Finding Text
Identification of Federal Program(s) – Student Financial Assistance Cluster (ALN’s 84.063, 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) – Enrollment Reporting – The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 60 days of the date the University becomes aware of the change in enrollment status. There are two categories of enrollment information: “Campus Level” and “Program Level,” each with separate record types that need to be reported accurately. Institutions are responsible for accurately reporting the significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements, it is the school that must ensure that enrollment information is submitted timely, accurately, and completely (34 CFR 685.309(b), 685.210(c), and 690.83(b)(2)).
Condition – For certain students selected for testing who graduated or withdrew during the year, the University did not submit status change notification or failed to submit timely notification to the NSLDS website.
Cause – Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements.
Effect or Potential Effect¬ – The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs – None.
Context – The University did not accurately report Campus Level enrollment data elements to the NSLDS website for 1 of 25 Federal Pell Grant and Federal Direct Student Loan recipients selected for testing that had a reduction or increase in attendance levels, graduated, withdrew, dropped out, or enrolled but never attended during the fiscal year.
The University did not accurately report Program Level enrollment data elements to the NSLDS website for 6 of 25 Federal Pell Grant and Federal Direct Student Loan recipients selected for testing that had a reduction or increase in attendance levels, graduated, withdrew, dropped out, our enrolled but never attended during the fiscal year.
Identification of Repeat Finding – No similar findings noted in the prior year.
Recommendation¬¬ – We recommend that the University enhance its internal controls, policies, and procedures over the applicable compliance requirements of the Enrollment Reporting to ensure that all Campus Level and Program Level data is reported accurately and status changes are submitted to the NSLDS website within the required timeframe.
Views of Responsible Officials – The University concurs with the finding and will review and revise its procedures for the frequency of NSLDS reporting to ensure accurate and timely reporting of enrollment changes. The University will implement a monthly enrollment audit to ensure that any change in enrollment status is identified in a timely manner and reported to NSLDS