Lenoir-Rhyne University

Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268) Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in a student’s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not submit its next Roster File to NSLDS within 60 days. Condition: The University did not report students’ status changes accurately and within the required timeframe. Cause: Significant turnover of staff in the Registrar’s Office. Effect or Possible Effect: The University was not in compliance with required federal guidelines. Questioned Costs: None. Context: Program Level: Based on a sample of 40 students, 29 students’ enrollment status were not accurately reported to the NSLDS. Program Level: Based on a sample of 40 students, 1 student exceeded the maximum time allowed in the program. Campus Level: Based on a sample of 40 students, 4 students’ selected were not reported to the NSLDS within the required timeframe. Campus Level: Based on a sample of 40 students, 5 students’ enrollment effective date was not correctly reported. Identification of Repeat Finding: This is a repeat of prior year finding 2024-001. Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner. Views of Responsible Officials: The University experienced significant turnover of staff in the Registrar’s Office in fiscal year 2024. This turnover unfortunately was the catalyst for untimely student status change submissions to the NSLDS. This was identified previously; however, the situation was not able to be rectified until well into the 2025 fiscal year. The University has hired new permanent staff, including an experienced registrar. This group has been working with the clearinghouse personnel to work out errors, and reporting is now being addressed in a timely manner.

Name of Responsible Individual: Jeni Wyatt, Assistant Provost for Undergraduate Education Condition: The University did not report students' status changes accurately and within the required timeframe. Corrective Action Plan: The University experienced significant turnover of staff in the Registrar’s Office in fiscal year 2024. This turnover unfortunately was the catalyst for untimely student status change submissions to the NSLDS. This was identified previously; however, the situation was not able to be rectified until well into the 2025 fiscal year. The University has hired new permanent staff, including an experienced registrar. This group has been working with the clearinghouse personnel to work out errors, and reporting is now being addressed in a timely manner. Anticipated Completion Date: September 30, 2025

2024-001

Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268) Criteria or Specific Requirement: N. Special Tests and Provisions –Return of Credit Balances: Federal Regulations require credit balances to returned to students within 14 days of the credit being created on the students account. Condition: The University did not return credit balances to students within the required timeframe. Cause: Administrative oversight. Effect or Possible Effect: The University was not in compliance with federal regulations regarding the timing of return of credit balances. Questioned Costs: None. Context: Based on a sample of 40 students, 2 students selected had a credit balance that was not returned within the 14-day period. Subsequent to the 14-day period, the credit balances were returned to the students. Identification of Repeat Finding: This is a repeat of prior year finding 2024-002. Recommendation: We recommend that the University enhance its procedures to ensure timely return of credit balances to students. Views of Responsible Officials: The University experienced significant turnover of staff in the Business Office, particularly in Student Accounts, during summer 2024 through fall 2024. The University recognizes that there needs to be better checks and balances in place to ensure all credit balances triggered by federal aid are properly refunded to students within the 14-day required period. Director of Student Accounts will more frequently post financial aid awards on student accounts, once a week at a minimum. The Business Office will monitor all refunds and process them twice weekly, with two different staff members cross-trained so that a week is never missed. The AVP of Business and Finance will review the status of all credit balances on Student accounts’ on a weekly basis throughout the year to ensure timely reimbursement. This was identified in the prior year audit, but unfortunately not fixed until well into the 2025 fiscal year.

Name of Responsible Individual: Alex Putzer, AVP of Business and Finance Condition: The University did not return credit balances to students within the required timeframe. Corrective Action Plan: The University experienced significant turnover of staff in the Business Office, particularly in Student Accounts, during summer 2024 through fall 2024. The University recognizes that there needs to be better checks and balances in place to ensure all credit balances triggered by federal aid are properly refunded to students within the 14-day required period. Director of Student Accounts will more frequently post financial aid awards on student accounts, once a week at a minimum. The Business Office will monitor all refunds and process them twice weekly, with two different staff members cross-trained so that a week is never missed. The AVP of Business and Finance will review the status of all credit balances on Student accounts’ on a weekly basis throughout the year to ensure timely reimbursement. This was identified in the prior year audit, but unfortunately not fixed until well into the 2025 fiscal year. Anticipated Completion Date: May 31, 2025

