SOUTHERN NAZARENE UNIVERSITY

Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.

The institution has refigured the R2T4 calculation for the affected files and will report the aid adjustments to COD. To avoid repeating the same mistake of miscalculating the number of break days in the semester in regard to completing the R2T4 for traditional undergraduates, we will verify with the school’s official academic calendar recordkeeper, the Registrar's Office, on an annual basis to ensure the correct number of academic days (and breaks) are being entered. We will also develop a committee made up of the Assistant Director of Financial Aid, the Director of Financial Aid, the Associate Vice President of Financial Services, and the Registrar to ensure we are collaboratively reviewing the school calendar profiles for the R2T4 process so as to eliminate any errors that might occur. Personnel involved are Josiah Mosley, Assistant Director of Financial Aid, Perry Diehm, Director of Financial Aid, Chris Peterson, Associate VP for Financial Services, and Chuck Chitwood, Registrar.

Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.

The institution has refigured the R2T4 calculation for the affected files and will report the aid adjustments to COD. To avoid repeating the same mistake of miscalculating the number of break days in the semester in regard to completing the R2T4 for traditional undergraduates, we will verify with the school’s official academic calendar recordkeeper, the Registrar's Office, on an annual basis to ensure the correct number of academic days (and breaks) are being entered. We will also develop a committee made up of the Assistant Director of Financial Aid, the Director of Financial Aid, the Associate Vice President of Financial Services, and the Registrar to ensure we are collaboratively reviewing the school calendar profiles for the R2T4 process so as to eliminate any errors that might occur. Personnel involved are Josiah Mosley, Assistant Director of Financial Aid, Perry Diehm, Director of Financial Aid, Chris Peterson, Associate VP for Financial Services, and Chuck Chitwood, Registrar.

Item 2020-001 ? Special Tests and Provisions: Enrollment Reporting CFDA Number ? 84.268 Federal Award Number ? P268K172028 Federal Award Year ? June 30, 2020 Federal Agency ? U.S. Department of Education Pass-Through Entity ? Not applicable Criteria: Enrollment reporting is required by Title 34 CFR Section 685.309 for all schools that participate in Title IV financial assistance. These regulations require that schools report information requested by the U.S. Department of Education (the Department) in a timeframe specified by the Department. Condition / context: Out of a sample of 40 students from a population of 1,391 students who withdrew or graduated during the audit period, the University did not report the correct enrollment status for five students to the National Student Loan Data System (NSLDS). The sample was not a statistically valid sample but was determined using Chapter 11 ? Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Government Auditing Standards and Single Audits Audit and Accounting Guide. Cause: Established procedures to ensure accurate and timely reporting of traditional student graduation status were not consistently performed by employees familiar with the operations of the Registrar's office due to the impact of COVID - 19 and related health and safety protocols. Effect: Inaccurate reporting can impact a student's loan grace period, in-school deferment eligibility, beginning loan repayment time period, and appropriate interest charges. Questioned cost: Not applicable. Repeat finding: Not a repeat finding. Recommendation: We recommend the University report the correct enrollment status for the four students identified. We also recommend the University enhance communication and monitoring controls to contemplate the ongoing impact of COVID - 19 on the Register's office operations and ensure that enrollment status changes are updated and timely submitted to the NSLDS through the Clearinghouse. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" in the attached Exhibit.

