EIN: 310536640
UEI: NGCKFNEEYJL5
Audited by: RSM US LLP
Cognizant agency: 84 [Department of Education]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 27, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 27, 2026 (29 days from today).
What is a management decision? →During the course of our special tests and provisions, we identified 3 students from our sample of 25 whose withdraw date was reported to National Student Loan Data System (NSLDS) as the day after the withdraw began. We also identified 2 students whose withdraw date was reported as the end of the semester in which the student was attending and 1 student whose withdraw date did not correlate with the last date of attendance. Cause: Administrative oversight by personnel in reporting the status accurately and timely did not operate as designed. Context: Controls did operate properly for the University to notify NSLDS accurately and within the required time frame. Effect: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to report enrollment status changes accurately and timely. Questioned Costs: None Repeat Finding: Yes Recommendations: The University should evaluate sufficiency of current procedures to ensure that all status changes are reported in a timely and accurate manner for students who receive federal loans. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan on pages 40-41.
Show full finding ▾Hide full finding ▴Finding 2025-001 Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.033, 84.007, 84.379, 84.268 Federal Agency: Department of Education Award Year: 2025 Criteria: The University is required to ensure proper controls are present to report enrollment information accurately and on a timely basis as required through specific regulations at 34 CFR 685.309(b). Condition: During the course of our special tests and provisions, we identified 3 students from our sample of 25 whose withdraw date was reported to National Student Loan Data System (NSLDS) as the day after the withdraw began. We also identified 2 students whose withdraw date was reported as the end of the semester in which the student was attending and 1 student whose withdraw date did not correlate with the last date of attendance. Cause: Administrative oversight by personnel in reporting the status accurately and timely did not operate as designed. Context: Controls did operate properly for the University to notify NSLDS accurately and within the required time frame. Effect: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to report enrollment status changes accurately and timely. Questioned Costs: None Repeat Finding: Yes Recommendations: The University should evaluate sufficiency of current procedures to ensure that all status changes are reported in a timely and accurate manner for students who receive federal loans. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan on pages 40-41.
Corrective Action Taken or Planned: A. Correction of "Day After" Reporting Logic The University previously identified a practice where the withdrawal (W) status was made effective the day following the student's notification. ● Process Update: This process was officially updated in April 2025 to align with the regulation, ensuring the withdrawal start date and the date of official notification are the same. The three findings all occurred prior to the April adjustment. ● Ongoing Diligence: The Registrar’s team is actively monitoring current and future records to ensure this logic is applied consistently going forward. B. Reporting Withdrawal Dates for Late-Term Requests To address students reported as withdrawn on the last day of the term rather than their actual date of request: ● Manual Tracking: For students who request a withdrawal between the official University withdrawal deadline and the end of the term, the Financial Aid Office will create a new process where they track students needing NSC manual corrections and share that information with the RO Team member doing the NSC reporting. ● NSC Overrides: The NSC reporting processor will utilize this information to perform manual date changes for these students, ensuring the reported date reflects the official date of notification rather than the term end date. C. Correlation of Withdrawal Date and Last Date of Attendance (LDA) To address findings where withdrawal dates did not correlate with the LDA: ● Faculty LDA Requirement: Although the University is a non-attendance-taking institution, a new requirement has been implemented for faculty to enter the Last Date of Attendance (LDA) for any student receiving a non-passing grade. ● Reporting Sync: The latest of the reported LDAs will be used by both the Financial Aid office (for calculations) and the NSC processor (for reporting) if a student is withdrawing from the University for the subsequent term and the student received all non-passing grades in the prior term. The Financial Aid office will notify the Registrar’s office if there are students with no passing grades and a LDA prior to the official withdrawal date to update their withdrawal date to match that LDA. ● Verification Workflow: The Registrar’s office will verify withdrawal information with the student, including the notification date, to ensure accuracy before manual NSC corrections are made. D. Internal Audit and Collaborative Controls To prevent recurrence and ensure compliance with federal reporting timelines: ● Collaborative Review: The Registrar and the Executive Director of Financial Aid & Scholarships will meet on a recurring basis to jointly review enrollment reporting procedures and ensure data alignment. ● Spot Checks: An internal audit process has been implemented to spot-check each submission file to verify that enrollment and withdrawal dates are accurate. The shared spreadsheet of manual dates will also be checked to ensure those dates are being changed. ● Petition and Request Review: The Registrar Team will carefully review all petitions and requests to determine which date to use as the original notification. ________________________________________ Person(s) Responsible for Corrective Action: University Registrar and Executive Director of Financial Aid & Scholarships. ________________________________________ Anticipated Completion: June 30, 2026 ________________________________________
2024-002
FAC accepted this audit on March 31, 2025 — management decision was due October 1, 2025.