2024-002

Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268) Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in a student’s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not expect its next Roster File to NSLDS within 60 days. Condition: The University did not report students’ status changes accurately and within the required timeframe. Cause: Administrative oversight. Effect or Possible Effect: The University was not in compliance with required federal guidelines. Questioned Costs: None. Context: Program Level: Based on a sample of 40 students, 38 students’ enrollment status were not accurately reported to the NSLDS. Campus Level: Based on a sample of 40 students, 16 students selected were not reported to the NSLDS within the required timeframe. Identification of Repeat Finding: This is a repeat of prior year finding 2023-001. Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner. Views of Responsible Officials: The University experienced significant turnover of staff in the Registrar’s Office in late fiscal year 2023 through fiscal year 2024. This turnover unfortunately was the catalyst for untimely student status change submissions to the NSLDS. This was identified during the 2023 fiscal year-end audit; however, the situation was not able to be rectified until well into the 2024 fiscal year. The University has hired three new permanent staff and an interim registrar, as we search for a permanent registrar. This group has been working with the clearinghouse personnel to work out errors, and reporting is now being addressed in a timely manner.

Name of Responsible Individual: Jeni Wyatt, Assistant Provost for Undergraduate Education Condition: The University did not report students' status changes accurately and within the required timeframe. Corrective Action Plan: The University experienced significant turnover of staff in the Registrar’s Office in late fiscal year 2023 through fiscal year 2024. This turnover unfortunately was the catalyst for untimely student status change submissions to the NSLDS. This was identified during the 2023 fiscal year-end audit; however, the situation was not able to be rectified until well into the 2024 fiscal year. The University has hired three new permanent staff and an interim registrar, as we search for a permanent registrar. This group has been working with the clearinghouse personnel to work out errors, and reporting is now being addressed in a timely manner. Anticipated Completion Date: 10/31/2024

2023-001

Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268) Criteria or Specific Requirement: N. Special Tests and Provisions –Return of Credit Balances: Federal Regulations require credit balances to returned to students with 14 days of the credit being created on the students account. Condition: The University did not return credit balances to students within the required timeframe. Cause: Administrative oversight. Effect or Possible Effect: The University was not in compliance with federal regulations regarding the timing of return of credit balances. Questioned Costs: None. Context: Based on a sample of 40 students, 3 students selected had a credit balance that was not returned within the 14-day period. Identification of Repeat Finding: This is a repeat of prior year finding 2023-002. Recommendation: We recommend that the University enhance its procedures to ensure timely return of credit balances to students. Views of Responsible Officials: The University experienced significant turnover of staff in the Business Office, particularly in Student Accounts, during summer 2024 through fall 2024. The University recognizes that there needs to be better checks and balances in place to ensure all credit balances triggered by federal aid are properly refunded to students within the 14-day required period. Director of Student Accounts will more frequently post financial aid awards on student accounts, once a week at a minimum. The Business Office will monitor all refunds and process them weekly. Additionally, a concerted effort to have the majority of students signed up for eRefund will be made priority. The AVP of Business and Finance will review the status of all credit balances on Student accounts’ on a weekly basis throughout the year to ensure timely reimbursement.

Name of Responsible Individual: Alex Putzer, AVP of Business and Finance Condition The University did not return credit balances to students within the required timeframe. Corrective Action Plan: The University experienced significant turnover of staff in the Business Office, particularly in Student Accounts, during summer 2024 through fall 2024. The University recognizes that there needs to be better checks and balances in place to ensure all credit balances triggered by federal aid are properly refunded to students within the 14-day required period. Director of Student Accounts will more frequently post financial aid awards on student accounts, once a week at a minimum. The Business Office will monitor all refunds and process them weekly. Additionally, a concerted effort to have the majority of students signed up for eRefund will be made priority. The AVP of Business and Finance will review the status of all credit balances on Student accounts’ on a weekly basis throughout the year to ensure timely reimbursement. Anticipated Completion Date: 11/30/2024

