Charles R. Drew University of Medicine and ScienceHigher Education

Finding: 2025-001 – Special Tests and Provisions – Return of Title IV Funding (R2T4) and Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (See Finding 2025-001 for included table) Criteria: When a recipient of Title IV loan assistance withdraws from the University during a payment period or period of enrollment in which the recipient began attendance, the University must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. The regulations (34 CFR 668.22(j)(1)) provide that an institution must return the amount of title IV funds for which it is responsible under paragraph as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. In addition, the National Student Loan Data System (NSLDS) is the Department of Education’s centralized database for students’ enrollment information. It is the University’s responsibility to update this information timely and accurately when the enrollment status of a student that has received federal loans changes. Unless the University expects to complete its next roster file within 60 days, the University 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: We selected a sample of 12 students out of a population of 41 that were identified by the University as having received some federal assistance and withdrew from the University during the year under audit. We believe this to be a representative sample of the population. Effect or potential effect: We found exception with two students whose title IV funds were returned more than 100 days after it was determined that the student had withdrew and whose status of withdrawal was communicated to NSLDS. Cause: Academic departments who approved a leave of absence or dismissal resulting in a change to enrollment was not timely reported to the University registrar and financial aid office resulting in respective delays to the return of title IV funds and enrollment status updates. Recommendation: We recommend that the University provide more training and guidance on the importance of timely communication of changes in enrollment status to the registrar and financial aid to ensure compliance with these reporting requirements. Repeat finding: Not a repeat finding. Views of responsible officials: Management agrees with the finding. A corrective action plan has been created by management.

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 ? Direct Loan, 34 CFR section 685.309(b)(2)(i): An institution is required to notify the Department of Education within 30 to 60 days (depending on the method of communication) if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who enrolled at that school but has ceased to be enrolled on at least a half-time basis. Condition/Context ? A sample of 34 federal aid recipient students were selected from system generated reports of 422 students who graduated, withdrew, or dropped during the 2021-2022 academic year. The enrollment information and withdrawal, address change, or graduation date per the University?s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. We also obtained the SCHER1 report and reviewed the days elapsing between when records were distributed to the University and when responses were provided. A total of nine student status changes were not reported to the NSLDS within the required timeframe. One monthly distribution was not responded to within the 15 day timeframe. Effect ? The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by Department of Education, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Cause ? Starting in 2022, the University contracted with a third-party intermediary to transmit enrollment information to NSLDS. Prior to that, records were updated either manually or through a batch update process. Management?s existing processes did not identify and report the student status changes within the required timeframe. Repeat Finding ? This is not a repeat finding. Recommendation ? We recommend the University revise its policies to establish clear roles and responsibilities and processes in which to report student status changes to the third-party intermediary. We also recommend that management implement controls to ensure reported changes were ultimately timely and correctly reported to the NSLDS. Views of Responsible Officials and Planned Corrective Actions ? The University will update monthly reporting to National Student Clearinghouse when responding to NSLDS roster files rather than every other month. Additionally, the department has revised paperwork for graduating students to ensure status are processed in a timely manner by the Registrar.

FINDING 2019-001 ? Special Tests and Provisions ? Enrollment Reporting ? Significant Deficiency in Internal Controls. See Schedule of Findings and Questioned Costs for chart/table. Criteria: The National Student Loan Data System (?NSLDS?) is the U.S Department of Education?s (?ED?s?) centralized database for students? enrollment information. In accordance with the NSLDS Enrollment Reporting Guidelines (?Guide?), published by ED, the timeliness of reporting is important to ensure that students receive their entitled deferment benefits and it provides Congress with necessary enrollment and graduation rates of grant and loan recipients. It is the University?s responsibility to update this information. The University determines how often it receives the Enrollment Reporting roster file with the default set at every 2 months. Schools must report enrollment changes within 30 days; however, if a roster file is expected within 60 days, the school may provide the updated data on that roster file (34 CFR section 685.309). Condition/Context: In testing individual student status changes, we selected a sample of 22 students who had received student financial assistance and had withdrawn or graduated from the University during the 2018-19 fiscal year as identified by internal records. We compared the enrollment information and withdrawal or graduation date per the University?s records to the information reported to NSLDS. We noted the status changes for 2 graduated students and 2 withdrawn students were not reported to NSLDS timely. In discussing these exceptions with the Registrar, we determined this to be isolated instances rather than a systematic problem. Cause: The University does not utilize batch reporting when responding to NSLDS roster files. All status changes are reported manually through the NSLDS website. In the case of these 4 exceptions, there was a delay in manual processing of web updates within the Registrar?s office. 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. Recommendation: We recommend the University utilize batch reporting when responding to NSLDS roster files. Additionally, we recommend the University implement new procedures to ensure paperwork for all graduated and withdrawn students is processed timely by the Registrar. Views of responsible officials and planned corrective actions: Management is developing a plan to evaluate inclusion of batch reporting in addition to adopting more formal processes and reminders to ensure all documentation is completed timely and there is formal tracking of status changes of the students.

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