Elon University

Finding 2020 - 001 Enrollment Reporting and Clearing Status Change Submission Errors Federal Agency: U.S. Department of Education Cluster: Student Financial Assistance Cluster Program Year: June 1, 2019 through May 31, 2020 Assistance Listing #: 84.268 Federal Direct Student Loans Criteria: CFR 685.309(b)(2)(i) requires that unless it expects to submit its next updated enrollment report to the Secretary of Education within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under title IV of the Higher Education Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, 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. Condition: The University did not clear errors on enrollment submissions in a timely manner. The University does not have a process in place to resolve these errors in submission in a timely manner. Effect: The status changes of certain students were reported initially by the University in a timely manner (within the 30-day requirement), however, because the Clearinghouse ?rejected? certain student status changes, the information held by the Clearinghouse was inaccurate. The Clearinghouse was reporting those students as ?withdrawn? rather than ?graduated?. Cause: The control owners in the Registrar?s office were not aware of the of the requirement to manually resolve the errors within a 30-day timeframe. Context: For two of the twenty-five students selected for testing, the University received an online exception report from the National Student Clearinghouse several days after the 12/18/2019 enrollment submission indicating which status changes for graduated students could not be applied. These ?graduation status not applied? errors were not resolved within in a timely manner by the University. Questioned Costs: None Recommendation: We recommend that the University implement training to ensure control owners are aware of enrollment reporting requirements and evaluate the existence of these issues of non-compliance in the remaining population and remediate as necessary. Views of responsible officials and planned corrective actions: The University agrees with finding 2020 ? 001 that the University did not clear errors on enrollment submissions within the 30-day requirement. Management has reviewed enrollment submissions for fiscal year 2019-2020 and have taken corrective action to remediate the finding. The University has a corrective action plan to prevent further noncompliance. Recurring Finding: No

Finding 2020 - 001 Enrollment Reporting and Clearing Status Change Submission ErrorsCorrective Action Plan; Completion Date: August 21, 2020 The University agrees with finding 2020 - 001 that the University did not clear errors on enrollment submissions within the 30-day requirement. Action has been taken and all submissions that received the error of the "G" not applied. Students' records within the National Student Clearinghouse (NSC) have been updated to reflect the "graduated" status. To correct the errors identified in the 2019 audit that identified students that were not graduated ("G" not applied), the Registrar's Office logged in to the NSC, accessed the Degree Verify transmission history, and identified the submission term that contained the data identified as an error. The Registrar's Office then opened the "G" not applied tab, viewed the list, opened each student record and updated the individual record code to reflect graduated. It has been determined that the control owners in the Registrar's office were not aware of the change in the reporting process by the National Student Clearinghouse that provides an additional screen to check for processing errors. The Registrar's Office has created the following plan to be in compliance moving forward with future submissions: New order for enrollment and degree submissions After speaking with the NSC, we have determined the best way to submit enrollment and degree submissions for each term. At the end of each term the Registrar's Office will wait for all degrees to be conferred before submitting a final enrollment report. This will insure that the "graduated" status is captured for the students that have completed degrees. Once the final enrollment submission is processed by the NSC, the Registrar's Office will then submit a Degree Verify file. Once this file is processed by NSC, the Registrar's office will verify that no additional errors exist on the new verification screen. The Registrar's Office will correct any errors that exist on the verification screen within the required 30 - day period. National Student Clearinghouse Training The Registrar's Office will register and attend all available webinars and training sessions made available by the NSC. Three members of the Registrar's Office team have been cross trained to ensure files are uploaded, errors corrected, and files verified within the 30-day window. The NSC receives a processing calendar annually containing the file submission dates. Elon will continue to follow the NSC recommended guidelines for file submission. Responsible University officials for the corrective action plan are Rodney Parks, University Registrar and Assistant Vice President (rpark4@Elon.edu) and Nicole Jones, Senior Assistant Registrar for Operations (njones@elon.edu).

