Boise State University

Criteria or specific requirement: Per 34 CFR 682.604(a)(1), a school must ensure that exit counseling is conducted with each Direct Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school, and that an individual with expertise in the Title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions. Condition: The University did not have documentation of exit counseling notification. Context: During our testing of 40 students, we identified 1 student that did not have documentation of exit counseling notification. Questioned costs: None. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to the applicable student who withdrew in two consecutive terms. The student received exit counseling after the first withdrawal but not after the second. Repeat finding: No. Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of responsible officials: Management acknowledges the finding and has developed a plan to correct the finding.

Criteria or specific requirement: The Department of Education requires that Title IV credit balances must be paid to the student or parent no later than 14 days after the credit balance occurred. (34 CFR 164(h)(2)). Condition: The University did not timely refund credit balances to the student or parent. Context: During our testing of 40 students, we identified 1 student that was not refunded within the required 14 days. The credit balance was refunded 11 days late. Questioned costs: None. Effect: The student or parent did not have access to Title IV funds timely after disbursement. Cause: The Student Financial Aid office had an automated process to ensure all refunds were issued in 14 days failed to recognize a credit balance of less than $10 in a student's account. Repeat finding: No. Recommendation: We recommend the University review credit balance refund processes, including any automated processes, to ensure all credit balances are paid timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 & 84.268 Federal Award Identification Number and Year: P063P230097 & P268K240097 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct Loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); 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 certify 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. 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. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of the accuracy of NSLDS reporting, we identified eight out of forty samples where the program effective date per institutional records did not match the program effective date reported in NSLDS. Context: Out of 40 students tested, we identified eight students in which the program effective date per institutional records did not match the program effective date reported in NSLDS. Questioned costs: None.Effect: The University was out of compliance as it relates to ensuring the program effective date reported in NSLDS matches institutional records. Cause: The program effective dates per institutional records not matching program effective date per NSLDS program enrollment was due to either and old admissions software or the Online Major Change (OMC) tool. Repeat finding: No. Recommendation: We recommend the University review its current procedures for NSLDS reporting and implement additional procedures to ensure program effective dates in NSLDS match institutional records. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 34 CFR 668.22(B)(2) states, an institution must document a student's withdrawal date determined in accordance with paragraph (b)(1) and maintain the documentation as of the date of institution's determination that the student withdrew. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of timely and accurate return of Title IV funds, we identified one out of 40 samples that the return of Title IV funds was later than 45 days after the institution's determination that the student withdrew. Additionally, one out of 40 samples did not have documentation for the student's withdrawal date used for the return of Title IV calculation.Context: We selected forty samples to test which resulted in two exceptions: 1. One had the return of Title IV funds later than 45 days after the institution's determination that the student withdrew, and 2. One did not have documentation for the student's withdrawal date used for the return of Title IV calculation. Questioned costs: $270 Effect: The University had two elements of noncompliance as it relates to the Department of Education’s many requirements of returning Title IV funds. Cause: Of the two exceptions: 1. A student’s Title IV funds were returned 65 days after the institutional determination. Per discussion with the University, the daily query being used to process disbursements in the Fall semester wasn’t coming through over the weekend as it should have been. Upon discussion with the University, this impacted the timeliness of two other students not tested. 2. A student’s documentation of withdrawal date was not retained by the University due to a former staff member not asking other department employees to contact instructors for Last Date of Attendance for an officially withdrawn course. They instead used the date the course was officially dropped in self-service. Repeat finding: No. Recommendation: We recommend the University review its current procedures for return of Title IV funds. As part of the review, the University should implement safeguard to ensure refunds are returned timely and that refund amounts are supported by having documentation of withdrawal dates. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 Federal Award Identification Number and Year: P063P230097 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Each year, based on the maximum Pell Grant established by Congress, ED provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment Schedule provides the maximum scheduled award a student would receive for a full academic year as a full-time student based on their EFC and COA. The Disbursement Schedules are used to determine annual awards for full-time, three-quarter time, half-time, and less-than-half-time students. All Schedules, however, are based on the COA of a full-time student for a full academic year (see Volume 7, The Federal Pell Grant Program and Iraq and Afghanistan Service Grants, of the FSA Handbook for 2023-24 for guidance on selecting formulas for calculating cost of attendance, prorating costs for programs less or greater than an academic year and determining payment periods). Disbursement schedules for 20222023 and 2023-2024 award years can be found at the following links: 2022-2023 Federal Pell Grant Payment and Disbursement Schedules (GEN-22-04) and 2023-2024 Federal Pell Grant Payment and Disbursement Schedules (GEN-23-02). Students that receive Pell Grant may not receive more than six Scheduled Awards (12 semesters, or the equivalent) as measured by the percentage of “lifetime eligibility used” (LEU) field in COD (tracked by ED) (20 USC 1070a(c)(5)). The LEU maximum percentage for student eligibility is 600 percent. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing our testing of return of Title IV funds, one student had been awarded Pell when they were not eligible to receive Pell due to the timing of the award. Context: During our Return of Title IV testing, we selected forty samples to test. While testing eligibility was not the focus of this test, the University brought to our attention one exception of a student being awarded Pell when they were not eligible to receive Pell due to the timing of the award. We also tested 40 other students in our eligibility testing in which no exceptions were identified. Questioned costs: $1,879. Effect: The University was out of compliance with the requirement to properly award students Title IV funds based on eligibility. Additionally, the University was out of compliance as it relates to properly calculating the return of Title IV funds. Cause: Per discussion with the University, Pell was awarded erroneously and a review process did not identify the issue prior to disbursing the aid. Repeat finding: No. Recommendation: We recommend the University review its current procedures for awarding Title IV funds to ensure only eligible students are receiving funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Justice Federal Program Title: Postconviction Testing of DNA Evidence; Capital Case Litigation Initiative Assistance Listing Number: 16.820; 16.746 Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.516(4): Known questioned costs that are greater than $25,000 for a Federal program which is not audited as a major program should be reported as finding. Except for audit follow-up, the auditor is not required under this part to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (e.g., as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, then the auditor must report this as an audit finding. Additionally, per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. CFR 200.403(a) requires costs incurred on federal awards to be necessary and reasonable for the performance of the Federal award and be allocable thereto. Condition: CLA was notified by the Post-Award Office of Sponsored Programs that they were informed about several irregularities and potentially unallowable costs related to certain Department of Justice Awards. Context: The University conducted an internal investigation in conjunction with the Idaho State Board of Education Internal Audit and Advisory Services, the investigation identified unallowable costs/activities that were charged to Department of Justice Awards. The University notified the Department of Justice of this situation through a Disclosure Letter to the Department. The disallowed costs were related to time and effort that was not allocable to the affected grants as well as lobbying efforts and related indirect cost recoveries. Questioned costs: $65,750.67. Effect: The University was out of compliance as it relates to charging disallowable costs/activities to federal programs. Cause: An employee was found to have intentionally overridden the system of internal controls in violation of University policy. Repeat finding: No Recommendation: We recommend the University continue to foster a research and creative activity environment that stresses the importance of compliance and prompt disclosure and resolution of any self-identified issues. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Criteria or specific requirement: Entities receiving federal awards must identify in its accounts all federal awards expended and report those amounts on the Schedule of Expenditures of Federal Awards for the period the federal award was expensed. Specifically, in accordance with Uniform Administrative Requirements outlined in 2 CFR 200, the guidance states: Per 2 CFR 200.502, The determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In addition, per 2 CFR 200.510, the Schedule of Expenditures of Federal Awards (SEFA) must be prepared to reflect the awards for the period covered by the auditee’s financial statements. Lastly, section 2 CFR 200.510 states that for costs to be allowable, they should be determined in accordance with generally accepted accounting principles (with exceptions provided in that part). Condition: The University’s year-end cutoff controls allowed for certain costs from Fiscal Year 2022 to not be reported in the Fiscal Year 2022 SEFA but rather reported in the Fiscal Year 2023 SEFA. Context: During our testing of 40 payroll transactions, we found one instance of 2022 fringe benefits being charged to a federal program in 2023. In addition, during our testing of 40 general disbursements transactions, we identified four instances of 2022 costs being charged to federal programs in 2023. Questioned costs: Known amounts of 2022 costs included in the 2023 SEFA was $3,214. (ALNs: 47.041, 47.083, 93.866, and 10.310 Award Numbers: 1663642, 1757324, R01AG059923, and 2022-67020-36410) Cause: Per the University, the cause for the five exceptions were due to: The one payroll exception was due to the 2021-2022 Human Capital Management (HCM) implementation and the issues that implementation brought about. As disclosed in a direct communication with the University’s cognizant agency, the initial custom software used for the allocation of fringe benefit costs did not work appropriately. As a result, throughout 2022, the University dedicated significant resources to address the HCM shortcomings. Then, in 2023, various corrections were made (again, as disclosed to the cognizant agency.) This sample was one of those costs that was identified as not properly being allocated to the federal program in the prior year; thus, was charged to the federal government in the current fiscal year. Three of the four general disbursement exceptions related to the University’s procurement card accrual policy. Currently, the University’s accrues for procurement card purchases through June 23, which leaves seven days of activity that flows into the next fiscal year. Three of our samples relate to procurement card charges incurred during these seven days. The last of the four general disbursements that related to a prior year but reported in the Fiscal Year 2023 was due to a staffing issue. A key employee responsible for monitoring specific departmental charges fell ill and was out for a period of time. Upon the employee’s return, the employee spent time analyzing charges and identified the cost that should have been recorded as a federal charge in the prior year; thus, then charged the federal agency in Fiscal Year 2023. Effect: The University was out of compliance as it relates to identifying and reporting federal costs in the period incurred. Repeat finding: No Recommendation: We recommend the University evaluate its cutoff procedures to ensure federal costs are identified and reported in the correct fiscal year. