Woodbury UniversityHigher Education

Finding 2024-002 – Special Tests and Provisions – Enrollment Reporting – Material Weakness in Internal Control Over Compliance (See SFQC - Section III - Federal Award Findings and Questioned Costs - Finding 2024-002 for table included) Criteria: The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information. It is Woodbury University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes. Woodbury University is ultimately responsible for the timeliness and accuracy of this information even when a third-party servicer is used as an intermediary to report on the University’s behalf. Woodbury University currently contracts with a third-party servicer and has elected to receive an Enrollment Reporting roster file every 30 days from NSLDS. At a minimum, institutions must certify the enrollment status of all students included on the roster file within 15 days of receiving the roster file. If errors are identified, the University has 10 days to resubmit a corrected response. Unless the school expects to complete its next roster file within 60 days, the school must notify the secretary within 30 days, if it discovers that a student who received a loan under Title IV of the Act either did not enroll or ceased to be enrolled on at least a half-time basis (34 CFR section 685.309). Condition/context: From a system generated population of 119 students who received federal aid and either graduated, withdrew, or changed their permanent address during the year ended June 30, 2024, we selected a sample of 17 students who received direct loans. We find this sample representative to the population. The enrollment information and withdrawal or graduation date per the Woodbury University’s records were compared to the information reported to NSLDS in order to determine if status changes were reported accurately and within the required timeframes. Of the 17 students selected for testing, 17 were not reported to the NSLDS within the required timeframe and had an incorrect status reported to the NSLDS. Questioned Costs: No questioned costs were identified as part of this finding. Effect: The NSLDS database did not include all accurate information in the timeframe required by ED. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine inschool status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Cause: The lack of timely reporting was caused by turnover in the Registrar’s office. Repeat finding: Yes, see 2023-002. Recommendation: Woodbury University should develop additional procedures and controls to monitor the accuracy of information provided to its third-party servicer and to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate. Each institution has access to manually correct information directly within NSLDS at any time. Views of responsible officials and planned corrective actions: Management agrees with the finding and recommendation and plans to implement additional controls.

Finding 2023-002 – Special Tests and Provisions – Enrollment Reporting – Significant Deficiency in Internal Control Over Compliance (See Section III - Federal Awards Findings - Finding 2023-002 for included table) Criteria: The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information. It is Woodbury University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal aid changes. Woodbury University is ultimately responsible for the timeliness and accuracy of this information even when a third-party servicer is used as an intermediary to report on the University’s behalf. Woodbury University currently contracts with a third-party servicer and has elected to receive an Enrollment Reporting roster file every 30 days from NSLDS. At a minimum, institutions must certify the enrollment status of all students included on the roster file within 15 days of receiving the roster file. If errors are identified, the University has 10 days to resubmit a corrected response. 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 federal aid either did not enroll or ceased to be enrolled on at least a half-time basis (34 CFR section 685.309). Condition/context: We selected a sample of students identified by Woodbury University as having received some federal assistance and who either withdrew, took a leave of absence (LOA), or graduated during the year ended June 30, 2023. Our sample consisted of 2 students out of a population of 3 that withdrew or took a LOA during the year and a sample of 13 students out of a population of approximately 122 that graduated during the year. We then compared the enrollment information and withdrawal, LOA, or graduation date per Woodbury University’s records to the information reported to NSLDS. We believe this to be a representative sample of the population. We noted exceptions with all Spring 2023 graduates, of which there were 11 in our sample, whose status change was not reported within the required time frame. Questioned Costs: No questioned costs were identified as part of this finding. Effect: Enrollment status is utilized by students, ED, the 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, this significant deficiency 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: The lack of timely reporting was caused by turnover in the Registrar’s office. Repeat finding: This is not a repeat finding. Recommendation: Woodbury University should develop additional procedures and controls to monitor the accuracy of information provided to its third-party servicer and to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate. Each institution has access to manually correct information directly within NSLDS at any time. Views of responsible officials and planned corrective actions: Management agrees with the finding and recommendation and plans to implement additional controls.

Finding: 2022-002 - Eligibility - Significant Deficiency in the Internal Control Over Compliance: SEE SCHEDULE OF FINDINGS AND QUESTION COSTS FOR CHART/TABLE - Criteria: 2021-2022 Federal Student Aid Handbook, volume 3, chapter7: Depending on individual circumstance, students may receive only need-based aid, non-need-based aid, or a combination of need-based and non-need-based aid. The total amount of need-based aid cannot exceed the student's financial need and the total amount of all aid cannot exceed the student's cost of attendance. - Condition/context: A sample of 48 federal aid recipient students were selected from system generated reports of 790 students who were disbursed federal student aid during the 2021-2022 academic year. The student's records were inspected. - Effect: An exception was noted whereby one student was awarded aid in excess of their cost of attendance which resulted in an over award of $5,550 of federal direct subsidized loans. - Cause: The student was over awarded due to a weakness in the University's manual packaging process. The standard packaging process is done automatically. When the packaging is performed automatically there are triggers in the process that prevent over awarding. In the case of this student, it was done manually, and those checks and balances were never activated, because of this there was not flag to stop the awarding. - Repeat finding: This is not a repeat finding. - Recommendation: We recommend the University amend procedures so in teh event that packaging is done manually, there are added reviews over the student's aid awarded. - View of responsible officials and planned corrective actions: We accept Moss Adams' recommendation and if a situation arises where we must manually package a student, the procedure will include an additional review by another individual, either the Director or a Counselor, to review the package for accuracy.

Finding: 2020-002 ? Reporting ? Significant Deficiency in Internal Control Over Compliance (See Section III - Federal Award Findings and Questioned Costs for table) Criteria: 18004(a)(1) of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Public Law 116?136, 134 Stat. 281 (March 27, 2020), to publicly post certain grant information on the University?s primary website no later than 30 days after receiving its award as part of the reporting requirements under Section 18004(e) of the CARES Act. Condition/context: The University received its initial allocation of the HEERF award on April 28, 2020 and made an initial post of the required grant information on its primary website on June 23, 2020 which was 46 days after the funding was received. Cause: At the onset of the award, management prioritized its focus on processing disbursements to students in need. Coordination of an individual responsible for gathering information required by the CARES Act and personnel that have access to post public information to the University?s website took longer than 30 days. Effect or potential effect: The initial public post was not made within required timeframe under the conditions of the grant. Identification of repeat finding: This not a repeat finding. Recommendation: We recommend that the University continue to review guidance provided by grant agreements and establish timetables and responsible parties to complete respective compliance requirements.

GSA_MIGRATION