Criteria Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institution...
Criteria Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the NSLDS. 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 (NSDLSFAP) website. 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. Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition In testing the Program-Level enrollment reporting data elements as reported to NSLDS, key items to test are: OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. During the performance of our test work, the College identified that 31 of the 409 students who graduated during the year had enrollment statuses that did not agree between campus-level and program-level NSLDS data. Specifically, these 31 students’ enrollment statuses were correctly reported as graduated in the campus-level NSLDS data but were inaccurately reported as withdrawn in the program-level NSLDS data. The exception described above did not result in changes to the amounts awarded or disbursed to students by the College for the current fiscal year. Cause The condition resulted from a gap in the College’s internal control processes. Specifically, the College did not implement a control to ensure that all changes in enrollment information were submitted accurately to NSLDS. Possible Asserted Effect Inaccurate submission of student enrollment status information and related program information affects the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding was a Repeat Finding This is not a repeat finding. Recommendation We recommend the College review and enhance its process related to enrollment reporting to ensure that all key data elements are reported accurately to the NSLDS. Views of Responsible Officials Responsible Individual: Joan Romano, Registrar, Enrollment Strategy and Operations Contact Information: jromano2@berklee.edu , 617-747-2475 In response to the condition identified, the College has strengthened its internal controls over enrollment reporting to ensure alignment between campus-level and program-level data submitted to NSLDS. Automated validation control implemented: Crossfield validation added to the student information system to ensure campus and program-level enrollment statuses align prior to NSLDS submission at graduation closure. Graduation records with misaligned statuses will be blocked from transmission, and discrepancies generate exception alerts that must be corrected before file submission. Monthly reconciliation and documented exception tracking established: After each NSLDS submission and graduation file transmission, reconciliation reports will compare campus and program-level data. Any discrepancies identified are resolved through a formal exception tracking process before certifying subsequent submissions. Standard operating procedures will be updated to document these enhancements to enrollment data reporting. Enhanced monitoring and supervisory oversight: Enhanced controls will ensure enrollment data reported to NSLDS is accurate, complete, and compliant preventing future reporting misalignment. The Registrar/Associate Registrar will perform review and sign-off to confirm procedures are consistently followed to remediate the risk of any future findings. Expected Implementation Completed: May 31, 2026 Status of Completion: In Process