Nebraska Wesleyan University

Significant Deficiency – Special Tests and Provisions: Enrollment Reporting Program: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: May 31, 2025 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act 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 (ii) 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. Condition/Context: For one out of 28 students selected in the sample, the effective date that was reported to the National Student Loan Data System (NSLDS) did not match the date that the student changed status. For a second student, the student’s enrollment status was not correctly reported within the 60 day requirement. The sample was not a statistically valid sample. Questioned Costs: Not applicable. Cause: For the misreported effect date, management speculates a system update in Colleague may have overwritten or re-timestamped the enrollment status change. For the student not reported within 60 days, this issue resulted from a data entry error during batch processing of status updates in Colleague. The incorrect status type was inadvertently applied due to overlapping workflows and timing of updates. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If the University does not review, update and verify student enrollment statuses, effective dates of the enrollment status and the anticipated completion dates, then the Title IV student loan records can be inaccurate. Recommendation: The University should review its procedures and controls to ensure that all effective dates for enrollment status changes are updated accurately in NSLDS. Management's Response: To prevent future occurrences, 1) Management has implemented an additional verification step in our status update workflow, 2) Management is reviewing how major changes interact with enrollment status updates in Colleague and 3) Management will implement a validation step to ensure that effective dates reflect the original action date when multiple updates occur in close succession.

Significant Deficiency - Special Tests and Provisions: Return of Title IV Fund Calculations Program: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: May 31, 2025 Criteria: 34 CFR 668.22 requires that 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 in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition/Context: For two of the six students selected in the sample, the amount of the Title IV refund was calculated incorrectly due to using the incorrect number break days for students that withdrew in the Spring term. This results in too much being returned to the U.S Department of Education. The sample was not a statistically valid sample. Questioned Costs: $57 of Federal Direct Student Loans ALN 84.268. Cause: Incorrect break days were input into the R2T4 tool on U.S Department of Education's Common Origination and Disbursement website which is used to perform the R2T4 calculations. These incorrect break days were not identified and corrected in the University personnel’s review of the calculations. Effect: The University refunded $57 of Federal Direct Student loans that should not have been refunded. Recommendation: The University should review and update its procedures and controls to ensure the correct academic period dates and breaks are used for performing R2T4 calculations. Management's Response: The scheduled break days for the spring semester accidentally failed to include the weekend before the week of Spring Break. The school calendar profile for the Return of Title IV Funds Calculation will now be reviewed by both the Director of Scholarships and Financial Aid and the Assistant Director of Financial Aid before being created in the COD Return of Title IV Funds Tool each term.

Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act 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 halftime basis for the period for which the loan was intended; or (ii) 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. Condition/Context: Exceptions were noted for 7 out of the 25 students tested. The exceptions noted are as follows: • For four students, incorrect status was reported to National Student Loan Data System (NSLDS) at the campus level. These four students, in addition to one more student, had incorrect status reported to NSLDS at the program level. • For seven students, incorrect effective dates were reported at the program level. The sample was not a statistically valid sample. Cause: The University uses the National Student Clearinghouse (NSC) to transmit enrollment information to NSLDS. The University transmitted correct enrollment information for the students identified above to NSC, yet the program level enrollment information was not correct in NSLDS. In addition, it was noted that the University’s system was such that all students reported ¾ time were reported in NSLDS as half time. Effect: Incorrect information was reported to NSLDS. Questioned Costs: Not applicable. Recommendation: We recommend the University adjust their system to correctly report ¾ time enrollment and work with NSC to understand the errors in program level reporting to NSLDS. Management's Response: There is no disagreement with the audit findings. We discovered the program was only reporting students as less-than-half-time (“L”), half-time (“H”), and full-time (“F”). We have already adjusted the enrollment reporting program to properly report students who are enrolled at a ¾-time (“Q”) level. We will also work with the National Student Clearinghouse to ensure the enrollment effective dates are correctly reported for both the campus and program levels.

2021-001 National Student Loan Data System (NSLDS) Enrollment Reporting Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster CFDA Numbers: Various Award Period: July 1, 2020 through June 30, 2021 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date as well as program enrollment effective date. Condition: During our testing, we noted for 2 out of the 40 students tested, the enrollment effective date did not match the enrollment effective date per the University?s records. Questioned costs: None Context: During our testing, it was noted the University did not have proper procedures in place specifically for withdrawals to ensure the enrollment effective date was updated accurately within NSLDS. Cause: The University did not have a process in place to ensure the effective date reported to NSLDS matches the effective of the student?s last date of attendance. Effect: The enrollment effective date reported to NSLDS is used to determine when the student?s grace period should begin. By not reporting an incorrect effective date, the grace period begin date for the student will be incorrect. Repeat Finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the enrollment effective date reported to NSLDS is aligning with the University?s last date of attendance. Views of responsible officials: There is no disagreement with the audit finding.

Significant Deficiency in Internal Control over Compliance, Other matters

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