Finding Text
Finding 2024-003 – N. Special Tests and Provisions – Enrollment Reporting
Information on Federal Program(s) - Student Financial Assistance Cluster (ALN: 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 Student Financial Assistance 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). Institutions must review, update, and verify 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. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (“SAIG”) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.
Condition – Certain students’ enrollment status changes were not reported timely or accurately to NSLDS. Additionally, error records were not corrected within the required timeframe.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect - The University was not in compliance with the enrollment reporting requirements.
Questioned Costs – None.
Context – The context of this finding is as follows:
• For 3 of 40 campus level records and 1 of 40 program level records tested, the University did not certify the student’s enrollment status within 60 days.
• For 3 of 40 campus level records and 9 of 40 program level records tested, the University did not accurately report all enrollment data elements.
• 36 of 97 error records identified during the year ended June 30, 2024 were not corrected within 10 days as required.
Indication of Repeat Finding - This is a repeat of prior year Finding 2023-005.
Recommendation – We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that students’ enrollment statuses are reported timely and accurately to NSLDS and that errors are corrected within the required timeframe.
Views of Responsible Officials – In response to Finding 2024-003, Wheeling University will continue the enrollment reporting process that was implemented in October 2023, which was in response to Finding 2022-005 and continued with the Finding 2023-005. With the stability of staffing in the Registrar’s Office and Financial Aid Office and the level of experience and competence of this staff, enrollment reporting has been completed within the parameters of regulatory guidelines. The Registrar’s Office submits enrollment reports as scheduled and subsequent error resolution reports as appropriate. The Financial Aid Office reviews identified NSLDS errors, corrects and resubmits them timely. Regularly scheduled meetings, including the Registrar’s and Financial Aid Offices, continue as noted in corrective actions for Findings 2022-005 and 2023-005. These meetings serve as the platform to discuss and address identified enrollment reporting concerns/issues timely, resulting in improved accuracy in enrollment reporting and timeliness in error resolution. In addition, attendance through Census will be monitored in an effort better identify registered but not enrolled students for administrative action and timely reporting. Institutional enrollment reports will be used to identify students who have chosen not to continue their studies at the University but without withdrawing from the institution to alert departments to execute their operational protocols for students who have discontinued enrollment. Students who officially withdraw pursuant to established University protocols will be required to consult with Financial Aid during this process. University departments will continue to be informed of student withdrawals as they occur to inform their practices.