Madonna UniversityHigher Education

Assistance Listing Number, Federal Agency, and Program Name - 84.268, 84.063, and 84.007, Department of Education, Student Financial Aid Cluster Federal Award Identification Number and Year - P268K221640, P063P121640, and P007A212038 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes - 2021-001 Criteria - An institution shall submit, in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct (34 CFR 690.83(b)(2) and 34 CFR 685.309). A school must update the National Student Loan Data System (NSLDS) within 30 days of a student status change, unless the school expects to submit its next enrollment report to the NSLDS within 60 days (34 CFR 685.309). Condition - The student status changes for certain students with status changes were not reported accurately and/or within 60 days. Additionally, certain students were reported with incorrect effective dates. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors that attributed to this finding: 1.Of the 40 students tested, there were 8 students who withdrew/graduated whose status change was not reported accurately to the NSLDS. These students withdrew or graduated and were reported but with an incorrect effective date. 2.Of the 40 students tested, there were 2 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. 3.Of the 40 students tested, there was 1 student who withdrew whose status change was not reported to the NSLDS. Cause and Effect - The University does not have a control(s) or process(es) in place to ensure status changes are reported to the NSLDS accurately and timely in all cases. As a result, certain student status changes were not reported accurately and timely to the NSLDS. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting, including a review of students who graduated or withdrew, officially or unofficially. Views of Responsible Officials and Corrective Action Plan - The University concurs with the finding. Enrollment services is working with IT on an error report and ongoing review process to identify reporting errors for timely correction.

Assistance Listing Number, Federal Agency, and Program Name - 84.268, 84.063, and 84.007, Department of Education, Student Financial Aid Cluster Federal Award Identification Number and Year - P268K221640, P063P121640, and P007A212038 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - An institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (I)). Before an institution disburses Title IV, Higher Education Act (HEA) program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Except in the case of a post-withdrawal disbursement made in accordance with Sec. 668.22(a)(5), if an institution credits a student's account at the institution with Direct Loans, the institution must notify the student or parent of: i.The anticipated date and amount of the disbursement ii.The student's or parent's right to cancel all or a portion ofthat loan or loan disbursement and have the loan proceeds returned to the secretary iii.The procedures and the time by which the student or parent must notify the institution that he or she wishes to cancel the loan or loan disbursement. Unless otherwise directed by the granting agency, an institution must maintain records related to its administration of a student financial assistance program for three years after the end of the award year in which the FISAP is submitted (34 CFR 668.24). Condition - The University could not provide records to substantiate that the relevant criteria were complied with by the University in all cases. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 13 students tested for R2T4, there were 6 students who were unofficial withdrawals in which the University could not provide support to substantiate the last date of academically related activity that was used as the withdrawal date for Title IV calculation purposes. Of the 25 students tested for eligibility, there were 2 students in which the University could not provide support that a disbursement notification was sent to the student/parent. Cause and Effect - Processes and controls are not designed and implemented to ensure that proper record retention is occurring necessary to substantiate compliance with relevant requirements. Recommendation - The University should implement additional controls to ensure all appropriate support is retained to backup the inputs of Title IV calculations. The University should implement controls to ensure that appropriate support is retained to support that disbursement notifications were sent to students/parents. Views of Responsible Officials and Planned Corrective Actions - The University concurs with the finding. Madonna will train faculty to preserve and provide documentation related to reported last dates of attendance. This will be stored in the University's enterprise document management system.

