Finding Text
Criteria: 34 CFR 685.309(b) states that upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary in the manner and format prescribed by the Secretary and within the timeframe prescribed by the Secretary. Unless it 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 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. Context: Noncompliance with federal regulations was noted for 16 of the 40 students who were tested. 4 Of the students did not have their change in enrollment status reported to NSLDS within 60 days and 12 students did not show the correct change of status, and thus also did not have their change in enrollment status reported timely to NSLDS. In addition, the effective date reported to NSLDS for 4 students did not match the University’s records, and related CIP code reported to NSLDS for 1 student did not match the University’s records. A total of 70 students who were issued Federal Direct Student Loans separated from the University or had a change in enrollment status during fiscal year 2023. The sample was not considered statistically valid.
Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and other information, then the Title IV student loan records will be inaccurate, which impacts student loan repayments.
Cause: It does not appear that there are proper processes in place surrounding enrollment reporting in order to verify that the correct dates, enrollment statuses, or other information are reported to NSLDS within the required timeframes.
Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates and status changes are reported to NSLDS within required time frames. This could include a review of withdrawal or graduation dates compared to the effective dates reported to NSLDS to make sure they are accurate.
Management’s Response: Briar Cliff will work with Ellucian on a review of the setup and processes that the Registrar’s Office currently follows, and we will work with Ellucian for recommendations on implementing a process/procedure that ensures the Registrar’s Office has been trailed and is in compliance.