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Criteria or specific requirement: 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. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs. The determination of the difference is often referred to as R2T4 calculations. The amount of earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student?s withdrawal date. The Department of Education (ED) requires that R2T4 calculations are performed unless one module that includes 49% or more of the number of days in the payment period has been completed (34 CFR 668.22(a)). In addition, the Federal Student Aid Handbook, published by the Department of Education, states that percentages are calculated to four decimal places and is rounded to three decimal places for R2T4 calculations. Condition: The University calculated R2T4 for modular students that had completed more than 49% of the days in the payment period. In addition, the University calculated one student's return using the incorrect completed percentage. Context: Forty students who received aid and then withdrew, never began attendance, or were terminated during the fiscal year were tested. Three exceptions were identified as follows: ? Two students that were taking module classes had incorrect calculations. Both had completed enough modular time that included 49% or more of number of days in the payment period. Given these students withdrew after completing more than 49% of the number of days in the payment period, they should have been exempt from the return of funds calculations. $3,940 was returned that should not have been. ? One student in which the calculation used the incorrect percentage earned. The amount of refund calculated by the school was $816. The actual amount that should have been refunded was $959. Questioned costs: None. Cause: There was a misinterpretation of the new regulations from ED. The University did not detect an automatic override amount for the last date of attendance in their system. Effect: Certain R2T4 calculations were performed incorrectly. The exceptions noted above resulted in loan funds that were incorrectly returned to ED totaling $3,940 offset by an additional amount needing to be returned to the ED of $143. Repeat finding: No Recommendation: We recommend the University update their R2T4 calculation process to eliminate the students that completed 49% of the payment period days in their modular classes. We also recommend the University review the calculation for automatic last date of attendance overrides. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 674.19(e) states that Institutions must retain original, true, and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan made. An original electronically signed MPN must be retained by the institutions for three years after all the loans made on the MPN are satisfied. Condition: During our testing, we noted two of the Perkins files in which the MPN were not retained on file. Context: We tested record retention for 20 student Perkins Loans. Of the 20, we identified two students? MPNs were not maintained as required by the regulations. Questioned costs: None. Cause: The records were lost or misplaced. Effect: The University was not in compliance with the Perkins recordkeeping regulations. Repeat Finding: No. Recommendation: We recommend that the University implement procedures to ensure all documentation is being maintained as required by federal regulations. Views of responsible officials: The University agrees with the finding.

FINDING 2019-001 Enrollment Reporting Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education CFDA Number: 84.268 Federal Program Name: Federal Direct Student Loans Award Year: 2018-19 CFDA Number: 84.038 Federal Program Name: Federal Perkins Loan Program Award Year: 2018-19 Condition and context: A sample of students who were borrowers of Federal direct student loans or Federal Perkins loans and had graduated from the University during the 2018-19 fiscal year was selected. The enrollment information and graduation date per the University?s records was compared to the information reported to the NSLDS. We noted that 1,622 graduates who were Federal borrowers were considered graduated by the University, however, their NSLDS Enrollment Detail report did not show the graduated status. These students had their degrees conferred by the University and were considered to be ?G Not Applied? errors on the NSC's Degree Reporting page. After being corrected for the "G Not Applied" error, their degrees were verified/posted through the NSC. However, the University Registrar was not aware that there was an additional enrollment reporting field that needed to be reported to the NSC in order for these "G Not Applied" records to update the student's status to "Graduated" on the NSLDS. As such, this was discovered during the Single Audit and upon further investigation by the University, 1,317 students with "G Not Applied" errors from the 2017-18 award year were also affected. Random, not statistical sampling was used. Questioned costs: None to be reported. Effect: This information is utilized by ED, the Federal Direct Student Loan program, lenders, and other institutions to determine in-school status. NSLDS also uses the newly submitted enrollment data to recalculate a student?s 150% limit for direct subsidized loans to determine if loss or protection of the subsidy should occur. Therefore, errors in enrollment reporting could impact future subsidy loss or protection related to the 150% limit. Cause: This occurred because of lack of proper understanding of third-party servicer's parameters in reporting graduated students' enrollment statuses. There is also no control that monitors for compliance. Repeat finding: No. Recommendation: We recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. Furthermore, we recommend the University educate and train staff involved in the process regarding the Enrollment Reporting compliance responsibilities and the consequences of inaccurate reporting to the NSLDS via the NSC. This policy should specifically address the personnel assigned to various tasks (data entry and review). Opportunities for additional NSC training in this area and others are available through the NSC?s Clearinghouse Academy page. Lastly, we recommend the University establish an internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot-checks the status updates on NSLDS so to internally audit the submissions.

