Corrective Action Plans

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· For thirteen (13) students, the College did not report the students' withdrawal status until approximately eleven months after the student withdrew; additionally, for each of these students, the withdrawal date documented in the college's student records did not agree with the withdrawal dates doc...
· For thirteen (13) students, the College did not report the students' withdrawal status until approximately eleven months after the student withdrew; additionally, for each of these students, the withdrawal date documented in the college's student records did not agree with the withdrawal dates documented in the NSLDS system.
· For two (2) students who both attended and withdrew from the College in the spring 2025 semester, the NSLDS system showed a withdrawn status effective in December 2024 that was reported to NSLDS ten months later in October 2025.
· For two (2) students who both attended and withdrew from the College in the spring 2025 semester, the NSLDS system showed a withdrawn status effective in December 2024 that was reported to NSLDS ten months later in October 2025.
· For one (1) student who attended and withdrew from the College in February 2025, the NSLDS system did not have a withdrawal record. The most recent record shown was received in October 2025 and it shows a status of "L — Less than Half-time" effective in January 2025.
· For one (1) student who attended and withdrew from the College in February 2025, the NSLDS system did not have a withdrawal record. The most recent record shown was received in October 2025 and it shows a status of "L — Less than Half-time" effective in January 2025.
· For one (1) student who attended and withdrew from the College in the spring 2025 semester, the most recent records in the NSLDS system were from 2017, with no status to show enrollment or withdrawal from the College in 2024-2025.
· For one (1) student who attended and withdrew from the College in the spring 2025 semester, the most recent records in the NSLDS system were from 2017, with no status to show enrollment or withdrawal from the College in 2024-2025.
· For one (1) student who attended and withdrew from the College in the spring 2025 semester, the NSLDS enrollment details show a status of '2— No Record Found."
· For one (1) student who attended and withdrew from the College in the spring 2025 semester, the NSLDS enrollment details show a status of '2— No Record Found."
Deficiencies noted above were discovered in a review of 25 complete student withdrawals during the respective semester. Considering the high percentage and similarity in deficiencies noted in the sample, the issues noted appear to be pervasive, leading to the possibility that there may be issues not...
Deficiencies noted above were discovered in a review of 25 complete student withdrawals during the respective semester. Considering the high percentage and similarity in deficiencies noted in the sample, the issues noted appear to be pervasive, leading to the possibility that there may be issues noted in a greater number of student records, related to changes in enrollment status, for the college's whole student population.
Questioned Costs: None
Questioned Costs: None
Cause: The majority of the deficiencies appear to be due to delays in report processing incurred during the migration to a new student information system.
Cause: The majority of the deficiencies appear to be due to delays in report processing incurred during the migration to a new student information system.
Effect: Noncompliance with federal compliance requirements and errors that may affect determinations that guarantors, lenders, and servicers of student loans make related to in-school status, deferments, grace periods, and repayment schedules.
Effect: Noncompliance with federal compliance requirements and errors that may affect determinations that guarantors, lenders, and servicers of student loans make related to in-school status, deferments, grace periods, and repayment schedules.
Recommendation: The College should ensure all pertinent staff are sufficiently trained and knowledgeable on the requirements of the Enrollment Reporting requirements. Additionally, the College should revise current or implement new policies and procedures to strengthen its controls to ensure that al...
Recommendation: The College should ensure all pertinent staff are sufficiently trained and knowledgeable on the requirements of the Enrollment Reporting requirements. Additionally, the College should revise current or implement new policies and procedures to strengthen its controls to ensure that all status changes are reported accurately and in a timely manner to NSLDS.
Planned Corrective Action Responsible Official:
Planned Corrective Action Responsible Official:
To correct the issue and prevent recurrence, the College Registrar's Office is taking the following actions:
To correct the issue and prevent recurrence, the College Registrar's Office is taking the following actions:
1. Standardize data and dates used for reporting.
1. Standardize data and dates used for reporting.
The Registrar's Office will rely solely on the official enrollment and withdrawal status fields and dates recorded in Banner as the source for all enrollment reporting to the National Student Clearinghouse (NSC) and subsequently NSLDS. Internal lists, such as graduation lists or ad hoc reports, will...
The Registrar's Office will rely solely on the official enrollment and withdrawal status fields and dates recorded in Banner as the source for all enrollment reporting to the National Student Clearinghouse (NSC) and subsequently NSLDS. Internal lists, such as graduation lists or ad hoc reports, will no longer serve as the primary source for effective dates. For students identified in the audit sample, the registrar will review and correct NSLDS records to ensure that status codes and effective dates align with the official institutional records.
2. Tighten the roster submission and response schedule.
2. Tighten the roster submission and response schedule.
The college will ensure that roster files received from NSLDS (via NSC) are reviewed and certified in accordance with federal requirements no less frequently than every 60 days and that responses are transmitted within 15 days of receipt. Internally, the Registrar's Office will work on a more freque...
The college will ensure that roster files received from NSLDS (via NSC) are reviewed and certified in accordance with federal requirements no less frequently than every 60 days and that responses are transmitted within 15 days of receipt. Internally, the Registrar's Office will work on a more frequent submission rhythm during active terms (e.g., mid-term and end-of-term cycles) to avoid delays like those noted in the finding.
3. Automate and streamline withdrawal/status processing.
3. Automate and streamline withdrawal/status processing.
In coordination with Information Technology, the Registrar's Office is refining Banner SaaS workflows so that withdrawals and other status changes (e.g., reductions to less than half­time) are consistently captured in the system and reflected in the next enrollment reporting file, without manual int...
In coordination with Information Technology, the Registrar's Office is refining Banner SaaS workflows so that withdrawals and other status changes (e.g., reductions to less than half­time) are consistently captured in the system and reflected in the next enrollment reporting file, without manual intervention where possible. This includes validating that students who attend and withdraw in the same term are correctly reflected as withdrawn in NSLDS, rather than remaining in a prior status.
4. Retrospective review and clean-up of recent terms.
4. Retrospective review and clean-up of recent terms.
The Interim Registrar will conduct a targeted review of enrollment records for the periods impacted by the system transition (including FY 2024-2025), comparing Banner to NSC/NSLDS data. Any discrepancies (missing withdrawals, incorrect dates, "L-Less than Half-time" where a withdrawal occurred, "Z-...
The Interim Registrar will conduct a targeted review of enrollment records for the periods impacted by the system transition (including FY 2024-2025), comparing Banner to NSC/NSLDS data. Any discrepancies (missing withdrawals, incorrect dates, "L-Less than Half-time" where a withdrawal occurred, "Z-No Record Found," or outdated records) will be corrected through updated files and/or NSLDS Enrollment Maintenance.
5. Written procedures, staff training, and ongoing monitoring.
5. Written procedures, staff training, and ongoing monitoring.
The College is updating its written procedures for Enrollment Reporting to clearly document:
The College is updating its written procedures for Enrollment Reporting to clearly document:
o The Banner fields and dates that must be used for enrollment and withdrawal reporting;
o The Banner fields and dates that must be used for enrollment and withdrawal reporting;
o The required timing for responding to NSLDS roster files; and
o The required timing for responding to NSLDS roster files; and
o The steps for making corrections when errors are identified.
o The steps for making corrections when errors are identified.
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