Finding Text
2024-003—Error in Reporting for National Student Loan Data System (NSLDS)
U.S. Department of Education
Student Financial Assistance Programs Cluster (Direct)
Federal Direct Loan Program (84.268)
Federal Award Year: 2023-2024
Repeat Finding: No
Criteria
The Code of Federal Regulations (34 CFR 685.309) requires enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date.
According to the NSLDS Enrollment Reporting Guide, a student’s Program-Level enrollment status should be reported with the same enrollment status as that student’s campus-level enrollment status for all programs the student is enrolled in at that location, even if the student is not currently taking coursework that applies to a particular program. If the student has withdrawn or graduated from an academic program, a “terminal enrollment status” of ‘W’ or ‘G,’ as appropriate, should be reported for that program, even if the student is still taking coursework applicable to other programs in which the student is enrolled.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is completed properly.
Condition:
The College did not properly report the student enrollment change for students who received federal student aid to the NSLDS.
The College did not timely report three students’ Program-Level or Campus-Level enrollment status change to NSLDS. Out of the 11 students tested, we noted 3 students (28%) whose status change at the Program-Level and Campus-Level was not timely reported to NSLDS.
The College did not have formally documented controls related to the process of enrollment reporting, which is required under Uniform Grant Guidance.
Cause
An additional submission to the NSLDS was required for the students who withdrew during the term to meet the reporting requirements that did not occur. The College noted that changes related to mid-term withdrawals are not completed until the end of the term, which is outside the allowable window of reporting noted above.
Effect
Noncompliance with federal regulations could result in the loss of future federal funding.
Context
We tested 11 students who received federal student aid with enrollment changes. For each student tested, management provided documentation from NSLDS showing when the student’s status changed, and when it was reported. Out of the 11 students tested, we noted 3 students (28%) whose status change at the Program-Level and Campus-Level was not timely reported to NSLDS.
Questioned costs
There were no questioned costs with respect to this finding.
Recommendation
We recommend the College review current processes and implement updated processes and controls for reporting to NSLDS, implementing procedures to ensure submissions are reported timely and accurately.
Views of responsible officials
Management agrees with this finding. See corrective action plan.