University of Dallas

Criteria or specific requirement – Special Tests and Provisions – Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information. Condition – The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Questioned costs – None Context – Out of the population of 214 students with student attendance changes, a sample of 22 students was selected for testing. Our sampling method was not, and was not intended to be, statistically valid. There were 14 attributes tested for each student with at least one status change, which were as follows: Campus-Level Records 1. OPEID Number 2. Enrollment Effective Date 3. Enrollment Status 4. Certification Date Program-Level Records 5. OPEID 6. CIP Code 7. CIP Year 8. Credential Level 9. Published Program Length Measurement 10. Published Program Length 11. Program Begin Date 12. Program Enrollment Status 13. Program Enrollment Effective Date Other Records 14. Student changed his or her permanent address. The University did not report one student’s status timely, and the incorrect program length for Master’s programs was reported for two students. Effect – The University reported incorrect information or did not report the status changes timely. Cause – The University’s processes did not ensure status changes were reported timely and accurately. Identification as a repeat finding, if applicable – 2024-001 and 2023-002 Recommendation – The University should update its controls to ensure changes in students’ enrollment status are reported in a timely and accurate manner. Views of responsible officials, reason for recurrence, and planned corrective actions – The University will continue to improve upon Enrollment Reporting as well as continue with all of the changes previously identified and corrected. The University will ensure that the Received Date by NSLDS is within the 60 day compliance reporting requirement. With respect to the reporting of Program Lengths in error, the University took steps to update the processes associated with that activity subsequent to the issuance of the report containing the prior year Single Audit finding 2024-001. Upon consultation with the Office of the Provost and the appropriate Deans of the affected Colleges, the program length for the Master’s programs at the University was updated to two (2), for those programs between 30 and 36 credit hours in length; and three (3) academic years, for those whose minimum credit hours exceeds 36 credit hours, which will meet a reasonable progression to such degree. The Office of Registrar updated all such programs to reflect the decision for the University in November 2024. The students noted in the 2025-001 finding ceased to be active prior to the updated process’ implementation and were excluded from the reporting population. All activity contained in the sample selection for changes after the implementation date were handled in accordance with the regulations. One of those students reenrolled and the Program Length was updated to correctly reflect the student’s new program. The University will continue to monitor this area for any future discrepancies.

Criteria or specific requirement – Special Tests and Provisions – Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information. Condition – The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Questioned costs – None Context – Out of the population of 245 students with student attendance changes a sample of 25 students was selected for testing. Our sampling method was not, and was not intended to be, statistically valid. There were 14 attributes tested for each student with at least one status change, which were as follows: Campus-Level records: 1. OPEID Number 2. Enrollment Effective Date 3. Enrollment Status 4. Certification Date Program-Level records 5. OPEID 6. CIP Code 7. CIP Year 8. Credential Level 9. Published Program Length Measurement 10. Published Program Length 11. Program Begin Date 12. Program Enrollment Status 13. Program Enrollment Effective Date Other Records 14. Student changed his or her permanent address. The University did not report 5 student’s statuses timely, the University reported the incorrect status change date for 12 students, the incorrect program length for Master’s programs was reported for 6 students and 2 students had never been reported. Effect – The University did not report the status changes timely. Cause – The University’s processes did not ensure status changes were reported timely and accurately. Identification as a repeat finding, if applicable – 2023-002 and 2022-001 Recommendation – The University should update their controls to ensure changes in students’ enrollment status are reported in a timely and accurate manner. Views of responsible officials, reason for recurrence and planned corrective actions - Upon reflection of the term end date and subsequently the status change date, the Office of Registrar updated the term end date to the last date of educationally related activities more widely known as the last date of the final examinations for each relevant term. Upon consultation with the Office of the Provost and the appropriate Deans of the affected Colleges, the program length for the Master’s programs at the University will be updated to two (2), for those programs between 30 and 36 credit hours in length; and three (3) academic years, for those whose minimum credit hours exceeds 36 credit hours, which will meet a reasonable progression to such degree. The Office of Registrar will update all such programs for the University. The Office of Registrar and the Office of Financial Aid explored reporting enrollment directly to the National Student Loan Data System and while such was initially promising, the Office of Financial Aid determined that such activity would be disruptive to the business practices of the University given the work needed for the Financial Value Transparency and Gainful Employment reporting in which the National Student Loan Clearinghouse (NSLC) has served as an invaluable partner. This option may still be explored further if additional resources become available. The Office of the Registrar will split the graduation file sent to our third-party servicer, NSLC, so that the students from the College of Business who are on a different calendar may be reported to NSLDS sooner which should assist in reporting those students on an earlier timeframe. The Office of Registrar will begin rolling grades the week after Add/Drop on a weekly basis of each term to reduce the timeframe for students who have withdrawn from a course to be reported to NSLDS. The Office of the Registrar will update the grading policy in Ellucian Banner to align any changes in grading policy for students who fail to attend course. The Office of Financial Aid will work with the Student Registrar to ensure such reporting is accurate by reviewing the set-up of such data points as Enrollment Effective Date, Enrollment Status, Term Begin Date, Term End Date and Award Completion Date. Implementation: The responsible parties include the Office of Registrar, the Office of Financial Aid along with the staff of Information Technology. Some updates to the status change dates or term end dates have already been recorded. Updates to the program length for Master’s programs will be made by November 2024. Implementation of internal Office of Registrar functions to assist in reporting for changes in grades and enrollment levels should be in place by November 2024. Any change in the processing of the Graduated file from NSLC should be in place by the anticipated date of implementation of February 2025. Full utilization of all changes by close of the Spring 2025 term.

