Name of Responsible Individual: Jason Byrd, University Registrar
Corrective Action: Liberty University acknowledges that its FY24 single audit identified one instances where students’ enrollment reporting was not updated in a timely manner in accordance with U.S. Department of Education (ED) requi...
Name of Responsible Individual: Jason Byrd, University Registrar
Corrective Action: Liberty University acknowledges that its FY24 single audit identified one instances where students’ enrollment reporting was not updated in a timely manner in accordance with U.S. Department of Education (ED) requirements. Additionally, Liberty acknowledges that there were numerous instances where Clearinghouse error reports identified students with repeat errors which were not corrected within the required timeframe. Liberty has invested significant effort into ensuring its enrollment reporting process is handled compliantly and within alignment with ED’s best practices. Liberty’s Registrar’s Office created a new Director of Clearinghouse Reporting position, which was filled in May 2024, to specifically address any enrollment reporting deficiencies. This new position is responsible for monitoring Clearinghouse feeds and any associated error reports and works closely with Liberty’s Financial Aid and Information Technology (ADS) offices to ensure enrollment reporting compliance.
Liberty has continued the work of developing a more comprehensive quality control (QC) process. The QC process utilizes National Student Loan Data System (NSLDS) reporting and compares it to Banner, Liberty’s system of record, to identify students who may not have been accurately reported for a variety of reasons. This process relies on the NSLDS Enrollment History Report -SCHHS1, which is a very large and somewhat unstable report due to the volume of enrollment reporting that Liberty completes. Because of the complexities of this report, and the many changes that occurred with NSDLS updates to reporting, Liberty had to file numerous inquiries with ED to be able to run a functioning report, including an NSLDS ticket submitted on September 20, 2022, (Case # 220920-000436). The report was first successfully run in January 2024, though it took several months for Liberty to build QC reports internally that could leverage the report results. Liberty seeks to run the report at least once per month, though failures at NSLDS are unfortunately somewhat common and require escalation to ED for resolution.
NSLDS – SCHHS1 Report:
Once downloaded, this report is uploaded into Liberty’s system and is utilized internally for four additional QC reports which compare the NSLDS output to Banner. It should be noted that the QC reports are primarily useful for identifying common and repeat issues that require further research and are not fine-tuned enough to identify all individual instances of missing or incomplete records.
Liberty Internal QC Reporting:
Below are multiple screenshots of the four additional QC reports that Liberty has created.
The Graduated Dates Prior to Term End report compares graduation dates by term to identify NSLDS graduation dates that appear to not match Banner’s graduation date in SHDGMR.
The NSLDS MisMatches report generates an Excel file showing instances where it believes a student’s enrollment in Banner does not appear to match their reported enrollment in NSLDS.
The NSLDS No Banner SSN report pulls students who appear in NSLDS’ enrollment file but do not appear to have a corresponding student ID record in Liberty’s system.
The NSLDS Record Missing report pulls Liberty University students who appear to be missing a corresponding record in NSLDS.
With all of these reports, there may be a legitimate reason for the discrepancy between Liberty’s Banner data and the NSLDS system, which causes the reports to generate a number of false positives, however, the reports have been helpful to identify more common/persistent errors and provides an additional layer of QC to ensure that Liberty’s enrollment files are as accurate as possible. Liberty is also engaging in a review of its Clearinghouse file generation process to ensure that student’s enrollment changes, particularly for program level records, are reported in a timely manner.
Accountability Meetings
Finally, in addition to running regular QC reports and hiring a dedicated Director of Clearinghouse reporting position, Liberty began holding a series of bi-weekly “Enrollment Reporting Check-In” meetings with key stakeholders from University Compliance, Financial Aid, Registrar, and IT/ADS in February 2024, which are dedicated to discussing current and upcoming enrollment reporting submissions and errors, trends seen with SSCR errors, and brainstorming ways to ensure ongoing compliance.
While improvement efforts continue to be underway, Liberty believes these efforts are starting to bear fruit as evidenced by a 98.7% reduction in the number of repeat errors in the 2024 calendar year compared to total reporting period.
Moving forward Liberty will continue to hold monthly meetings with key stakeholders to discuss any errors being pulled and ensure best practices are implemented to ensure ongoing accuracy. The University’s Registrar’s Office will also continue to review the QC reports in a timely manner, as well as evaluate the current processes for withdrawal/graduated student files. Liberty will continue to review and implement updates as necessary to maintain enrollment reporting compliance and believes these new processes will allow us to be compliant in subsequent years.
Anticipated Completion Date: April 2025