2023-002

Federal Program Information: Student Financial Assistance Cluster: Federal Pell Grant Program (Assistance Listing #84.063). Criteria or Specific Requirement: C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)). Condition: The University had one instance during the year that were identified in which Title IV funds drawn were held in excess of the allowable time frame. Cause: Administrative oversight.   Effect or Possible Effect: The University is not in compliance with the Cash Management compliance requirements. While amounts were immaterial, certain funds were overdrawn and held in excess of the allowable time frame. Questioned Costs: Below reporting threshold. Context: One instance of excess cash that was not eliminated within the allowable time frame was identified for the Federal Pell Grant Program for the year ended May 31, 2024. Identification of Repeat Finding: No similar findings identified in the prior year. Recommendation: We recommend that the University enhance its procedures over cash management to ensure timely elimination of excess cash balances. Views of Responsible Officials: This is the first time, to the University’s knowledge, that this error has occurred. We believe it was a one-off employee manual oversight, and not a systemic issue. We believe the general procedures for performing the Title IV drawdowns are in good standing; however, we will add a process where the AVP of Business and Finance regularly reviews the Title IV drawdowns to prevent this in the future.

Name of Responsible Individual: Alex Putzer, AVP of Business and Finance Condition: The University had one instance during the year that were identified in which Title IV funds drawn were held in excess of the allowable time frame. Corrective Action Plan: This is the first time, to the University’s knowledge, that this error has occurred. We believe it was a one-off employee manual oversight, and not a systemic issue. We believe the general procedures for performing the Title IV drawdowns are in good standing; however, we will add a process where the AVP of Business and Finance regularly reviews the Title IV drawdowns to prevent this in the future. Anticipated Completion Date: 12/31/2024

Federal Program Information: Student Financial Assistance Cluster: Federal Pell Grant Program (Assistance Listing #84.063). Criteria or Specific Requirement: L. Reporting – Financial Reporting – Federal regulations require that the University submit origination and disbursement records for students to the Common Origination and Disbursement (“COD”) system. Items considered key in student origination records, if applicable, are: Social Security number, award amount, enrollment date, verification status code (when the applicate is selected for verification), transaction number, COA, and the “Academic Start Date” and “Academic End Date”. Condition: For certain students identified through our testing, a key item (enrollment date) in student Pell origination records submitted to the COD did not agree to university’s enrollment files. Cause: Administrative oversight.   Effect or Possible Effect: The University is not in compliance with Pell origination reporting requirements. Failure to accurately update borrower origination information prior to COD submission could result in improper awards of Title IV funds. Questioned Costs: None. Context: For 2 of 25 students selected for disbursement testing, the University did not accurately report the student enrollment date to the Department of Education Common Origination and Disbursement website. Identification of Repeat Finding: No similar findings identified in the prior year. Recommendation: We recommend the University ensure that disbursement records are submitted to COD no earlier than 7 days before and no later than 15 days after disbursement as required by federal regulations. Views of Responsible Officials: The University has evaluated its current practices to confirm student enrollment dates. As a result, the Office of Financial Aid will enhance its policies and procedures for processing Pell grant originations to ensure that accurate enrollment dates are recorded for reporting purposes. These enhancements will include updates to the university’s Pell processing procedures, conducting a simulation of the origination file prior to the official submission to the Common Origination Database (COD), additional training for staff, and implementing periodic secondary reviews.

Name of Responsible Individual: Courtney Thompson-Ballard, Director of Financial Aid Condition: For certain students identified through our testing, the University did not submit Federal Pell Grant payment data through the COD website within the required timeframes. Corrective Action Plan: The University has evaluated its current practices to confirm student enrollment dates. As a result, the Office of Financial Aid will enhance its policies and procedures for processing Pell grant originations to ensure that accurate enrollment dates are recorded for reporting purposes. These enhancements will include updates to the university’s Pell processing procedures, conducting a simulation of the origination file prior to the official submission to the Common Origination Database (COD), additional training for staff, and implementing periodic secondary reviews. Anticipated Completion Date: 10/31/2024

Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268) Criteria or Specific Requirement: N. Special Test and Provisions – Verification - An institution shall require an applicant selected for verification to submit acceptable documentation that will verify or update the following information used to determine the applicant's EFC: adjusted gross income, U.S. income tax paid, aggregate number of family members in the household, number of family members in the household who are enrolled as at least half-time students in postsecondary educational institutions if that number is greater than one, and untaxed income subject to U.S. income tax reporting requirements in the base year which is included on the tax return form, excluding information contained on schedules appended to such forms. Untaxed income and benefits include: Social Security benefits if the institution has reason to believe that those benefits were received and were not reported or were not correctly reported; child support if the institution has reason to believe child support was received; U.S. income tax deductions for a payment made to an individual retirement account or Keough account; interest on tax-free bond; foreign income excluded from U.S. income taxation if the institution has reason to believe that foreign income was received; and all other untaxed income subject to U.S. income tax reporting requirements in the base year included on the tax return form, excluding information contained on schedules appended to such forms. (34 CFR section 668.56). Condition: The University did not accurately verify all required information for 2 students. Cause: Administrative oversight. Effect or Possible Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with verification compliance requirements. Questioned Costs: None. Context: For 2 of 15 students selected for verification testing, the University did not properly perform verification procedures. Identification of Repeat Finding: No similar findings identified in the prior year. Recommendation: We recommend that the University enhance its procedures to ensure appropriate verification procedures are performed for all students who are selected for verification unless excluded by federal regulations. Views of Responsible Officials: The University has reviewed its current verification practices. As a result, the Office of Financial Aid will enhance its policies and procedures to ensure accurate verification outcomes. These enhancements will include additional training for financial aid counselors through both internal and external resources, the implementation of the NASFAA Tax Transcript Decoder documentation, and periodic secondary reviews.

Name of Responsible Individual: Courtney Thompson-Ballard, Director of Financial Aid Condition: The University did not accurately verify all required information for 2 students. Corrective Action Plan: The University has reviewed its current verification practices. As a result, the Office of Financial Aid will enhance its policies and procedures to ensure accurate verification outcomes. These enhancements will include additional training for financial aid counselors through both internal and external resources, the implementation of the NASFAA Tax Transcript Decoder documentation, and periodic secondary reviews. Anticipated Completion Date: 12/31/2024

Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268) Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting: Federal regulation 34 CFR 685.309 states that the institution shall accurately report a change in a student’s enrollment status directly to the lender or guarantee agency within 30 days if a student has graduated, withdrawn, or ceased to be enrolled (or failed to enroll) at least half-time and the school does not expect its next Roster File to NSLDS within 60 days. Condition: The University did not report students’ status changes accurately and within the required timeframe. Cause: Administrative oversight. Effect or Possible Effect: The University was not in compliance with required federal guidelines. Questioned Costs: None. Context: Program Level: Based on a sample of 25 students, 1 student’s enrollment status was not accurately reported to the NSLDS. Campus Level: Based on a sample of 40 students, 17 students’ selected were not reported to the NSLDS within the required timeframe. Identification of Repeat Finding: This is a repeat of prior year finding 2022-004. Recommendation: The University should implement procedures to ensure that student status changes are reported in a timely manner. Views of Responsible Officials: The University agrees with the finding - refer to the University’s Corrective Action Plan.

Name of Responsible Individual: Jennu Wyatt, Assistant Provost for Undergraduate Education. Corrective Action: The University experienced some turnover in the Registrar's office at the end of the 2023 fiscal year-end. This turnover unfortunately was the catalyst for the group of students who did not have their status change reported timely to the NSLDS as the previously submitted status change report, which these students were included within, kicked back from the NSLDS with several errors. That was unbeknownst to the remaining employees in the Registrar's office, until a couple of months later, when the issue was finally identified and resolved. The University now has a new Assistant Registrar in place and is interviewing for the Registrar position currently. Additionally, the Assistant Provost for Undergraduate Education, who now is the direct supervisor of the Registrar, is being trained in many Registrar functions, including the NSLDS reporting. The Assistant Provost is now on the communications contact list for all NSLDS reporting, as is the Assistant Registrar, so that any future error reports will be seen by multiple people and addressed in a timely manner. Anticipated Completion Date: 11/30/2023.