During the course of our testing, we identified one student from a sample of nine whose Title IV refunds were not calculated correctly. Additionally, we identified one student from a sample of nine whose return of Title IV aid was not returned in the appropriate time required. Cause: Administrative oversight by personnel in calculating and reporting the status accurately and timely did not operate as designed Context: Controls did not operate properly to refund students with Federal Direct loans or Pell grants. Effect: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to return aid properly to the students. Questioned Costs: None Repeat Finding: Yes Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan on page 39-42.
Show full finding ▾Hide full finding ▴Finding 2024-001 Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 and 84.268 Federal Agency: Department of Education Award Year: 2024 Criteria: 34 CFR 668.22 requires the University to implement internal control procedures and to appropriately administer funding under the Student Financial Assistance Cluster to return Title IV funds in the appropriate time required by regulations. Condition: During the course of our testing, we identified one student from a sample of nine whose Title IV refunds were not calculated correctly. Additionally, we identified one student from a sample of nine whose return of Title IV aid was not returned in the appropriate time required. Cause: Administrative oversight by personnel in calculating and reporting the status accurately and timely did not operate as designed Context: Controls did not operate properly to refund students with Federal Direct loans or Pell grants. Effect: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to return aid properly to the students. Questioned Costs: None Repeat Finding: Yes Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan on page 39-42.
1. Identifying Number: 2024-001: Title IV Refund and Return of Funds Compliance Issue: A sample review found instances where Title IV refunds were miscalculated and not returned within the required timeframe. Cause: Administrative oversight led to inaccurate and untimely calculation. Effect: The University did not fully comply with FSA Handbook and federal regulations for returning Title IV aid in a timely manner. Corrective Actions Underway 1. Enhanced Quality Assurance Measures Implementation of a new review protocol for Title IV refund calculations, including a secondary verification process before fund returns. Establishment of a biweekly internal audit of refund calculations to identify and resolve errors before submission. 2.Ongoing Compliance Monitoring and Prevention Efforts Establishment of a quarterly compliance review conducted by the Financial Aid leadership team to proactively address potential issues. Development of a standardized documentation process for all Title IV transactions and NSLDS updates to ensure clear audit trails. Creation of staff retraining initiative to reinforce compliance expectations and best practices. Next Steps: Conduct a full compliance assessment at 30, 60, and 90 days to confirm improvement and adjust protocols as needed. Establish a reporting dashboard for real-time tracking of Title IV refunds and enrollment status updates. Formalize a policy review cycle to ensure that all processes remain aligned with the latest federal regulations. These actions are intended to strengthen the University’s compliance posture, mitigate risks, and enhance the accuracy and timeliness of financial aid administration. Please let me know if additional measures or oversight mechanisms should be considered. Person Responsible for Corrective Action:The Executive Director of Financial Aid & Scholarships is responsible for executing the corrective action plan. Anticipated Completion Date: Fiscal year 2025
2023-001
During the course of our special tests and provisions, we identified 3 students from a sample of 25 where the number of days between the enrollment change and reporting to National Student Loan Data System (NSLDS) was not within the required 60 days. We also identified 3 students from our sample of 25 whose withdraw date was reported as the day after the withdraw began and 1 student whose withdraw date was reported as the end of the semester in which the student was attending. We also identified 2 students from our sample of 25 who was reported as withdrawn instead of graduated. Cause: Administrative oversight by personnel in reporting the status accurately and timely did not operate as designed. Context: Controls did operate properly for the University to notify NSLDS accurately and within the required timeframe. Effect: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to report enrollment status changes accurately and timely. Questioned Costs: None Repeat Finding: Yes Recommendations: The University should evaluate sufficiency of current procedures to ensure that all status changes are reported in a timely and accurate manner for students who receive federal loans. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan on page 39-42.