Assistance Listing Number, Federal Agency, and Program Name - 84.268, 84.063, and 84.007, Department of Education, Student Financial Aid Cluster Federal Award Identification Number and Year - P268K221640, P063P121640, and P007A212038 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - A Title IV, Higher Education Act (HEA) credit balance occurs whenever the amount of Title IV, HEA program funds credited to a student?s ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period, as provided under paragraph (c) of this section. A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than: i.14 days after the balance occurred if the credit balance occurred after the first day of class of that payment period ii.14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. (34 CFR 668.164 (h)(1)) Condition - Certain credit balances were not refunded to students within 14 days. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 25 students tested, there were 2 students who had credit balances created by Title IV funds that were not refunded within 14 days. Cause and Effect - The University does not have a control or process in place to ensure that credit balances are refunded to students within 14 days in all situations. Specifically, it was observed that one individual is responsible for executing the refund of credit balances, and a process was not in place to rotate these duties while the staff member was on a personal leave during a period of time during the fiscal year ended June 30, 2022. As a result, credit balances were not refunded on a timely basis. Recommendation - The University should implement controls to ensure that credit balances are refunded to students within 14 days. Specifically, the University should ensure additional resources are allocated to this process to ensure continuity of operating effectiveness in the event of personnel changes or unexpected leaves. Views of Responsible Officials and Planned Corrective Actions - The University concurs with the finding. The University will identify one or more additional staff members who can perform this function in the event of illness or absence, cross-train these individuals, and ensure permissions are granted, ensuring appropriate segregation of duties.

Assistance Listing Number, Federal Agency, and Program Name - U S. Department of Education - Assistance Listing Number 84.425E, COVID-19 - Higher Education Emergency Relief Fund (HEERF) - Student Aid Federal Award Identification Number and Year - P425E201464 Pass-through Entity - N/A Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - CARES Act 18004(e) and the CRRSAA 314(e) require an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary at such time in such a manner as the secretary may require. ARP Act 2003 specifies that the same terms and conditions of CRRSAA 314 apply to HEERF III funds. While the acts do not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, pursuant to these requirements, the Department of Education required quarterly public reporting of student portion and institutional portion awards. Condition - The University did not make available timely student HEERF quarterly reporting for the quarter ended September 30, 2021. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - There was one instance identified where the University did not make available timely the student HEERF quarterly report on the University's website. Cause and Effect - There was no control implemented to ensure that the required information was properly made available on the University's website on a timely basis. As a result, quarterly reporting for the quarter ended September 30, 2021 was not made available timely. Recommendation - We recommend that the University implement additional controls to ensure reporting requirements for federal grants are complied with in all instances. Views of Responsible Officials and Planned Corrective Actions - The University concurs with the finding. The University will create a review process to ensure correct and timely reporting documents are posted in accordance with federal regulations.

CFDA Number, Federal Agency, and Program Name 84.268, 84.063, and 84.007, Department of Education, Student Financial Aid Cluster Federal Award Identification Number and Year P268K211640, P063P201640, and P007A202038 Pass through Entity N/A Finding Type Material weakness Repeat Finding Yes 2020 005 Criteria An institution shall submit, in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct (34 CFR 690.83(b)(2) and 34 CFR 685.309). A school must update the National Student Loan Data System (NSLDS) within 30 days of a student status change, unless the school expects to submit its next enrollment report to the NSLDS within 60 days (34 eCFR 685.309). Condition The student status changes for certain students with status changes were not reported accurately and/or within 60 days. Additionally, certain students were reported with incorrect effective dates. Questioned Costs None Identification of How Questioned Costs Were Computed N/A Context There were three types of enrollment reporting issues identified: 1) Of the 40 students tested, there was 9 students who withdrew whose status change was not reported accurately to the NSLDS. Student withdrew and was reported but with an incorrect effective date. 2) Of the 40 students tested, there were 9 students who withdrew whose status changes were not reported to the NSLDS within 60 days. 3) Of the 40 students tested, there was 1 student who withdrew whose status change was not reported to the NSLDS. Student withdrew in the spring semester but was not reported by the University to NSLDS. Cause and Effect The University does not have a control or process in place to ensure status changes are reported to the NSLDS accurately and timely. As a result, certain student status changes were not reported accurately and timely to the NSLDS. Recommendation The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting, including a review of students who graduated or withdrew, officially or unofficially. Views of Responsible Officials and Corrective Action Plan Based upon the recommendation of the audit, a new process has been created the includes the review of students that graduated or withdrew, officially or unofficially, and verification that status changes have been appropriately applied with NSLDS within the deadline period. This process began with the fall 2021 semester. This is a manual review done by the assistant vice president for enrollment services and registrar, at this time, however consideration is being given to create a less manual process. The University will also be providing reinforcement to all faculty about the criticality of timely reporting of last date of attendance. Management is committed to this corrective action and has demonstrated improvement from the prior year in the error rate. The University understands reporting issues of this type are common and will be seeking additional guidance on best practices to reduce the risk of recurrence. The University will continue to address the challenges of this manual process.