2022-004

Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268) Criteria or Specific Requirement: N. Special Tests and Provisions –Return of Credit Balances: Federal Regulations require credit balances to returned to students with 14 days of the credit being created on the students account. Condition: The University did not return credit balances to students within the required timeframe. Cause: Administrative oversight. Effect or Possible Effect: The University was not in compliance with federal regulations regarding the timing of return of credit balances. Questioned Costs: None. Context: Based on a sample of 25 students, 1 student selected had a credit balance that was not returned within the 14 day period. Recommendation: We recommend that the University enhance its procedures to ensure timely return of credit balances to students. Views of Responsible Officials: The University agrees with the finding - refer to the University’s Corrective Action Plan.

Name of Responsible Individual: Jeremy Shreve, Vice President of Business & Finance. Corrective Action: The University recognized that while the two students who were not issued refunds timely were unique situations, there needs to be better checks and balances in place to ensure all credit balances are properly refunded to students within the 14-day required period. One of the late refunds was caused due to untimely posting of financial aid awards in the student accounts office, as it was not within a traditional awarding window. In response to this concern, the Director of Student Accounts will more frequently post financial aid awards on sudent accounts, once a week at a minimum. The other late refund was caused by a student who did not properly set up their eRefund, which caused the payment to not be issued properly through the bank. To address this issue, the Director of Student Accounts is working with the IT department to create a reporting mechanism to identify what students are proprly signed up for eRefunds and cross-check them against the eRefund payment list before sending. This will identify any student not properly set up for the eRefund. Additionally, the Controller's office has a reconciliation process wherein any eRefund that is not issued from the bank properly should be identified. Unfortunately, this reconcilation process has not been performed frequently enough to catch all instances. The Controller's office has changed that to be performed on a weekly basis to ensure all instances are caught in time to be rectified before the 14-day period is over. Anticipated Completion Date: 1/31/2024.

Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268) Criteria or Specific Requirement: Special Tests and Provisions ? Return of Title IV Funds - 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. Condition: The University did not prepare certain students? return calculations properly. In addition, the University did not maintain adequate records to support its determination of the last date of attendance for students enrolled in a distance education program. Cause: Administrative oversight. Effect or Possible Effect: The University was not in compliance with required federal guidelines. Questioned Costs: Below reporting threshold. Context: For 1 of 4 students tested, the University used the incorrect number of days in term/payment period. For 2 of 4 students tested, the University was unable to substantiate the students? last dates of attendance. Identification of Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhance its procedures over the preparation and review of R2T4 calculations to ensure compliance with the return of Title IV funds requirements. Views of Responsible Officials: The University has reviewed current practices related to withdrawal/R2T4 calculations. As a result, the University will enhance current policy and procedures to better support staff in the proper calculation of return of Title IV funds requirements. These enhancements will include but are not limited to; additional staff training and periodic secondary review. The Office of Financial Aid will also work with the Office of Academic Records to document substantiated last dates of attendance for withdrawing students.

Name of Responsible Individual(s): Courtney Thompson, Director of Financial Aid Corrective Action: The University has reviewed current practices related to withdrawal/R2T4 calculations. As a result, the University will enhance current policy and procedures to better support staff in the proper calculation of return of Title IV funds requirements. These enhancements will include but are not limited to; additional staff training and periodic secondary review. The Office of Financial Aid will also work with the Office of Academic Records to document substantiated last dates of attendance for withdrawing students. Anticipated Completion Date: 5/31/2022

Federal Program Information: Student Financial Assistance Cluster: Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268) Criteria or Specific Requirement: Special Tests and Provisions ? Enrollment Reporting: Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (?FFEL?) loan programs via the National Student Loan Data System (?NSLDS?) (OMB No.1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). 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 which the financial aid administrator can access for the auditor. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information; ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. According to the Guide, any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days. Condition: Campus Level: The University did not report certain students? changes in enrollment status to NSLDS within the required timeframe. Program Level: The University did not accurately report certain students? significant data elements to NSLDS. Certain error/acknowledgement file errors were not corrected within the required timeframe. Cause: Administrative oversight. Effect or Possible Effect: The University was not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers. Questioned Costs: None. Context: For 2 of 40 campus level records tested, the University did not timely report the students? withdrawn status to NSLDS. For 1 of 25 program level records tested, the University failed to report the student?s withdrawn status to NSLDS. For 2 of 25 program level records tested, the University failed to report the students? second major program of study. Several instances of repeating error records were identified throughout the fiscal year. Recommendation: We recommend that the University enhance its procedures to ensure accurate and timely enrollment reporting. Views of Responsible Officials: The University has modified reporting practices to SSCR in order to meet Federal Regulations 34 CFR 690.83(b)(2), 34 CFR 682.610 and 34 CFR 685.309. The Office of Academic Records will report student enrollment to SSCR on the 15th of every month (or the following business day if the 15th falls on a weekend, holiday or scheduled university closure). This plan will allow for reporting from SSCR to NSLDS to meet the 60 day timeline for student status change. The University has also strengthened report criteria to ensure that all current program and major detail are provided to SSCR.

