Finding 2025-001 Special Tests and Provisions – NSLDS Reporting Compliance and Internal Control (Significant Deficiency) U.S. Department of Education – Student Financial Assistance Cluster Federal Direct Student Loans (Federal Assistance Listing #84.268) Federal Award Number: P268K256103 Federal Award Year: 2024-2025 Criteria or Specific Requirement Institutions are required to report enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan (“FFEL”) programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). 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 website which the financial aid administrator can access for the auditor. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for accurately reporting all Program-Level Record data elements. The Program-Level Record data elements that the U.S. Department of Education considers to be high risk include, but are not limited to: • Published program length; • Program begin date; • Program enrollment status; • Program enrollment effective date; and, • Classification of Instructional Program (“CIP”) code. Published Program Length should be reported based on the definition of “normal time” to completion in the regulations at 34 CFR 668.41(a), as follows: • If the school has published, in its catalog, on its website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school has published. Note: For gainful employment programs, the school must have published the program’s length in weeks, months, or years on the school’s website. • If the school has not published a program length and the program is an associate or bachelor’s degree program, the program length to be reported should be two years (associate) or four years (bachelor), respectively, unless the academic design of the program makes it longer or shorter than typical. • For all other programs for which the school has not published a program length, the program length is based on the school’s determination of how long, in weeks, months, or years, the program is designed for a full-time student to complete. Context and Condition For a non-statistical sample of 22 students, the published program length reported for 20 students on their NSLDS Program-Level records did not comply with the requirements in the NSLDS Enrollment Reporting Guide. For these 20 students, all of whom were enrolled in the School’s full-time Juris Doctor (J.D.) program, the School reported a published program length of four years instead of three years, which is the program length for the full-time J.D. program as published on the School’s website. Cause As a general practice, the School reported a program length of four years for all students, instead of reporting the actual length of the program each student was enrolled in. Effect The published program length for twenty students was not accurately reported to the NSLDS. Questioned Costs None noted. Identification as a Repeat Finding This is not a repeat finding. Recommendation The School should implement procedures to ensure that students’ program-level enrollment reporting data, including the published program length, are reported to the NSLDS accurately and in accordance with the requirements in the NSLDS Enrollment Guide. Views of Responsible Officials See Corrective Action Plan.