this review, in June 2021 the University identified and corrected the program length for the respective graduate program referenced in the finding. Students included in the fiscal year 2021 finding were all students who withdrew or took a leave of absence prior to the January 2021 computer program correction and prior to the University completing its internal review of graduate program lengths. As a result of the current year finding the University has developed an internal program length calculation review and reconciliation that will be conducted prior to the start of each academic term. Anticipated Completion Date: March 2022

2020-001

2020 001 Enrollment Reporting Student Financial Assistance Cluster: U.S. Department of Education: Federal Direct Student Loan Program (CFDA #84.268) Federal Pell Grant Program (CFDA #84.063) Federal Grant Numbers: P063P190268 (07/01/2019-06/30/2020), P268K200268 (07/01/2019-06/30/2020) Statistically Valid Sample: No, and it was not intended to be Prior Year Finding: N/A Finding Type: Significant Deficiency and Noncompliance Criteria: Under the Pell grant and ED loan programs, institutions are required to report enrollment information 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 verify 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 information. 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 the following significant data elements under the Campus-Level Record that ED considers high risk: ? OPEID number, enrollment effective date, enrollment status and certification date Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk: ? OPEID number, CIP code, CIP year, credential level, published program length measurement, published program length, program begin date, program enrollment status and program enrollment effective date Published Program Length should be reported based on the definition of ?normal time? to completion in the regulations at 34 CFR 668.41(a), as follows: ? If the school has published, in its catalog, on its website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school has published. ? If the school has not published a program length and the program is an associate or bachelor?s degree program, the program length to be reported should be two years (associate) or four years (bachelor), respectively, unless the academic design of the program makes it longer or shorter than the typical. ? For all other programs for which the school has not published a program length, the program length is based on the school?s determination of how long, in weeks, months, or years, the program is designed for a full-time student to complete. 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. Unless an institution expects to submit its next updated enrollment report to the Department within the next 60 days, an institution must notify NSLDS within 30 days after the date that the institution discovers that (1) a Direct loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (2) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. (34 CFR 685.309(a)(2) and 34 CFR 682.610(c)(2)) Additionally, in accordance with Federal requirements, 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 Enrollment Reporting Roster and updates it for changes in student status. The file is sent to the Clearinghouse who transmits the updated information to NSLDS. There were 40 students selected for testwork, and the following exceptions were identified: ? For 39 of the 40 students selected for testwork, the University did not report the correct published program length based on the type of program that the student was enrolled in. The University does not publish program lengths for its programs, therefore the published program length should be reported based on the definition of ?normal time? to completion in the regulations at 34 CFR 668.41(a). For bachelor?s degree, the published program length should be reported as four years and the published program length reported by the University for the students selected in our testwork was 4.285 years. For all other programs for which the school has not published a program length, the program length is based on the school?s determination of how long, in years, the program is designed for a full-time student to complete. The published program length reported by the University for the students selected for testwork ranged from 2.142 through 4.285. ? For 1 of the 40 students selected for testwork, the University did not report the student?s status change to NSLDS on the Campus-Level Record. Cause: There was an issue in calculating the published program length for students who had not yet submitted an application for graduation and therefore the information was not properly transmitted to NSLDS for the exceptions noted. Effect: Published program length which is not reported accurately will result in an incorrect calculation of a student?s maximum and remaining eligibility periods under the 150% limit. The 150% limit states that in general, a student may not receive Direct Subsidized Loans for more than their maximum eligibility period which is 150% of the published length of their program. If the published program length is not reported corrected, the maximum eligibility period may not be properly calculated. Student status changes not reported in an accurate or timely manner will cause the student to not enter into repayment status on a timely basis. Questioned Costs: No questioned costs were noted as a result of the audit procedures performed. Recommendation: We recommend the University ensure that the published program length for each student is accurately reported to the NSLDS and all status changes are reported to NSLDS within the required timeframe. Views of Responsible Officials: The University found that there was an error in the computer program used to calculate the published program length within the program level details for students who had not yet submitted an application for graduation at the time the program was executed. The University corrected the computer program in January 2021. The University student graduated in December 2019. At that time, the student?s graduation status was reported within the NSLDS program-level record. However, they were not reported as graduated in the NSLDS campus-level record. This student?s graduation status was reported in the campus-level detail in November 2020.

2020 001 Special Tests ? Enrollment Reporting Federal Agency: U.S. Department of Education Program Titles and CFDA Numbers: Federal Direct Student Loan Program (CFDA #84.268), Federal Pell Grant Program (CFDA #84.063) Federal Grant Numbers: P063P190268 (07/01/2019-06/30/2020), P268K200268 (07/01/2019-06/30/2020) Contact Person: Mary Byrne, AVP for Finance & Controller, (732) 571-3404 Corrective Action: The University found that there was an error in the computer program used to calculate the published program length within the program level details for students who had not yet submitted an application for graduation at the time the program was executed. The University corrected the computer program in January 2021. The University student graduated in December 2019. At that time, the student?s graduation status was reported within the NSLDS program level detail. However, they were not reported as graduated in the NSLDS campus level detail. This student?s graduation status was reported in the campus level detail in November 2020. Anticipated Completion Date: January 2021