Finding 1088492 (2024-002)

Criteria According to 34 CFR 685.309(b)(2): Unless the Colleges expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that – (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the Colleges to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, we noted 1 student, out of a sample of 40, that were not reported to NSLDS. During our testing, we noted that three of the Colleges merged into one entity during year ending June 30, 2024. We observed the records and noted 18 students out of 3,789 students did not have their NSLDS status properly transferred to the new institution. Cause The Colleges did not have adequate procedures in place to ensure that status changes were properly reported to NSLDS. The College did not have procedures in place to ensure student statuses were properly transferred during the merger of three of the Colleges. Effect The Colleges did not report the student’s correct status change to NSLDS, which may impact the student’s loan grace periods and enrollment reporting statistics collected by the Department of Education. Questioned Costs Not applicable. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5% of our sample, were not reported to NSLDS. Of the 3,789 students merged into one institution, 18 students, or 0.5% of merged students, were not reported to NSLDS. Identification as a Repeat Finding, if applicable Not applicable. Recommendation The Colleges should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the status changes, the importance of reporting the correct status changes and the consequences of incorrect reporting. Additionally, the Colleges should implement reconciliation procedures between enrollment records and NSLDS to ensure that information is properly maintained. View of Responsible Officials The Colleges agrees with the finding.