Show full finding ▾Hide full finding ▴Finding 2024-002 Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 and 84.268 Federal Agency: Department of Education Award Year: 2024 Criteria: The University is required to ensure proper controls are present to report enrollment information accurately and on a timely basis as required through specific regulations at 34 CFR 685.309(b). Condition: During the course of our special tests and provisions, we identified 3 students from a sample of 25 where the number of days between the enrollment change and reporting to National Student Loan Data System (NSLDS) was not within the required 60 days. We also identified 3 students from our sample of 25 whose withdraw date was reported as the day after the withdraw began and 1 student whose withdraw date was reported as the end of the semester in which the student was attending. We also identified 2 students from our sample of 25 who was reported as withdrawn instead of graduated. Cause: Administrative oversight by personnel in reporting the status accurately and timely did not operate as designed. Context: Controls did operate properly for the University to notify NSLDS accurately and within the required timeframe. Effect: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to report enrollment status changes accurately and timely. Questioned Costs: None Repeat Finding: Yes Recommendations: The University should evaluate sufficiency of current procedures to ensure that all status changes are reported in a timely and accurate manner for students who receive federal loans. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan on page 39-42.
2. Identifying Number: 2024-002: Enrollment Reporting Finding: During the course of our special tests and provisions, we identified 3 students from a sample of 25 where the number of days between the enrollment change and reporting to National Student Loan Data System (NSLDS) was not within the required 60 days. We also identified 3 students from our sample of 25 whose withdrawal date was reported as the day after the withdrawal began and 1 student whose withdrawal date was reported as the end of the semester in which the student was attending. We also identified 2 students from our sample of 25 who were reported as withdrawn instead of graduated. Corrective Action Taken or Planned: Actions Taken The University has already taken corrective action on this finding. The issues raised were addressed in the following ways: number of days between the enrollment change and reporting was not within the required 60 days Graduate File Corrections: We discovered (Fall 2023) an error in the reporting of graduates, despite timely reporting via Degree Verify. Upon this discovery, we met with the National Student Clearinghouse (NSC) to determine the cause of the issue and how to correct it. We learned that students with enrollment in more than one program, or where the program reported did not match the program on record with NSC, were not being properly processed with a G status via the Degree Verify submissions. We were informed that this is common for institutions where students may be enrolled in more than one program at a time. We were advised by NSC to submit a “Graduates only” file, in addition to the Degree Verify file submission. Upon discovering this, we submitted Graduates only files for branches 02, 03, 04, 05, 80, 82, 84, and 97, for all terms for 2020, 2021, 2022, and 2023 beginning in December 2023 and ending in April 2024. We worked through these submissions with NSC, and incorrect withdrawn statuses were corrected to graduated statuses. Antioch’s enrollment reporting process has been updated to include a monthly submission of a graduates only file in addition to degree verify file monthly submission. The University has experienced changes in staffing for personnel involved in enrollment reporting. The person previously in charge of Enrollment Reporting retired on 02/29/24. He was responsible for the enrollment reporting for the majority of this audit period, as well as the prior year. Antioch University hired a new Director of Records Administration with a primary responsibility for NSLDS reporting on 03/28/24. The University has implemented a comprehensive training plan, including improved documentation of procedures, increased clarity regarding the process for the necessity of error resolution, and a review of system processing to help reduce errors in reporting and increase efficiency. The review of current practice and improved procedures was in conjunction with consultants from AACRAO, NSC, Ellucian (the student information system company). Actions Planned The University plans for corrective action on this finding. This includes policy updates for withdrawal processing and implementation of internal audits. Withdraw date was reported as the day after the withdraw began. It has been the practice to process withdrawal requests in this way: When a student withdrawal is submitted, the notification date is considered the last date of active enrollment. The withdraw (W) status begins effective on the following date. This has not been raised as a finding in prior audits. This process will be updated (effective April 1, 2025) to follow 34 CFR 668.22(c). For withdrawal processing effective immediately, this process