FINDING 2019-002 Enrollment Reporting Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education CFDA Number: 84.268 Federal Program Name: Federal Direct Student Loans Award Year: 2018-19 CFDA Number: 84.038 Federal Program Name: Federal Perkins Loan Program Award Year: 2018-19 Condition and context: In our audit sample, two of the 26 students who officially withdrew from a term in 2018-19 were reported to the NSLDS timely on the first-of-term batch as submitted via the NSC; however, when gathering the data for the samples for the Single Audit, it was discovered by the University that the separation/withdrawal date as showing within the NSLDS was not correct and was subsequently corrected via "NSLDS Web" certification method on 6/4/19, which is outside of the required timeframe for timely reporting. The effective date (withdrawal date) was misreported initially and as a result, for these two students, the status updates to NSLDS were inaccurate, and once corrected, were certified outside of the timeframe as stipulated by the Federal guidelines. Upon further investigation by the University, there were 61 students who officially withdrew from a term in 2018-19 whose effective dates were inaccurately reported in the initial first-of-term batch submission via the NSC and needed to be subsequently corrected. Random, not statistical sampling was used. Questioned costs: None to be reported. Effect: This information is utilized by ED, the Federal Direct Loan program, lenders, and other institutions to determine in-school status. NSLDS also uses the newly submitted enrollment data to recalculate a student?s 150% limit for direct subsidized loans to determine if loss or protection of the subsidy should occur. Therefore, errors in enrollment reporting could result in incorrect future eligibility for undergraduate aid, as well as impact future subsidy loss or protection related to the 150% limit. Cause: This occurred because of lack of proper understanding of the date to report and also a miscommunication in the department as to whose responsibility it was to make the changes to the NSLDS. There is also no control that monitors for compliance. Repeat finding: No. Recommendation: We recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. Furthermore, we recommend the University educate staff involved in the process regarding the Enrollment Reporting compliance responsibilities and the consequences of inaccurate reporting to the NSLDS via the NSC. This policy should specifically address the personnel assigned to various tasks (data entry and review). Opportunities for additional NSC training in this area and others are available through the NSC?s Clearinghouse Academy page. Lastly, we recommend the University establish an internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot- checks the status updates on NSLDS so to internally audit the submissions.

FINDING 2019-003 Enrollment Reporting Significant Deficiency in Internal Control over Compliance Student Financial Assistance Cluster U.S. Department of Education CFDA Number: 84.268 Federal Program Name: Federal Direct Student Loans Award Year: 2018-19 CFDA Number: 84.038 Federal Program Name: Federal Perkins Loan Program Award Year: 2018-19 Criteria: The National Student Loan Data System (?NSLDS?) is the Department of Education?s (?ED?) centralized database for students? enrollment information. It is the University?s responsibility to update this information timely and accurately. The University determines how often it receives the Enrollment Reporting roster file with the default set at every 60 days. Under the loan programs, schools must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by ED via NSLDS. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis (34 CFR section 685.309). The University has engaged the National Student Clearinghouse's (NSC) services to assist with the reporting of student's status changes and degrees to the NSLDS. Condition and context: For four of the 26 official withdrawal status change samples who were reported as "withdrawn" to the NSLDS, their status updates were made using the "NSLDS Web" certification method and were not reported timely to the NSLDS within 60 days of the date in which they were identified as a withdrawal. The days? difference between the four students? withdrawal dates and the dates they were reported per NSLDS ranged from 71 - 205 days. Random, not statistical sampling was used. Questioned costs: None to be reported. Effect: This information is utilized by ED, the Federal Direct Loan program, lenders, and other institutions to determine in-school status. NSLDS also uses the newly submitted enrollment data to recalculate a student?s 150% limit for direct subsidized loans to determine if loss or protection of the subsidy should occur. Therefore, errors in enrollment reporting could result in incorrect future eligibility for undergraduate aid, as well as impact future subsidy loss or protection related to the 150% limit. Cause: This occurred because of miscommunication in the department as to whose responsibility it was to make the changes to the NSLDS. There is also no control that monitors for compliance. Repeat finding: No. Recommendation: We recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. Furthermore, we recommend the University educate staff involved in the process regarding the Enrollment Reporting compliance responsibilities and the consequences of inaccurate reporting to the NSLDS via the NSC. This policy should specifically address the personnel assigned to various tasks (data entry and review). Opportunities for additional NSC training in this area and others are available through the NSC?s Clearinghouse Academy page. Lastly, we recommend the University establish an internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot- checks the status updates on NSLDS so to internally audit the submissions.

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