Criteria or specific requirement – Special Tests and Provisions – Gramm-Leach-Bailey Act (16 CFR 314) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. The Federal Trade Commission considers Title IV eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bailey Act (GLBA) because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Institutions agree to comply with GLBA in their Program Participation Agreement with ED. Institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the Federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)).

Condition – The University must have a written information security program that addresses the required minimum seven elements.

Questioned costs – $0

Context – The University does not have a written information security program that addresses the required elements. The University has designated their Chief Information Officer as the qualified individual responsible for implementing and monitoring their information security program. They have started addressing the additional required elements, including reviewing access controls, implementing multi-factor authentication for students, disposing of student information securely, and performing annual penetration testing, reviewing the log for unauthorized access, implementing multi-factor authentication for staff and faculty with access to student information, implementing policies and procedures to ensure that personnel are able to enact the information security program and encrypting all information, on the institution’s system and when it’s in transit.

Effect – The University did not implement the revised GLBA regulations by the required date. Cause – The University’s controls did not ensure the revised GLBA regulations were implemented by the required date. Identification of a repeat finding, if applicable – N/A Recommendation – The University should complete the written information security program and ensure the additional required GLBA elements are included. Views of responsible officials and planned corrective accounts – On July 19, 2024, the University of Dallas received a notification from [the auditor] concerning several outstanding items from the latest Gramm-Leach-Bliley Act (GLBA) requirements in the compliance audit. The Chief Information Security Officer (CISO), IT security personnel and Chief Information Officer (CIO) compiled the necessary information to provide an accurate status update on the remediation efforts for each item. See corrective action plan for the current remediation status as of September 5, 2024.

Criteria or specific requirement – Special Tests and Provisions – Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (34 CFR 668.164(e) and (f). Condition – The University did not provide a URL for the contract to the Department of Education for publication in the Cash Management Contracts Database. Questioned Costs - $0 Context – The University entered into an agreement with a servicer to deliver Title IV credit balances in 2017 but did not provide the URL to the Department of Education. Effect – The University was not in compliance with the requirements noted above. Cause – The University’s internal controls did not ensure the required information was provided to the Department of Education. Identification of repeat finding, if applicable – N/A Views of responsible officials and planned corrective actions – The University has reviewed the requirements in 34 CFR 668.164(e) and (f) and the required information was submitted to the Department of Education on September 13, 2024. It should be noted that the information was available to the student’s on the University’s website at all times required.

Criteria or specific requirement – Eligibility – Pell must be awarded to all students who qualify. (34 CFR 690.61 through 690.66, and 690.75 through 690.76; Pell Grant Payment Schedules; General Provisions regulations, part 668, subpart K, and FSA Handbook). Condition – A student was not awarded a Pell Grant when the student was eligible. Questioned costs - $3,447 – Assistance Listing Number 84.063 Context –Out of the population of 1,170 students who received federal financial aid, a sample of 25 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. One student was eligible for a Pell Grant after subsequently meeting the University’s satisfactory academic policy (SAP) due to a grade change after the initial calculation for awards. The University did not recognize that this student was eligible and did not award a Pell Grant. Effect – A students who was eligible for a Pell Grant was not awarded. Cause – The University’s controls did not reassess students’ eligibility after changes in SAP. Identification as a repeat finding, if applicable – N/A Recommendation – The University should update their controls to ensure students with changes to eligibility status are considered for federal aid. Views of responsible officials and planned corrective actions – The Office of Financial Aid will work with the Student Registrar and staff to develop a communication track to recognize and respond to grade changes to perform the most accurate assessment of the student's financial aid.

Criteria or specific requirement - Special Tests and Provisions – Enrollment Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information. Condition - The University’s processes did not ensure timely and accurate student status reporting to National Student Loan Data System (NSLDS). Questioned costs - None Context - Out of the population of 415 students with student attendance changes a sample of 25 students was selected for testing. Our sampling method was not, and was not intended to be, statistically valid. There were 14 attributes tested for each student with at least one status change, which were as follows: Campus-Level records: 1. OPEID Number 2. Enrollment Effective Date 3. Enrollment Status 4. Certification Date Program-Level records 5. OPEID 6. CIP Code 7. CIP Year 8. Credential Level 9. Published Program Length Measurement 10. Published Program Length 11. Program Begin Date 12. Program Enrollment Status 13. Program Enrollment Effective Date Other Records 14. Student changed his or her permanent address. The University reported incorrect dates for student status changes and did not ensure timely submission of reports to NSLDS for 14 students and the incorrect effective date was reported for 19 students. Effect - The University did not report the status changes timely. Cause - The University’s processes did not ensure status changes were reported timely and accurately. Identification as a repeat finding, if applicable – 2022-001 Recommendation - The University should update their controls to ensure changes in students’ enrollment status are reported in a timely and accurate manner. Views of responsible officials, reason for recurrence and planned corrective actions - Upon agreement with the Student Registrar the University of Dallas will begin dual reporting to both the National Student Loan Clearinghouse (NSLC) and the National Student Loan Data System (NSLDS) every thirty days. The Student Registrar will work with information technology to set-up and run the SFRSSCR from the Banner system as well as run the same reports for the NSLC on the same day and approximate time to ensure that timely reporting is completed for the University of Dallas. The Financial Aid Office will in turn run the appropriate reports to ensure that such reporting is successful. The Financial Aid Office will either request access for the Student Registrar to submit such reports to the NSLDS or, if necessary, perform this task on behalf of the Student Registrar. The Financial Aid Office will work with the Student Registrar to ensure such reporting is accurate by reviewing such data points as Enrollment Effective Date, Enrollment Status, Term Begin Date, Term End Date and Award Completion Date.