CFDA Number, Federal Agency, and Program Name 84.268, 84.063, and 84.007, Department of Education, Student Financial Aid Cluster Federal Award Identification Number and Year P268K211640 , P063P201640, and P007A202038 Pass through Entity U.S. Department of Education Finding Type Significant deficiency Repeat Finding No Criteria 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 grant or loan assistance that the student earned as of the student's withdrawal date. (34 CFR ? 668.22) Section 3508 of the CARES Act waives Return of Title IV Funds (R2T4) requirements for students whose withdrawals were related to the novel coronavirus disease (COVID 19), but requires certain verification documentation and reporting in the Common Origination and Disbursement (COD) system. Condition The University did not properly process and/or verify withdrawals related to potential COVID 19 illnesses. The University did not properly report COVID 19 withdrawals in the COD system via the Coronavirus Indicator checkbox indicating a student withdrew as a result of COVID 19. Questioned Costs None Identification of How Questioned Costs Were Computed N/A Context Of the 21 students selected for return to Title IV testing, the return for 1 student who withdrew due to COVID 19 was not properly processed as a waiver exemption. Had this student not been eligible for a waiver exemption a return to Title IV calculation would have been required and a return of $6,024 would have needed to have been processed. There was a further 1 student that withdrew for illness and the University did not verify if the illness was, or was not COVID 19 related and accordingly did not process the withdrawal under the COVID 19 waiver exemption process. Cause and Effect Controls are inadequate to ensure that withdrawals due to COVID 19 are properly identified and processed as a waiver exemption. As a result, 2 students' special circumstances were not verified and/or addressed properly. Recommendation The University should implement additional controls to ensure all withdrawals due to special circumstances are identified and necessary return of Title IV calculations are completed, and that such calculations and returns are done so in an accurate and timely manner. Views of Responsible Officials and Planned Corrective Actions Previously, students were required to notify the registrar?s office, in writing, requesting changes in enrollment, specifically drops and withdrawals. The date that the request was received in the office of registrar, was entered as the last date of attendance. Based upon the recommendations from the audit, the University will be using all forms of communication from the student, faculty or staff to determine the actual last date of attendance in the classroom, not the date that the official request was submitted to the office of the registrar. The University will now add to the special request process for students requesting a late drop or withdraw, when a refund is requested, that they indicate the last day they attended the course(s), and if they are requesting the late drop or withdrawal as a result of COVID 19.

