Finding Text
Finding 2024-002
Special Tests and Provisions - Enrollment Reporting Compliance and Internal Control (Significant Deficiency)
U.S. Department of Education - Student Financial Assistance Cluster
Federal Direct Student Loans (ALN 84.268) Federal Award Number: P268K211912
Federal Pell Grant Program (ALN 84.063) Federal Award Number: P063P201912
Federal Award Year: 2023-2024
Criteria:
Under the Federal Pell Grant Program and U.S. Department of Education (“ED”) loan programs, institutions are required to report student enrollment information via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. 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 website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS maintains 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. Required campus-level data includes:
• Office of Postsecondary Education Identifier (“OPEID”);
• Enrollment status; and
• Enrollment effective date.
Required program-level data includes, but is not limited to:
• Program enrollment status;
• Program enrollment effective date;
• Program begin date;
• Published program length and measurement; and
• Classification of Instructional Program (“CIP”) code.
Context and Condition:
From a selection of forty (40) students tested, we identified the following instances of noncompliance:
1) For one (1) student, the program begin date that was reported to the NSLDS did not reflect the first day of the earliest semester in which the student began attending the respective program being reported.
2) For one (1) student, the enrollment change was reported to the NSLDS 68 days after the College was notified of the enrolment change, which exceeds the 60-day timeframe required by ED.
Cause:
Due to the manner in which the College’s enrollment and financial aid system has been programmed to report such information, the identified student’s program begin date was inaccurately reported to the NSLDS, and an enrollment change was not reported timely.
Effect:
The program begin date for one student was not properly reported to the NSLDS, and one enrollment change was not reported timely to the NSLDS.
Questioned Costs:
None identified.
Identified as a Repeat Finding:
Yes.
Recommendation:
The College should implement procedures to ensure that students’ program begin dates are reported to the NSLDS accurately, enrollment changes are reported timely, and all changes are reported in accordance with the NSLDS Enrollment Guide.
Views of Responsible Officials and Planned Corrective Actions
The College has made great strides in working through its historical data to correct and update students’ program begin dates. There has been significant improvement in the accuracy of this data being reported to the NSLDS, and we expect final completion of this manual process during the College’s next fiscal year. The College also recognizes the importance of reporting all enrollment changes timely to the NSLDS. In order to address the cause of the late enrollment reporting finding, the College has now implemented a process of reporting to the National Student Clearinghouse every 45 days, to ensure that the 60-day timeframe required by the ED is always met.