Audit 393612

Finding No. 2025-001 Special Tests and Provisions – NSLDS Reporting U.S. Department of Education: Student Financial Assistance Cluster: Federal Pell Grant (ALN 84.063) Federal Grant Number: P063P241851 Statistically Valid Sample: No and it was intended to be. Prior Year Finding: Not a repeat finding. Finding Type: Significant Deficiency and Noncompliance Criteria: Institutions are required to report enrollment information under the Pell Grant and the Direct Loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting all Campus-Level Record data elements. ED considers the following data elements to be high risk: • OPEID Number, Enrollment Effective Date, Enrollment Status, Certification Date Institutions are responsible for accurately reporting all Program-Level Record data elements. ED considers the following data elements to be high risk: • OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Effective Date Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309: Perkins 34 CFR 674.19(f)). Additionally, in accordance with 2 CFR 200.303, the University shall maintain internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program. Condition and Context: The University utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for transmission of its enrollment reporting changes including, but not limited to withdrawals and graduate status to the NSLDS. The University receives the Enrollment Reporting Roster and makes necessary updates for changes in student status. A final file is then sent to the Clearinghouse who transmits information or corrections to NSLDS. For 1 student in our sample of 40, the effective status of graduation was not accurately reported to NSLDS within 60 days of the status change. The status change was submitted and certified by NSLDS 228 days late. This student received an error code of 253 or 290, which represents an error in the student’s social security number (SSN). Upon further review, the University identified 10 other students that had this same error code during fiscal year 2025. One of these students had a status change which was not reported to NSLDS timely, and it was submitted and certified by NSLDS 494 days late. Cause: This error was caused by an incorrect assumption in the Registrar’s procedures that students who returned this error from the Clearinghouse were non-Title IV aid students. While the Registrar worked to rectify these errors with the Clearinghouse, the Registrar’s Office did not update the student’s status in NSLDS independently because management believed these students did not receive Title IV aid. Effect: Student status changes not reported in a timely or accurate manner may cause the student to not enter repayment status for Federal Direct Student Loans on a timely basis. A change in status for a student receiving a Pell Grant will impact the amount they are eligible to receive Question Costs: None. Recommendation: We recommend that management incorporate procedures in their process to review the error reports received from the Clearinghouse specifically for this error code, which should include the determination of whether these students had received Title IV aid. View of Responsible Officials: Management agrees with the finding. Students on the reject detail from the Clearinghouse enrollment submission who receive a 253 or 290 error will be reviewed using a Financial Aid provided report to determine if any have been awarded aid. Financial Aid will provide the FAFSA support to correct the Clearinghouse error for students who have received aid. We will also manually report those student statuses to the NSLDS while the errors are being corrected by the Clearinghouse for anyone receiving aid so status changes are reported timely. For students that do not have FAFSA information with Financial Aid, we will contact those students directly for documentation to correct or affirm their SSN information to try and resolve any future 253 or 290 errors.