CFDA Number, Federal Agency, and Program Name 84.268, 84.063, and 84.007, Department of Education, Student Financial Aid Cluster Federal Award Identification Number and Year P268K211640 , P063P201640, and P007A202038 Pass through Entity U.S. Department of Education Finding Type Material weakness Repeat Finding Yes 2020 006 Criteria If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance, but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (34 CFR 668.22(j)(1)). 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. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) 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; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student?s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date, the last date of attendance at an academically related activity as documented by the institution (34 CFR668.22(c) and (l)). Condition The University has discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on Federal regulations. The University is not obtaining and/or verifying that the dates received from the registrars' office are the correct dates for the students last attendance to be utilized in the return to Title IV calculations. Questioned Costs $724 Identification of How Questioned Costs Were Computed For 3 of the students, the incorrect date of withdrawal did not result in the change for the return to Title IV calculations. For 1 student, the incorrect withdrawal date resulted in a shortfall of the amount returned. The questioned cost amount was calculated by subtracting the amount returned from the total aid disbursed to the student as the full amount of the students aid was unearned. Context Of the 21 students selected for return to Title IV testing, for 4 students the University had discrepancies between the date utilized in the return to Title IV calculation and the date required to be utilized based on Federal regulation. Cause and Effect Controls are inadequate to ensure that proper withdrawal dates are utilized in return of Title IV calculations. As a result, the calculations for 4 students did not utilize the correct date of withdrawal and for 1 student an incorrect amount was returned. Recommendation The University should implement additional controls to ensure all necessary return of Title IV calculations are completed and that such calculations and returns are done so in an accurate and timely manner. The report that is utilized by the University to prepare return to Title IV calculations should be verified for accuracy, including the withdrawal dates, in accordance with applicable Federal regulations. Views of Responsible Officials and Planned Corrective Actions Previously, students were required to notify the registrar?s office, in writing, requesting changes in enrollment, specifically drops and withdrawals. The date that the request was received in the office of registrar, was entered as the last date of attendance. Based upon the recommendations from the audit, the University will be using all forms of communication from the student, faculty or staff to determine the actual last date of attendance in the classroom, not the date that the official request was submitted to the office of the registrar. The University will now add to the special request process for students requesting a late drop or withdraw, when a refund is requested, that they indicate their last day they attended the course(s). The University will also be providing reinforcement to all faculty about the criticality of timely reporting of last date of attendance. Management is committed to this corrective action and has demonstrated improvement from the prior year in the error rate. The University understands reporting issues of this type are common and will be seeking additional guidance on best practices to reduce the risk of recurrence. The University will continue to address the challenges of this manual process.

CFDA Number, Federal Agency, and Program Name - Student Financial Assistance Cluster CFDA No. 84.268 Federal Direct Student Loans Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type Material weakness Repeat Finding - No Criteria - The University must notify a student of the amount of loan funds that the student or his or her parent can expect to receive, which funds are from subsidized loans and which are from unsubsidized loans, and how and when those funds will be disbursed. The notification should also include the date and amount of the disbursement and the student?s right, or parent?s right, to cancel all or a portion of that loan disbursement. The University must send the notification in writing within 30 days prior to or after crediting the student?s account at the institution (34 CFR Section 668.165(a)(2) and 34 CFR Section 668.165(a)(3)). Condition The University did not provide adequate notification of loan disbursements and the right to cancel all or a portion of the loans to students or parents. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context Of the 25 students selected for eligibility testing, 25 of those students did not receive the proper notifications, and/or documentation supporting communication made was not maintained. Cause and Effect - There was a deficiency in the process, which was determined to be personnel related, that was not identified until the audit procedures were performed in July 2020. Recommendation - The University should implement a process to notify students or parents of loan disbursements that includes all required communication elements. This process should include a review process to ensure that the process is being performed timely and accurately, as well retaining records of communications made. Views of Responsible Officials and Corrective Action Plan The University had a procedure in place for this federal requirement, but due to the departure of the employee responsible for this function and COVID 19, the disbursement notifications were not processed in the beginning of 2020. An enrollment specialist has been assigned this task moving forward, and the notifications are now being mailed every two weeks.