Finding 2019 ? 001 U.S. Department of Education Cluster: Student Financial Assistance Cluster Program Year: June 1, 2018 through May 31, 2019 CFDA#?s: 84.007 Federal State Education Opportunity Grant 84.033 Federal Work Study Program 84.038 Federal Perkins Loan Program 84.063 Federal Pell Grant Program 84.379 Teacher Education Assistance for College and Higher Education Grants (TEACH Grants) 84.268 Federal Direct Student Loans SIGNIFICANT DEFICIENCY Return of Title IV Funds Criteria: In accordance with 34CFR668.22, when students withdraw from the University, the portion of their federal funding disbursed under the Student Financial Assistance (?SFA?) program that is considered ?unearned? by the student must be returned to the Department of Education within 45 days of the University becoming aware that the student has withdrawn. Condition: Of the 5 withdrawing students examined, in four cases, unearned funds were not returned timely. Effect: The University did not return funds in accordance with the applicable criteria and are not in compliance with 34CFR668.22. Cause: Insufficient review controls around timing of returns of Title IV funds caused University staff to be unaware of the deadlines for returning funds. Context: Of the 47 students who withdrew during the 2018-19 school year, and had received Title IV aid, we examined 5, and found four instances of noncompliance. Recommendation: We recommend that Management implement procedures such as reviewing weekly/monthly reports of withdrawals to identify possible amounts which would need to be returned on a timely basis to avoid penalties. Views of responsible officials and planned corrective actions: The University agrees with finding 2019 ? 001 that Title IV funds were not returned to the Department of Education within 45 days of the University becoming aware that the student has withdrawn in accordance with the applicable criteria and are not in compliance with 34CFR668.22. We have reviewed student withdrawals for fiscal year 2018-2019 and have taken corrective action to remediate the finding. The University has a corrective action plan to prevent further noncompliance.

The University agrees with finding 2019 - 001 that Title IV funds were not returned to the Department of Education within 45 days of the University becoming aware that the student has withdrawn in accordance with the applicable criteria and are not in compliance with 34CFR668.22. To ensure all 2018-2019 unearned Title IV funds were returned the University reviewed all 47 withdrawals and has taken corrective action to return funds and remediate the finding. The University has determined that the training provided as part of a departmental change in responsibilities was not comprehensive to cover all criteria for the return of Title IV funds. It also determined that documentation provided to Accounting for draws and return of funds was not consistent. The University implemented the following plan to address compliance going forward: Improved work flow and communication Meeting was held with Accounting, Financial Planning, Bursar and Technology staff to document the notification process for student withdrawals, standardize documentation and establish a work flow. A new report to assist both Financial Planning and Accounting in the tracking of funds was discussed and is in development with a scheduled completion date of January 31, 2020. Financial Planning notifies Accounting of Title IV related student withdrawals including the amount of aid to be returned. As an additional safeguard, the Assistant Controller for Budget and Cash Management, Comptroller and Associate VP for Business and Finance receive email notification of all student withdrawals with Title IV funds when processed by the Bursar. This notification alerts Accounting to expect requests for return of funds from Financial Planning. Monitoring of return of funds Accounting maintains a spreadsheet of all student withdrawals with Title IV funds. This spreadsheet identifies the type of aid, date of the withdrawal and date funds are returned to the federal government. The spreadsheet is reviewed by Comptroller on a monthly basis. Funds are returned on an individual basis separate from draws to request funds. All Title IV funds for withdrawals for which Accounting has received notification have been returned within the 45- day window for the 2019-2020 fiscal year. Title IV compliance training The University has scheduled an eight-hour education session on January 10, 2020 on student financial aid compliance with an external provider. Accounting, Financial Planning and Bursar offices will participate as the training is designed to cover all aspects of Title IV compliance. The session is tailored to cover eligibility reviews, special tests and provisions including verification, disbursements, and return of Title IV funds. This interactive training will also apply these provisions to processes at Elon to ensure compliance. Responsible University officials for the corrective action plan are Susan Kirkland, Associate Vice President for Business and Finance (kirkland3@elon.edu) and Jane Deaton, University Comptroller (jdeaton@elon.edu).