Name of Responsible Individual(s): Stacey Brackett, University Registrar Corrective Action: The University has modified reporting practices to SSCR in order to meet Federal Regulations 34 CFR 690.83(b)(2), 34 CFR 682.610 and 34 CFR 685.309. The Office of Academic Records will report student enrollment to SSCR on the 15th of every month (or the following business day if the 15th falls on a weekend, holiday or scheduled university closure). This plan will allow for reporting from SSCR to NSLDS to meet the 60 day timeline for student status change. The University has also strengthened report criteria to ensure that all current program and major detail are provided to SSCR. Anticipated Completion Date: 12/31/2022

Finding 2020-001: Gramm-Leach-Bliley Act ? Student Information Security Identification of the federal program: U.S. Department of Education Student Financial Aid Cluster Criteria or specific requirement: Uniform Guidance for Student Financial Aid (SFA) Programs {III. Compliance Requirements, N. Special Tests and Provisions, 10. Gramm-Leach-Bliley Act ? Student Information Security (16 CFR 313 and 314) stipulates that under the Gramm-Leach-Bliley Act (Public Law 106-102), financial institutions are required to explain their information-sharing practices to their customers and to safeguard sensitive data. The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the Gramm-Leach-Bliley Act. Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Institutions should perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b), which are: (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures, and documented safeguards for identified risks. Condition: The University performed a risk assessment and developed formal written policies to document safeguards for identified risk areas noted in 16 CFR 314.4 (b), as defined above, but did not put these policies in place and they were not operating during the year subject to audit. Cause: While the University began to address these items in fiscal year 2020, University management was unable to take the steps necessary in a timely manner to comply with these standards during the period under audit. Effect of potential effect: The University is not in compliance with the requirements defined above. Questioned costs: None Context: We inquired with University personnel, regarding the University?s compliance with the provisions of the Gramm-Leach-Bliley Act. We requested copies of documented policies and procedures that addressed the three areas noted in 16 CFR 314.4 (b), which are: (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures, and documented safeguards for identified risks. It was noted that the University has performed a formal risk assessment and has developed formal written policies and procedures for safeguards in response to risk areas noted in 16 CFR 314.4 (b), as defined above, during the year subject to audit. The policies and procedures, however, were not put into place and operating as of May 31, 2020. Recommendation: We recommend that the University formally put policies and procedures in operation that were developed to address the requirements of the Gramm-Leach-Bliley Act, as defined above. Views of responsible officials: Refer to the University?s Corrective Action Plan

Identifying Number: 2020-001 ? Gramm-Leach-Bliley Act ? Student Information Security Finding: same Anticipated Completion Date: May 31, 2021 University Official Responsible for Corrective Action: Nelson Murphy, Vice President for Finance and Administration Corrective Action Taken or Planned: The University completed and approved policies to address the requirements in 16 CFR 314.4 in late 2019. The University will also perform a documented risk assessment in fiscal 2021 as well as implement an IT security training program to comply with 16 CFR 314.4.