CFDA Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - CFDA No. 84.268 Federal Direct Student Loans and No. 84.063 Federal Pell Grant Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type Material weakness Repeat Finding - Yes - 2019 003 Criteria - Changes in a student?s status are required to be reported to the National Student Loan Data System (NSLDS) or the guarantee agency within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (34 CFR Section 682.610). Appendix C of the NSLDS Enrollment Reporting Guide defines a withdrawn (voluntary or involuntary) student as a student who has officially withdrawn from all courses, stopped attending all classes but did not officially withdraw, or who for any reason did not reenroll for the next regular (nonsummer) term without completing the course of study. The effective date is the date the student officially withdraws or, in the absence of a formal withdrawal, the last recorded date of attendance. 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 withdrawn status is the final day of the term in which the student was last enrolled. Condition Of the 40 students tested, 30 students were identified with incorrect effective dates related to a status change, or whose status changes were not reported to the NSLDS timely, or whose status changes were not reported to the NSLDS accurately. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were four types of enrollment reporting issues identified: 1) Of the 40 students tested, there was 1 student who withdrew whose status change was not reported accurately to the NSLDS. The student withdrew in the winter semester but was not reported until the summer semester reporting period with an incorrect effective date. 2) Of the 40 students tested, there were 10 students whose changes in enrollment status, other than graduation, were not reported to the NSLDS within 60 days. 3) Of the 40 students tested, there were 5 students who did not have their graduation status properly reported to the NSLDS. 4) Of the 40 students tested, there were 18 students whose graduation status changes were not reported to the NSLDS within 60 days. 5) Of the 40 students tested, there was 1 student who withdrew whose status change was not reported to the NSLDS. The student withdrew in the fall semester but was not reported by the University to the NSLDS. Cause and Effect The University does not have a control or process in place to ensure status changes are reported to the NSLDS accurately and timely. As a result, certain student status changes were not reported accurately and timely to the NSLDS. Recommendation The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting, including a review of students who graduated or withdrew, officially or unofficially. Views of Responsible Officials and Planned Corrective Actions The University concurs with the findings and recommendations. To address the instances of noncompliance within the finding, the University will do the following: ? We did not have an unofficial withdrawal status for the institution. Students who stopped attending were awarded the appropriate grade (in most cases an F grade), according to the catalog rules of the University. We created an unofficial withdrawal grade of FW that went into effect and was implemented for fall 2020. Those students who stop attending will have their grade updated to an unofficial withdrawal, their enrollment records adjusted, and if that results in a new enrollment status, it will be reported to the NSC and NSLDS. They will be recognized as unofficially withdrawn as part of the University?s return of Title IV aid calculation process and procedures. This will be managed by the associate registrar. ? The University currently manually reviews all submissions to the NSC for correctness for changes to enrollment status, including withdrawn. During this audit, an error that could not be explained was discovered in the report used for reviewing these changes. The AVP for Enrollment Services & Registrar will work with information technology (IT) to improve the reporting to avoid such errors. ? Beginning with winter 2021, graduation reporting will be modified so that students who are scheduled to graduate but have not completed all requirements in time for the graduates only report to the NSC (Student Clearinghouse) will be documented as to why there was a delay in processing (such as an outstanding `I? grade, transfer transcript delivery, extended placement, etc.) (completed beginning January 2021), reported as withdrawn to the NSC, and once a graduation conferral is completed, the NSC and NSLDS will be updated with the graduated status.

CFDA Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - CFDA No. 84.268 Federal Direct Student Loans, 84.063 Federal Pell Grant Program, and 84.007 Federal Supplemental Educational Opportunity Grant Program Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type Significant deficiency Repeat Finding - No Criteria - The return of Title IV funds, as required by 34 CFR 668.173(b), must be refunded within 45 days from the date of the student?s withdrawal. Withdrawal dates are defined as the time when the student officially withdraws or expresses notification to withdraw or, if the student does not officially withdraw, the date that the University determines the student is no longer in attendance. Condition Of the 12 students selected for return of Title IV testing, the University used the incorrect date of withdrawal for two students, and the University did not return the funds of 2 students within 45 days of becoming aware that the students had withdrawn from classes. Questioned Costs - $170 Identification of How Questioned Costs Were Computed - Questioned costs were identified by totaling the amounts that were returned in excess of the amount that would have been required to be returned for the three students with incorrect calculations. Context There were two types of return of Title IV fund issues identified: 1) Of the 12 students selected for return of Title IV testing, the University did not return the funds of 2 students within 45 days of becoming aware that the students had withdrawn from classes. The University performed an additional analysis of this issue and identified that this impacted an additional 3 students not included in the sample in the winter and summer semesters. 2) Of the 12 students selected for return of Title IV testing, the University used the incorrect withdrawal date within the calculation. The University performed an additional analysis of this issue and identified that this impacted 1 additional student not included in the sample in the winter and summer semesters. In all instances, this resulted in the University returning more aid than what would have been required using the proper withdrawal date. Cause and Effect The University did not have the proper control in place to ensure students who withdraw from eligible credit courses have a return to Title IV refund calculation performed in a timely manner or that the return to Title IV refund calculation was performed accurately. Recommendation The University should consider implementing review procedures to verify that all students needing calculations have been identified, as well as additional controls to ensure timeliness of calculations and returns. Views of Responsible Officials and Planned Corrective Actions The University will implement a process and procedure for return to Title IV calculations that will include a review for accuracy by another financial aid office staff member after preparation of each calculation. Two returns were delayed beyond the 45 day requirement while the University reviewed updated Department of Education COVID 19 guidance and institutional policy developments. Since that time and after reviewing the guidance and policies, the returns have been processed within the 45 day period.

