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Finding No. 2025-001 — Significant Deficiency
Finding No. 2025-001 — Significant Deficiency
— Special Tests and Provisions-Enrollment Reporting
— Special Tests and Provisions-Enrollment Reporting
Criteria: Federal regulations and related guidance governing Title IV student aid programs require schools to report the enrollment of students who receive federal student aid (U.S. Department of Education, National Student Loan Data System (NSLDS) Enrollment Reporting Guide, November 2022, Chapter ...
Criteria: Federal regulations and related guidance governing Title IV student aid programs require schools to report the enrollment of students who receive federal student aid (U.S. Department of Education, National Student Loan Data System (NSLDS) Enrollment Reporting Guide, November 2022, Chapter 2). At a minimum, schools are required to certify enrollment every 60 days and respond within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. 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.
Laredo College (College) uses the services of the National Student Clearinghouse (NSC) to report status changes to NSLDS. Under this arrangement, the college reports all students enrolled and their status to NSC. NSC then identifies any changes in status and reports those changes to NSLDS when requi...
Laredo College (College) uses the services of the National Student Clearinghouse (NSC) to report status changes to NSLDS. Under this arrangement, the college reports all students enrolled and their status to NSC. NSC then identifies any changes in status and reports those changes to NSLDS when required. Although the college uses the services of the NSC, the College still has the primary responsibility for ensuring any changes in student enrollment status is reported accurately and in a timely manner (NSLDS Enrollment Reporting Guide, November 2022, Chapter 3).
Condition: For 18 out of 25 (72 percent) students tested, the college did not accurately and timely report enrollment status changes to NSLDS. Specifically:
Condition: For 18 out of 25 (72 percent) students tested, the college did not accurately and timely report enrollment status changes to NSLDS. Specifically:
· 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.
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