Identifying Number 2020.001 ? Special Tests and Provisions: Enrollment Reporting Finding Out of a sample of 40 students from a population of 1391 students who withdrew or graduated during the audit period, the University did not report the correct enrollment status for five students to the National Student Loan Data System (NSLDS). View of responsible officials The institution agrees with this finding. Upon investigation of the five students identified by the auditor, it was determined that all of these students had graduated from the Institution. During the May 2020 graduation period, most of the institutional employees were working remotely as a result of SNU?s safety protocol surrounding COVID-19, with a required rotation of office personnel. Rarely were two employees from the same office in the same place at the same time. Due to the complexities of quarantined staff, remote work, and overall understaffing on the Registrars area, procedures were completed by office personnel who were not generally responsible for the procedure. This made the time period around the normal traditional graduation very difficult to maintain ?business as usual?. When the May graduates were reported to the National Student Clearinghouse (NSC), these students were left off the report which subsequently kept them from being uploaded from NSC to the National Student Loan Database System (NSLDS). Therefore, NSLDS was not updated with the graduation status for these students. Corrective action taken and planned The graduation status of these five students was updated at NSC by the Registrar on October 6, 2020. After the Director of PGS Financial Aid confirmed NCS had processed the updates, he requested NSC to send a special submission to NSLDS. This was completed as of October 13, 2020. NSLDS should process the update within five to seven days. The University will enhance its review and monitoring controls to contemplate the ongoing impact of COVID-19 on the Registrar's office operations and ensure that enrollment status changes are updated and timely submitted to the NSLDS through the Clearinghouse. Also, the Director of PGS Financial Aid will continue the random checks of graduation reporting after each major institutional graduation date. An additional security check which will bolster submission of correct information, mandates at least two members of the Office of the Registrar will inspect each submission to NSC which will help find any possible errors and omissions. Responsible parties include Perry Diehm, Director PGS Financial Aid and Chuck Chitwood, Registrar.

Item 2019-001 ? Special Tests and Provisions: Enrollment Reporting CFDA Number ? 84.268 Federal Award Number ? P268K172028 Federal Award Year ? June 30, 2019 Federal Agency ? U.S. Department of Education Pass-Through Entity ? Not applicable Criteria: Enrollment reporting is required by Title 34 CFR Section 685.309 for all schools that participate in Title IV financial assistance. These regulations require that schools report information requested by the U.S. Department of Education (the Department) in a timeframe specified by the Department. Condition / context: Out of a sample of 25 students from a population of 873 students who withdrew or graduated during the audit period, the University did not report the correct enrollment status for four students to the National Student Loan Data System (NSLDS). The sample was not a statistically valid sample but was determined using Chapter 11 ? Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Government Auditing Standards and Single Audits Audit and Accounting Guide. Cause: The lack of timely review and communication by the Registrar's Office of information submitted to the National Student Loan Clearinghouse (Clearinghouse) within the required timeframe. Effect: Inaccurate reporting can impact a student's loan grace period, in-school deferment eligibility, beginning loan repayment time period, and appropriate interest charges. Questioned cost: Not applicable. Repeat finding: Not a repeat finding. Recommendation: We recommend the University report the correct enrollment status for the four students identified. We also recommend the University enhance communication and monitoring controls to ensure that enrollment status changes are communicated to the Registrar's Office in a timely manner and enrollment status changes submitted to the NSLDS through the Clearinghouse are reviewed for accuracy. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" in the attached Exhibit.

Identifying Number 2019.001 ? Special Tests and Provisions: Enrollment Reporting Finding Out of a sample of 25 students from a population of 873 students who withdrew or graduated during the audit period, the University did not report the correct enrollment status for four students to the National Student Loan Data System (NSLDS). View of responsible officials The institution agrees with this finding. Upon investigation of the four students which were identified by the auditor it was determined that all of these students had graduated from the institution. In two of the cases, the student?s graduation had been backdated in order to allow them to have the same graduation date as their cohort group. A third had the graduation date backdated to the end of the last traditional term, and a fourth had a grade change in April 2019 which allowed graduation after his classes had ended in November of 2017. These changes were all originally rejected by the Registrar, but the decision was reversed by higher academic personnel. Corrective action taken and planned The institution corrected two of the NSLDS reporting errors in July 2019. The other two are currently being corrected. A meeting will be held with members of Student Financial Aid, Registrar and appropriate academic officials to explain the ramifications of backdating graduation dates. Additional meetings will be held at least quarterly to provide earlier detection and correction of graduation date abnormalities. The Registrar will also make sure to manually check any student graduation information which by virtue of any backdating may not be selected by the National Student Clearinghouse (NSC) reporting process for a particular month. The Registrar will then report any needed adjustments manually to NSC. Also, the Director of PGS Financial Aid will continue the random checks of graduation reporting after each major institutional graduation date. Responsible parties include Perry Diehm, Director PGS Financial Aid and Chuck Chitwood, Registrar.

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