CFDA Number, Federal Agency, and Program Name- Student Financial Assistance Cluster - CFDA No. 84.268 Federal Direct Loans and No. 84.063 Federal Pell Grants Federal Award Identification Number and Year - Various Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - Yes 2018-002, 2017-004 Criteria - Changes in a student?s status are required to be reported to the National Student Loan Data System (NSLDS) or the guarantee agency within 30 days of the change or included in a student status confirmation report sent to NSLDS within 60 days of the status change (34 CFR Section 682.610). Appendix C of the NSLDS Enrollment Reporting Guide defines a withdrawn (voluntary or involuntary) student as a student who has officially withdrawn from all courses, stopped attending all classes but did not officially withdraw, or who for any reason did not re- enroll for the next regular (non-summer) term without completing the course of study. The effective date is the date the student officially withdraws or, in the absence of a formal withdrawal, the last recorded date of attendance. 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 withdrawan status is the final day of the term in which the student was last enrolled. Condition -Of the 40 students tested, 10 students were identified with either incorrect effective dates related to a status change, or their status changes were not reported to the NSLDS timely. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were four types of Enrollment Reporting issues identified: 1) Of the 40 students tested, there was 1 student that unofficially withdrew in the fall 2018 semester whose status change effective date was incorrectly reported to the NSLDS, and this student had a return of title IV calculation performed. 2) Of the 40 students tested, there were 6 students that unofficially withdrew whose status changes were not reported timely to the NSLDS. Students who unofficially withdraw in the winter semester will not be defaulted to withdrawn until the required reporting period begins in the fall term as the spring/summer semester is not a required reporting period. Of the students tested, 5 of those were unofficial withdrawals from the winter 2019 semester and not reported timely. An additional unofficial withdraw from the fall 2018 semester was not reported as withdrawn when the student stopped attending mid-semester. 3) Of the 40 students tested, there were 2 students that did not have their graduation status properly reported to the NSLDS. 4) Of the 40 students tested, there was 1 student who officially withdrew during the winter semester whose status changes were not reported to NSLDS within 60 days. Cause and Effect - The University does not have a control or process in place to ensure status changes are reported to the NSLDS accurately and timely. As a result, certain student status changes were not reported accurately and timely to the NSLDS. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting, including a review of students who graduated or withdrew, officially or unofficially. Views of Responsible Officials and Corrective Action Plan - The University concurs with the findings and recommendations. To address the instances of noncompliance within the finding the University with do the following: -The University will review the policy of allowing 30 days after the end of the semester to confer degrees to determine if an alternative time period is more appropriate to ensure timely and accurate reporting of student status changes. -Additionally, the University will review the policy to allow 60 days beyond the end of the semester for requests for late withdrawals to determine if an alternative time period is more appropriate. -The University currently reports late conferrals to the clearinghouse as they occur. We will investigate reporting those who are not conferred due to I (incomplete) grades, or classes that haven?t ended with another status until the conferral can be made. -We do not have an unofficial withdrawal status within registrars office. Students who stop attending are awarded the appropriate grade (in most cases an F grade), according to the catalog rules of the University. We will consult with the NSC to determine the best course of action to update students who do not withdraw, but stop attending to ensure the records match in NSC and NSLDS as determined with those students who have been identified as unofficially withdrawn as part of the University?s return of title IV aid calculation process and procedures. -The University currently manually reviews all submissions to NSC for correctness for withdrawn statuses. The University will now include a manual review of graduate submissions as well.

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