Finding Text
Federal Agency: U.S. Department of Education
Program: Student Financial Assistance Cluster (84.268 Direct Loans, 84.063 Federal Pell Grant
Program)
Compliance Requirement: Special Tests and Provisions – Enrollment Reporting
Criteria:
In accordance with 34 CFR §685.309(b) and the Department of Education’s Enrollment
Reporting Guide, institutions must notify NSLDS of changes in student enrollment status within
30 days of the change, or ensure that the change is reported in the next scheduled roster file, but
no later than 60 days after the date of determination.
Condition:
We tested a sample of 17 students for changes in enrollment during the audit period. Our testing
revealed 16 instances where student enrollment changes were not updated within the required
timeframe.
The overall rate of error was 94%.
Cause:
The Institution uses a third-party provider, ECM, to update its enrollment information with
NSLDS. The Institution enters enrollment updates into an interface spreadsheet, which is
uploaded into ECM’s student system, SOLFIA. This data is then transferred from SOLFIA to the
NSLDS enrollment system.
In April 2024, ECM notified the Institution that it was updating SOLFIA to comply with new
technical specifications issued by the U.S. Department of Education. These updates were not
completed until September 2024, and technical issues with SOLFIA persisted thereafter. As a
result, the Institution was unable to transmit timely enrollment updates to NSLDS. Due to the
continuing issues with SOLFIA, the Institution began manually updating enrollment information
with NSLDS in March 2025.
Effect:
Untimely or missing enrollment status reporting may lead to delays in borrowers’ loan servicing
activities such as entering repayment, deferment, or grace periods, and could cause
noncompliance with federal requirements. Inaccurate reporting may also increase the risk of loan
defaults and interest accrual issues for students.
Questioned Costs:
Known questioned costs are not considered material; however, due to the compliance nature of
the finding and the frequency of occurrence, the finding is deemed material for reporting
purposes.Recommendation:
We recommend that the Institution work closely with its third-party provider to ensure that
system updates affecting enrollment reporting are implemented in a timely and controlled
manner. The Institution should:
• Establish contingency procedures, such as temporary manual reporting processes, to
ensure compliance during periods of system outages or transitions;
• Perform regular reconciliations between internal records, SOLFIA, and NSLDS to
identify and correct delays or discrepancies; and
• Strengthen communication protocols with its third-party provider to monitor and respond
to system issues affecting Title IV compliance.
Views of Responsible Officials:
The institution agrees with the finding. A corrective action plan addressing the noted deficiencies
has been submitted under separate cover.