Finding Text
N. Special Tests and Provisions – Enrollment Reporting
Information on Federal Program(s) - Student Financial Assistance Cluster (Federal Assistance Listing #84.063 and #84.268)
Criteria or Specific Requirement - Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). 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 which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Campus Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Program Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including OPEID number, CIP code, CIP year, credit level, program enrollment status, program enrollment effective date, program length, and program begin date.
Condition – During our testing of student enrollment reporting, we noted the following exceptions at the campus level and program level:
Campus Level: For 2 students selected for testing, the University did not report enrollment status changes within the required time frames.
Program Level: For 1 student selected for testing, the University did not correctly report all program enrollment data elements to NSLDS.
Cause – Administrative oversight in internal controls over enrollment reporting requirements.
Effect or Potential Effect – The University was not in compliance with the enrollment reporting requirements.
Questioned Costs – None.
Context – The context at the campus level and program is as follows:
Campus Level: 2 of 25 students selected for testing.
Program Level: 1 of 25 students selected for testing.
Indication of Repeat Finding – There was no similar finding identified during the prior year.
Recommendation – We recommend that the University enhance its procedures and its internal controls over enrollment reporting requirements.
Views of Responsible Officials – It was identified during the Student Financial Aid audit that Wingate University (WU) is out of compliance with the enrollment reporting requirements for two students (one student at the campus level and one student at both the campus level and program level). We currently contract with the National Student Clearinghouse (NSC) for enrollment reporting and have identified the compliance issue to be a disconnect between the reporting requirements in place with NSC and WU Institutional policy.
For each identified student, the student was permitted by WU policy to complete their degree requirements after the end of the academic term. When reporting the Graduated status in NSC, the Registrar is required to select the last date of the term as the Graduation Date instead of the date the student actually completed their degree requirements. When this occurs more than 60 days from the end of the term, the student is noted as out of compliance with reporting requirements due to the limitation identified with NSC.
The Registrar and Director of Financial Aid will work with NSC to identify a solution for reporting the actual completion date for a student when it occurs after the conclusion of the standard term and outside of the reporting definitions offered by NSC. If a viable solution cannot be identified with NSC, we will establish a policy to manually update data in NSLDS for impacted students to meet the 60-day reporting requirements for enrollment status changes.