Finding 1130860 (2024-006)

FINDING - Noncompliance with Enrollment Reporting Requirements Federal Agency: Department of Education Assistance Listing Numbers: 84.268, 84.063 Program Names and Award Numbers: Federal Direct Student Loans, Federal Pell Grant Program Program Expenditures: $10,983,995, $12,186,160 Questioned Costs: None Northeastern Illinois University (University) did not have adequate procedures and controls in place to ensure that the effective date of students who unofficially withdrew was accurately reported to National Student Loan Data System (NSLDS). CONDITIONS FOUND & CRITERIA During our testing of the University’s compliance with enrollment reporting requirements for Direct loan programs via the NSLDS (OMB No. 1845-0035), we noted the University did not update program-level and campus-level effective enrollment dates for the students’ appropriate withdrawal date. We noted the following: - Two of 25 (8%) of the students originally tested withdrew during the Fall semester however were reported to NSLDS as withdrawn with an effective enrollment change date for the last day of the spring semester. NSLDS requires the that date the current enrollment status is to be reported when the change was first effective (See 4.4.2 of NSLDS Enrollment Reporting Guide) - Five of 25 (20%) of the students originally tested withdrew during their respective fall and spring semester however were reported to NSLDS as withdrawn with an effective enrollment at the end of the semester and not updated retroactively. - 15 of 15 (100%) additional students tested as a result of the error withdrew during their respective fall and spring semester however were reported to NSLDS as withdrawn with an effective enrollment at the end of the semester and not updated retroactively thus bringing total errors to 22 of 40 students (55%). NSLDS requires the that date the current enrollment status is to be reported when the change was first effective (See 4.4.2 of NSLDS Enrollment Reporting Guide) and can be retroactively reported to reflect the accurate effective date (See 4.4.5 of NSLDS Enrollment Reporting Guide) The sample was not intended to be, and was not, a statistically valid sample. NSLDS Enrollment Reporting Guide (4.4.5) does speak to continue education as a way of determination of student’s enrollment status. However, this is only applicable when evaluating the end of the current school year, during the spring and summer semester, with respect to the upcoming school year’s fall semester. CAUSE University’s officials stated these students’ enrollment effective date was not reported until the last day of the semester by confirming if the student was enrolled in the next term, which resulted in reporting the incorrect date. EFFECT Failure to meet enrollment reporting requirements is noncompliance with federal regulations and could result in loss of loan/grant funding in future years. (Finding Code No. 2024-006) RECOMMENDATION We recommend the University’s registrar’s office implement processes and controls to ensure the appropriate determination of the last date of attendance for withdrawal determinations are reported to NSLDS. UNIVERSITY RESPONSE The University agrees with the recommendation.