Washington and Lee University

Findings and Questioned Costs Relating to Federal Awards 2024-001: Enrollment Reporting Federal Program – Student Financial Assistance Cluster – Federal Direct Student Loans Program (Assistance Listing No. 84.268) Federal Agency – U.S. Department of Education Federal Award Year – July 1, 2023 to June 30, 2024 Criteria Requirement 34 CFR 685.309 states that 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. 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. (Note: The automated processes and required reporting are described in the NSLDS Enrollment Reporting Guide. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.) When 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 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 a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Condition Found For 9 out of 40 enrollment status changes sampled, comparison of the institution’s records to that of NSLDS evidenced that enrollment reporting for these students were not accurately reflected within the NSLDS website. Therefore, the University did not report the accurate enrollment status to the NSLDS. Possible Cause and Asserted Effect Management’s review over its enrollment reporting requirements for SFA was not operating as designed to ensure accurate reporting of status changes. The personnel responsible for submitting degree verify and enrollment files to the national clearing house (NSC) did not perform this step in the correct sequence of the control, which is to submit the enrollment file first and then ensure that it is processed prior to submitting the degree verify file. Thus, student records were not accurately reflected in NSLDS within the 60-day time frame due to inadequate training of responsibilities. As such, certain status changes were not reported accurately or timely to NSLDS. Questioned Costs The questioned costs associated with this finding are not determinable as the finding is not of monetary nature. Sampling Approach The sample was not intended to be, and was not, a statistically valid sample. Identification of Repeat Finding This finding was a repeat of finding 2023-001. Recommendation We recommend that the University reinforce and train those individuals in the compliance control ownership role to ensure controls are operating as designed in order to prevent or detect and correct noncompliance on a timely basis. Specifically, strengthening its processes and controls around ensuring the enrollment file is processed prior to submitting the degree verify file to the NSLDS. Views of Responsible Officials The University agrees with the findings and the recommendation. The University has developed controls around the timeliness and accuracy of enrollment reporting. The instances of noncompliance were due to a lack of understanding of the need to ensure that NSC processes the enrollment file prior to submitting the degree verify file. As such, management has committed to reinforce and train the individuals in the compliance control ownership role with respect to the proper execution of the internal controls within the enrollment reporting.

Corrective Action Plan to Finding 2024‐001: Contact person for corrective action: Melissa Neal, Registrar Correction Action Plan: The University plans to implement the following: During the 2024‐2025 academic year, the Registrar Office will implement the following mechanisms to ensure that all status change records are reported to NLSDS accurately.  Reinforce training of individuals in the compliance and control ownership roles to ensure controls are operating as designed.  Ensure that individuals in compliance and control ownership roles within the Registrar’s office validated that enrollment files submitted were processed in the correct sequence.

2023-001

Findings and Questioned Costs Relating to Federal Awards 2023-001: Enrollment Reporting Federal Program – Student Financial Assistance Cluster – Noncash assistance – Federal Direct Student Loans Program (Assistance Listing No. 84.268) Federal Agency – U.S. Department of Education Federal Award Year – July 1, 2022 to June 30, 2023 Criteria Requirement 34 CFR 685.309 states that 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 National Student Loan Data System (NLSDS) Professional Access (NSLDSFAP) website. 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 U.S. Department of Education (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. (Note: The automated processes and required reporting are described in the NSLDS Enrollment Reporting Guide. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.) When 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 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 a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Condition Found For 21 out of 40 enrollment status changes sampled, comparison of the institution’s records to that of NSLDS evidenced that enrollment reporting for these students were not accurately reflected within the NSLDS website. Therefore, Washington and Lee University did not report the accurate enrollment status to the NSLDS. Possible Cause and Asserted Effect Management’s review over its enrollment reporting requirements for SFA was not operating as designed to ensure accurate reporting of status changes. The personnel responsible for identifying and resolving edit checks noted by the National Student Clearinghouse (NSC) did not perform this step of the control implemented by management, thus, did not accurately communicate the students’ status changes Management determined that the personnel assigned these responsibilities were not adequately trained to complete this step of the control. As such, certain status changes were not reported accurately to NSLDS. Questioned Costs The questioned costs associated with this finding are not determinable as the finding is not of monetary nature. Sampling Approach The sample was not intended to be, and was not, a statistically valid sample.Identification of Repeat Finding This finding is not a repeat of a finding in the immediately prior year. Recommendation We recommend that the Washington and Lee University reinforce and train those individuals in the compliance control ownership role to ensure controls are operating as designed in order to prevent or detect and correct noncompliance on a timely basis. Specifically, emphasizing the processes and controls around ensuring edit checks identified by the NSC are reviewed and resolved on a timely basis. Views of Responsible Officials The Washington and Lee University agrees with the findings and the recommendation. W&L has developed controls around the timeliness and accuracy of enrollment reporting. The instances of noncompliance were due to reliance on the NSC to identify and communicate potential errors in the accuracy of the student information uploaded to the NSC system instead of independently verifying there were no edit checks identified by the NSC as outlined in the design of the current internal controls implemented by the entity. As such, management has committed to reinforce and train the individuals in the compliance control ownership role with respect to the proper execution of the internal controls within the enrollment reporting.

Correction Action Plan: The University plans to implement the following: During the 2023-2024 academic year, the Registrar Office implemented the following mechanisms to ensure that all status change records are reported to NLSDS accurately.  Reinforce and train individuals in the compliance and control ownership role to ensure controls are operating as designed.  Incorporate the review of student status change records within the duties of the individuals in compliance and control ownership roles within the Registrar office.