Finding 2025-001 – Enrollment Reporting Federal Program: Student Financial Assistance Cluster Listing Number: 84.268 Federal Direct Loan 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. Condition and Context: It was identified that the University did not have effective internal controls over the review of student programs and campus level data changes submitted to NSLDS. Of the 60 students with enrollment changes we selected for testwork, we noted that there were 49 students whose campus or program level information was not submitted accurately to NSLDS. Specifically, for the 49 students we noted the following: • The campus level and program level enrollment status of 2 graduated students was reported incorrectly to NSLDS as Full-time (F) rather than Graduated (G), including the incorrect enrollment effective dates. • The campus level and program level enrollment status of 4 graduated students was reported incorrectly to NSLDS as Half-time (F) rather than Graduated (G), including the incorrect enrollment effective dates. • The campus level and program level enrollment status of 2 graduated students was reported incorrectly to NSLDS as Less than Half-time (L) rather than Graduated (G), including the incorrect enrollment effective dates. • The campus level and program level enrollment status of 10 graduated students was reported incorrectly to NSLDS as Withdrawal (W) rather than Graduated (G), including the incorrect enrollment effective dates for 8 of the 10 students. • The campus level and program level enrollment status of 1 graduated student was reported incorrectly to NSLDS as Half-time (H) and Withdrawal (W), respectively, rather than Graduated (G), including the incorrect enrollment effective dates. • The campus level and program level enrollment status of 5 graduate students was reported incorrectly to NSLDS as Full-time (F) and Withdrawal (W), respectively, rather than Graduated (G), including the incorrect enrollment effective dates. • The campus level and program level enrollment status of 1 graduate student was reported incorrectly to NSLDS as Full-time (F) and Record not found (Z), respectively, rather than Graduated (G), including the incorrect enrollment effective dates. • The campus level and program level enrollment status of 2 graduate students was reported incorrectly to NSLDS as Less than Half-time (L) and Record not found (Z), respectively, rather than Graduated (G), including the incorrect enrollment effective dates. • The campus level and program level enrollment status of 1 graduate student was reported incorrectly to NSLDS as Withdrawal (W) and Record not found (Z), respectively, rather than Graduated (G), including the incorrect effective dates. • The program level enrollment status of 6 graduate students was reported incorrectly to NSLDS as Record not found (Z) rather than Graduated (G), including the incorrect enrollment effective dates. • The program level enrollment status of 2 graduate students was reported incorrectly to NSLDS as Withdrawal (W) rather than Graduated (G), including the incorrect enrollment effective dates. • The campus level enrollment status of 1 graduate student was reported incorrectly to NSLDS as Withdrawal (W) rather than Graduated (G), including the incorrect enrollment effective dates. • The campus level enrollment status of 2 graduate students was reported incorrectly to NSLDS as Full-time (F) rather than Graduated (G), including the incorrect enrollment effective dates. • The program begin date of 1 graduated student was reported incorrectly to NSLDS. • The campus level and program level enrollment status of 2 active students was reported incorrectly to NSLDS as Full-time (F) rather than Active (A), including the incorrect enrollment effective dates. • The campus level and program level enrollment status of 1 active student was reported incorrectly to NSLDS as Record not found (Z) rather than Active (A), including the incorrect enrollment effective dates. • The campus level and program level enrollment status of 1 active student was reported incorrectly to NSLDS as Withdrawal (W) and Full-time (F), respectively, rather than Active (A), including the incorrect enrollment effective dates. • The campus level and program level enrollment effective dates of 1 active student were reported incorrectly to NSLDS. • The campus level and program level enrollment status of 1 less than half-time student was reported incorrectly to NSLDS as Withdrawal (W) rather than Less than Half-time (L), including the incorrect enrollment effective dates. • The campus level and program level enrollment status of 1 withdrawn student was reported incorrectly to NSLDS as Full-time (F) rather than Withdrawal (W), including the incorrect enrollment effective dates. • The campus level and program level enrollment status of 1 withdrawn student was reported incorrectly to NSLDS as Less than Half-time (L) rather than Withdrawal (W), including the incorrect enrollment effective dates. • The campus level and program level enrollment effective dates of 1 withdrawn student were reported incorrectly to NSLDS. In addition, of those 49 students, 24 students had enrollment status changes that were not reported to NSLDS within the required 60-day timeline. The delay in reporting the students’ enrollment status changes ranged from 4 days – 925 days. Possible Cause and Effect: The University’s internal control process failed in detecting that untimely and inaccurate information was reported to NSLDS. Isolated or Systemic: Systemic Questioned Costs: None noted Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding: Yes. A similar finding was identified in prior year for 9 students who had changes that were not submitted timely and 15 students whose campus or program level information was not submitted accurately to the NSLDS. Recommendation: We recommend that the University enhance its internal controls to ensure all information submitted 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: The University of Massachusetts Global concurs with this finding. The primary issues involved incorrect student status data reported at the Campus and Program level due to incorrect data parameters set up in the university’s reporting system which caused many of the student status changes to be omitted or incorrectly reported. Due to this reporting deficiency, the timely submission of the student status changes to the NSLDS within 60 days was also affected. The following summary indicates the actions that are in process to address these identified errors. Create and implement controls related to student Campus level data reporting that ensure the student status changes (i.e. change from full-time to graduated, withdrawn or half-time) are captured correctly and then reported accurately to the NSLDS. Create and implement controls related to student Program level data that ensure the student status changes (i.e. change from full-time to graduated, withdrawn or half-time) are captured correctly and then reported accurately to the NSLDS. Create and implement a control that ensures timely and accurate reporting to the NSLDS within 60 days of all student enrollment status changes at both the Campus and Program level. The Registrar will continue to work in conjunction with Information Technology and the UMG working group dedicated to this task to develop and test standalone reporting for both its Competency Based Education and Standard Aid Year populations based upon the specifications listed in the NSLDS Enrollment Reporting guide as follows: • Student current SSN • OPEID • CIP Code • CIP Year • Credential level • Published Program Length Measurement • Published Program Length • Weeks in Title IV Academic Year • Program Begin Date • Special Program Indicator • Program Enrollment Effective Date The University concurs and is working to address each of these reporting errors along with implementing these above mentioned controls prior to the end of the academic year 2025/2026.