will be updated to start the withdrawal on the date the student provides official notification, rather than starting on the day following. This means the last date attended and the start of the withdrawal will be the same date. Per the CFR 668.22(c). the student's withdrawal date is—(ii) The date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; For withdrawal processing effective at the end of the term, the effective date for the ‘W’ status is the final day of the term in which the student was last enrolled. Per the Withdrawal versus Graduation and Effective Dates section of the NSLDS Manual Nov 2022, p.23 - In the case of the student who completes a term and does not return for the next term, leaving the course of study uncompleted, the effective date for the ‘W’ status is the final day of the term in which the student was last enrolled. The policy and process will be updated and training will occur to begin this processing change effective April 1, 2025. Withdraw date was reported as the end of the semester in which the student was attending It has been the practice to process withdrawal requests in this way: When a student requests withdrawal but has completed courses, the grades are updated prior to processing the withdrawal request. The withdrawal is effective on the start date of the next term. This process will be updated (effective April 1, 2025) to follow 34 CFR 668.22(c) and the NSLDS Manual as outlined in the prior bullet point. For students withdrawing immediately from a term in which they’ve already completed one or more courses, the effective date for the ‘W’ status is the date AU is notified. However, they will only be dropped from courses still in progress. Completed courses cannot be withdrawn. The policy and process will be updated and training will occur to begin this processing change effective April 1, 2025. Reported as withdrawn instead of graduated The Grads Only submission did not return student records for 24SPTRI. We will need to review this with Ellucian to determine the issue. Once this is determined, we will re-run the submission for this term to update records. An internal audit process will be implemented to spot check 3-5 records on each submission for enrollment, grads only, or degree verify reporting. In addition, an audit report will be created to review 9 sample records on a quarterly basis from the current list of active students and the last two years of graduated and withdrawn students. The review will select 3 records from each status. An audit log will document these reviews. Person Responsible for Corrective Action: The Registrar and Executive Director of Financial Aid & Scholarships are responsible for executing the corrective action plan. The Executive Director of Financial Aid and Scholarships and the University Registrar will meet on a recurring basis to jointly review enrollment reporting procedures and National Student Loan Data System (NSLDS) reporting timelines. This collaboration ensures that all enrollment data submitted for Title IV purposes is accurate, timely, and aligned with institutional policies and federal regulations. Any discrepancies or issues identified are addressed collaboratively and corrective steps are documented. Anticipated Completion Date: Fiscal year 2025
2023-002
FAC accepted this audit on March 29, 2024 — management decision was due September 29, 2024.
During the course of our testing, we identified one student from a sample of seven whose return of Title IV aid was not calculated and returned in the appropriate time required. Additionally, we identified two students from a sample of seven whose Title IV refunds were not calculated correctly. Cause: Administrative oversight by personnel in reporting the status accurately and timely did not operate as designed. Context: Controls did not operate properly to refund students with Federal Direct loans or Pell grants. Effect: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to return aid properly to the students. Questioned Costs: None Repeat Finding: No Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Corrective Action Plan: See page 40 for Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2023-001 Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 and 84.268 Federal Agency: Department of Education Award Year: 2023 Criteria: The University is required to implement procedures to appropriately administer funding under the Student Financial Assistance Cluster to return Title IV funds in the appropriate time required by regulations. Condition: During the course of our testing, we identified one student from a sample of seven whose return of Title IV aid was not calculated and returned in the appropriate time required. Additionally, we identified two students from a sample of seven whose Title IV refunds were not calculated correctly. Cause: Administrative oversight by personnel in reporting the status accurately and timely did not operate as designed. Context: Controls did not operate properly to refund students with Federal Direct loans or Pell grants. Effect: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to return aid properly to the students. Questioned Costs: None Repeat Finding: No Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Corrective Action Plan: See page 40 for Corrective Action Plan.
