California Lutheran University and AffiliateHigher Education

FINDING 2022-001 - Special Tests and Provisions ? Enrollment Reporting ? Significant Deficiency in Internal Control over Compliance "See Schedule of Findings and Questioned Costs for chart/table" 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 when the enrollment status or permanent address of a student that has received federal aid changes. The 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. The 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 and permanent address changes 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 or their permeant address has changed (34 CFR section 685.309). Condition/Context: We selected a sample of students identified by the University as having received some Federal assistance and who either withdrew from the University, graduated from the University, or had a change to their permanent address during the year ended May 31, 2022. Our sample consisted of 15 students out of a population of 75 that were identified as withdrawn during the year; a sample of 19 students out of a population of approximately 172 that were identified as graduates; and a sample of 15 students out of a population of 145 that had permanent address changes. We then compared the enrollment information and withdrawal or graduation date per the University?s records to the information reported to NSLDS. We believe this to be a representative sample of the population. We noted an exception with one student who had a permanent address change that was not reported within the required time frame. Questioned costs: No questioned costs were identified as part of this finding. Effect: Permanent addresses are used by ED for ensuring that repayment information and other communications from ED are quickly accessible to a student. Therefore, this deficiency in reporting permanent address changes could result in delays in receiving this information. Cause: Management appropriately and timely captured the status changes within the University?s student account system; however, when extracting the changes to submit to the third-party processor the report showed an error which was not detected within the 60-day timeframe. Repeat finding: This is not a repeat finding. Recommendation: We recommend that the University develop additional procedures to monitor the accuracy of information provided by its third-party servicer on behalf of the University 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 and that permanent address changes were processed. Each institution has access to correct information directly within NSLDS at any time. Views of responsible officials and planned corrective actions: The University concurs with the exception of one student for whom a permanent address change was not reported within the required timeframe. After investigation, it was determined that the selection criteria for data extraction required adjustment to ensure all students were included in the data extraction and reporting process. Maria Kohnke, Associate Vice President of Academic Services & Registrar, modified the selection criteria for the data exaction process in the Colleague system to ensure all permanent address changes are extracted and submitted for all students as required. The Associate Registrar is responsible for reviewing and modifying the selection criteria for the data extraction process at the beginning of each year and at each change in criteria. The criterion will be reviewed and approved by the Associate Vice President of Academic Services & Registrar when changes are made.

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