2019-001

Finding 2020-002 ? Enrollment Reporting Identification of the federal program: U.S. Department of Education Student Financial Aid Cluster Criteria or specific requirement: The code of Federal Regulations at 34 CFR Sections 685.309 and 690.83(b)(2) state that institutions must complete and return within 30 days of receipt the SSCR (Student Status Confirmation Report). Unless a roster will be submitted within the next 60 days, the University must notify the lender or guaranty agency within 30 days if it discovers that a student who has a loan either did not enroll or ceased to be in enrolled on at least a half-time basis. Condition: The University did not notify the National Student Loan Data System (NSLDS) within the required 60-day window of a student?s status change. Know questions cost: There are no known questioned costs or likely questions costs. Context: Based on a sample of 40 students, one student or 2.5% of the students selected was not report to the NSLDS within the required window as being withdrawn or enrolled as a full-time student Effect: Certification of the student?s status was not reported timely. Cause: Inadequate administrative oversight as required by the program control objectives. Recommendation: We recommend that the University implement adequate procedures to ensure that all status changes are reported in a timely manner for students who receive federal loans. Views of responsible officials: Refer to the University?s Corrective Action Plan

Identifying Number: 2020-002 ? Enrollment Reporting Finding: The University did not notify the National Student Loan Data System (NSLDS) within the required 60-day window of a student?s status change. The code of Federal Regulations at 34 CFR Sections 685.309 and 690.83(b)(2) state that institutions must complete and return within 30 days of receipt the SSCR (Student Status Confirmation Report.) Unless a roster will be submitted within the next 60 days, the University must notify the lender or guaranty agency within 30 days if it discovers that a student who has a loan either did not enroll or ceased to be in enrolled on at least a half-time basis. Anticipated Completion Date: May 31, 2021 Salem Official Responsible for Corrective Action: Stacey Brackett, Registrar and Courtney Thompson-Ballard, Director of Financial Aid Corrective Action Taken or Planned: The University has put in place a reporting plan to SSCR to meet Federal Regulations 34 CFR Sections 685.309 and 690.83(b)(2). The Office of Academic Records will report student enrollment status to SSCR on the 15th of every month (or the following business day if the 15th falls on a weekend/holiday). This plan will allow for reporting from SSCR to NSLDS to meet the 60 day timeline for student status change.

Finding 2019-001: Gramm-Leach-Bliley Act ? Student Information Security Identification of the federal program: U.S. Department of Education Student Financial Aid Cluster Criteria or specific requirement: Uniform Guidance for Student Financial Aid (SFA) Programs {III. Compliance Requirements, N. Special Tests and Provisions, 10. Gramm-Leach-Bliley Act ? Student Information Security (16 CFR 313 and 314) stipulates that under the Gramm-Leach-Bliley Act (Public Law 106-102), financial institutions are required to explain their information-sharing practices to their customers and to safeguard sensitive data. The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the Gramm-Leach-Bliley Act. Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Institutions should perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b), which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures, and documented safeguards for identified risks. Condition: The University did not perform a risk assessment nor have formal written policies in place to document safeguards for identified risk areas noted in 16 CFR 314.4 (b), as defined above, during the year subject to audit. Cause: While the University began to address these items subsequent to year-end, there was a lack of administrative oversight regarding the steps necessary to comply with these standards during the period under audit. Effect of potential effect: The University is not in compliance with the requirements defined above. Questioned costs: None Context: We inquired with University personnel, regarding the University?s compliance with the provisions of the Gramm-Leach-Bliley Act. We requested copies of documented policies and procedures that addressed the three areas noted in 16 CFR 314.4 (b), which are (1) employee training and management; (2) information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures, and documented safeguards for identified risks. It was noted that the University had not performed a risk assessment nor did it have adequate policies and procedures documented and in place to address the risk areas defined above during the period under audit. Recommendation: We recommend that the University perform a risk assessment and formally document its policies and procedures that address the requirements of the Gramm-Leach-Bliley Act, as defined above. Views of responsible officials: Refer to the University?s Corrective Action Plan

Identifying Number: 2019-001 ? Gramm-Leach-Bliley Act ? Student Information Security Finding: The University did not perform a risk assessment nor have formal written policies in place to document safeguards for identified risk areas noted in 16 CFR 314.4 (b), during the year subject to audit. The three areas that are required to be addressed by the standard are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures, and documented safeguards for identified risks. Anticipated Completion Date: May 31, 2020 University Official Responsible for Corrective Action: Peter Kendall, Senior Vice President for Finance and Administration Corrective Action Taken or Planned: Subsequent to year-end, the University began to develop policies to address the requirements in 16 CFR 314.4 and will complete those efforts in fiscal 2020. The University will also perform a documented risk assessment in fiscal 2020 as well to comply with 16 CFR 314.4.

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