Corrective Action Taken or Planned: Starting with the 2024-2025 Award year, the Office of Financial Aid and Scholarships is undergoing an internal reorganization. The purpose of this is to provide a broader depth of knowledge and better dual control and compliance functions within the Office of Financial Aid and Scholarships. In the new reorganization structure, the FA Specialist will be responsible for performing the R2T4 Calculations, with their Supervisor, the Assistant Director of Financial Aid Operations, reviewing and approving the calculation. Once the calculation is completed, and signed off on by the Assistant Director, the FA Specialist will will complete and send the Financial Aid Transmittal Register (FATR) report and notify the Student Accounts Office so they can process the return of funds on through the Financial Aid Posting Register (FATP). Review of the Financial Aid Posting Register will be done by the FA Specialist to ensure the internal process to return funds is timely and posted to the Common Origination and Disbursement system accurately. A quarterly review and internal control audit of Title IV refund calculations will also be completed to ensure accuracy in system processing, days and break calculations, and adherence to Title IV regulations. In addition, the staff will have additional training throughout the year on Title IV compliance and refunds to ensure the University is compliant with all regulations. Person Responsible for Corrective Action: Katy Stahl, the Executive Director of Financial Aid & Scholarships, is responsible for the execution of the corrective action plan. Anticipated Completion Date: Fiscal year 2024
During the course of our special tests and provisions, we identified 3 students from a sample of 25 where the number of days between the enrollment change and reporting to National Student Loan Data System (NSLDS) was not within the required 60 days. We also identified 6 students from our sample of 25 who were reported as withdrawn instead of as graduated. Additionally, we identified 2 students from our sample of 25 whose program start date did not agree to the University’s records. Cause: Administrative oversight by personnel in reporting the status accurately and timely did not operate as designed. Context: Controls did operate properly for the University to notify NSLDS accurately and within the required timeframe. Effect: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to report enrollment status changes accurately and timely. Questioned Costs: None Repeat Finding: No Recommendations: The University should evaluate sufficiency of current procedures to ensure that all status changes are reported in a timely and accurate manner for students who receive federal loans. Corrective Action Plan: See page 40 for Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2023-002 Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 and 84.268 Federal Agency: Department of Education Award Year: 2023 Criteria: The University is required to report enrollment information accurately and on a timely basis as required through specific regulations at 34 CFR 685.309(b). Condition: During the course of our special tests and provisions, we identified 3 students from a sample of 25 where the number of days between the enrollment change and reporting to National Student Loan Data System (NSLDS) was not within the required 60 days. We also identified 6 students from our sample of 25 who were reported as withdrawn instead of as graduated. Additionally, we identified 2 students from our sample of 25 whose program start date did not agree to the University’s records. Cause: Administrative oversight by personnel in reporting the status accurately and timely did not operate as designed. Context: Controls did operate properly for the University to notify NSLDS accurately and within the required timeframe. Effect: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to report enrollment status changes accurately and timely. Questioned Costs: None Repeat Finding: No Recommendations: The University should evaluate sufficiency of current procedures to ensure that all status changes are reported in a timely and accurate manner for students who receive federal loans. Corrective Action Plan: See page 40 for Corrective Action Plan.
Corrective Action Taken or Planned: The University has experienced changes in staffing for personnel involved in enrollment reporting and system irregularities with multiple programs with the National Clearing House. These inconsistencies have caused delays in processing and response to enrollment reporting changes. Antioch University has hired a new Director of Records Administration with a primary responsibility for NSLDS reporting. The University will implement a comprehensive training plan for new individuals and teams, including improved documentation of procedures, increased clarity regarding the process for the necessity of error resolution, and a review of system processing to help reduce errors in reporting and increase efficiency. In addition, internal reviews and control audits will be performed throughout the year to ensure accuracy in NSLDS reporting and alignment with the National Clearing House guidance. Person Responsible for Corrective Action: Maureen Heacock, the Registrar and Katy Stahl, Executive Director of Financial Aid & Scholarships are responsible for executing the corrective action plan. Anticipated Completion Date: Fiscal year 2024
FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.
FAC accepted this audit on July 14, 2022 — management decision was due January 14, 2023.
FAC accepted this audit on August 9, 2021 — management decision was due February 9, 2022.
FAC accepted this audit on March 26, 2020 — management decision was due September 26, 2020.
FAC accepted this audit on March 21, 2019 — management decision was due September 21, 2019.
FAC accepted this audit on March 28, 2018 — management decision was due September 28, 2018.
FAC accepted this audit on March 30, 2017 — management decision was due September 30, 2017.
GSA_MIGRATION
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GSA_MIGRATION
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