Finding 2025-001 – Enrollment Reporting Federal Program: Student Financial Assistance Cluster Listing Number: 84.268 Federal Direct Loans Program Federal Agency: Department of Education Award Year: July 1, 2024 – June 30, 2025 Criteria: According to the Code of Federal Regulations 685.309, enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. An institution must notify the Secretary of Education if it discovers a loan under Title IV of the Act was made to or on behalf of a student who was enrolled on at least a half-time basis or failed to enroll on a least a half-time basis for the period for which the loan was intended. The Department of Education lists several certification methods for enrollment reporting, including certifying directly through the National Student Loan Data System (NSLDS) website, or certifying through NSLDS’s batch enrollment reporting process. Additionally, there are two categories of enrollment information within NSLDS, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Further, per the NSLDS Enrollment Reporting Guide, as with any school/servicer arrangement for administration of Title IV programs, if the institution uses an Enrollment Reporting Servicer, the institution still has the primary responsibility in submitting timely, accurate, and complete responses to Enrollment Reporting Roster files, and for reporting any changes in student enrollment status in a timely manner. Institutions must also ensure to maintain proper documentation in accordance with 34 CFR 682.610(c) and 34 CFR 685.300(b). Condition and Context: The University did not have effective internal controls over the review and timely submission of student program and campus level data changes submitted to NSLDS. Of the 60 students with enrollment changes we selected for testwork, we noted that there were 9 students whose campus or program level information were not submitted accurately or timely to NSLDS. Specifically, for the 60 students, we noted the following: • The campus enrollment status for one graduated student was reported by the University as graduated to the National Student Clearinghouse (NSC); however, NSC reported the student status as withdrawal to NSLDS, and the University did not subsequently correct and report the student as graduated. • The program-level enrollment status for one graduated student was reported by the University as graduated to NSC, however the University’sStudent Information System (SIS) subsequently reported the student as active full-time on the Spring Early Registration file, which overrode the graduated status and triggered a withdrawal enrollment status. NSC reported the student status as withdrawal to NSLDS, and the University did not subsequently correct and report the student as graduated. • The campus-level enrollment statuses for two graduated students were reported by the University as graduated to NSC; however, the University’s SIS subsequently reported the students as active full-time on the Spring Early Registration file, which overrode the graduated statuses and triggered full-time enrollment statuses. NSC reported the students’ statuses as full-time to NSLDS, and the University did not subsequently correct and report the students as graduated. Additionally, the enrollment status changes were not reported within the 60-day requirement. • The campus-level enrollment effective date for one full-time student was not reported accurately by the University to NSLDS. • The campus-level enrollment effective date for one withdrawn student was not reported accurately by the University to NSLDS and was not reported within the 60-day requirement. • The program-level enrollment status for one full-time student was reported by the University to NSLDS as withdrawal rather than full-time and was not reported within the 60-day requirement. Additionally, the campus-level enrollment effective date was not reported accurately to NSLDS. • The campus-level and program-level effective dates for one full-time student was not reported accurately by the University to NSLDS and was not reported within the 60-day requirement. • The campus-level and program-level enrollment status of one half-time student was reported by the University to NSLDS as full-time and withdrawal, respectively, rather than half-time, and the enrollment effective dates were not reported accurately to NSLDS. Further, we noted that management's review control was not operating at a level of precision to ensure the students' status changes were reported accurately to NSLDS and within the 60-day requirement. Specifically, we noted the following: • Management did not properly review and correct the enrollment status change reported by NSC to NSLDS. • Management did not properly review and correct the enrollment status changes overridden by the SIS and reported to NSLDS. • Management did not properly review the campus-level and program-level enrollment effective dates reported to NSLDS. • Management did not properly review the campus-level and program-level enrollment statuses for withdrawn, full-time, and half-time students reported to NSLDS. • Management did not review the enrollment status changes in a timely manner to submit the changes to NSLDS within the 60-day requirement. Possible Cause and Effect: The University’s internal control process failed in detecting that untimely and inaccurate information was reported by the University and NSC to NSLDS. Questioned Costs: None noted. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: Yes. Recommendation: We recommend that the University enhances its internal controls to ensure all information submitted by the University and NSC to NSLDS is reviewed for accuracy on a timely basis, and to ensure all student status changes are monitored and submitted to NSLDS within 60 days of the student’s status change. View of Responsible Officials: University of the Pacific concurs with this finding. The University utilizes the services of National Student Clearinghouse to report student status data to the NSLDS. For the year ended June 30, 2025, nine students were identified whose records did not match at the program and campus levels and remained reported as enrolled. The Registrar's review of NSC and NSLDS transmission files identified a sequencing issue in which campus-level reporting overrode previously submitted program-level enrollment changes. The Registrar is reviewing all potentially impacted records and coordinating with NSC to update and confirm accurate reporting in NSLDS. In addition, the timing of monthly enrollment and degree submissions has been restructured to prevent overlapping transmissions and ensure reporting accuracy and compliance.