Finding Text
Federal Program Information: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Enrollment Reporting – Institutions are required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the University becomes aware of the change in enrollment status. Campus and Program Level records are required to be submitted timely, accurately, and completely. According to the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Condition: For certain students whose status changed during the year, the University did not accurately or timely report data elements identified as high risk by ED. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with enrollment reporting compliance requirements. Questioned Costs: None. Context: For 2 of 40 students selected for campus level and program level testing, the students’ statuses were not certified within the required timeframe. For 2 of 40 program-level records tested, the records contained an inaccurately reported data element. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2024-001 in the 2024 report. Recommendation: We recommend that the University implement procedures to ensure that that all status changes are submitted to the NSLDS website within the required timeframe and that all record data elements are reported accurately. Views of Responsible Officials: Liberty University acknowledges that its FY25 single audit identified instances where students’ enrollment reporting was not updated in a timely manner in accordance with U.S. Department of Education (ED) requirements. Liberty has invested significant effort into ensuring its enrollment reporting process is handled compliantly and within alignment with ED’s best practices. Liberty’s Registrar’s Office created a new Director of Clearinghouse Reporting position in May 2024, who is responsible for monitoring Clearinghouse feeds and any associated error reports and works closely with Liberty’s Financial Aid and Information Technology (ADS) offices to ensure enrollment reporting compliance. Liberty has continued the work of developing a more comprehensive quality control (QC) process by reviewing the Clearinghouse Reject report in a timely manner, meeting on a monthly basis with internal stakeholders, and working more closely with Clearinghouse Representatives to identify scenarios where enrollment records are accurately reported to Clearinghouse but never sent on to NSLDS. Liberty University plans to provide Clearinghouse representatives with specific audit cases to identify gaps in enrollment reporting and increase accuracy of individual reviews. Liberty Internal QC Reporting: Liberty University will continue to work quality control and the Clearinghouse Reject report which has enabled the university to be more proactive in its compliance efforts. Additionally, Graduated Dates Prior to Term End, NSLDS MisMatches, NSLDS No Banner SSN, and the NSLDS Record Missing reports will continue to be worked in a timely manner. These reports have been helpful to identify more common/persistent errors/delays and provide an additional layer of quality control checks for Liberty’s enrollment reporting. Accountability Meetings: Liberty began holding a series of biweekly “Enrollment Reporting Check-In” meetings with key stakeholders from Financial Aid, Registrar, and IT/ADS in February 2024, which are dedicated to discussing current and upcoming enrollment reporting submissions and errors, trends seen with SSCR errors, and brainstorming ways to ensure ongoing compliance. These meetings will continue with a focus on ways to improve reporting logic to prevent errors from occurring. While improvement efforts continue to be underway, Liberty believes these efforts are starting to bear fruit as evidenced by a 99.7% reduction in the number of repeat errors from FY24 to FY25. Finally, Liberty University uses a standard formula for its Program Lengths in order to ensure compliance with other requirements, however certain programs have unique program lengths which may not align with this standard formula for Enrollment Reporting purposes. The Financial Aid Office will work with Registrar and the Provost’s Office, to evaluate any programs which fall outside the standard formula and adjust the published program dates as necessary. Moving forward Liberty will continue to hold monthly meetings with key stakeholders to discuss any enrollment reporting errors and ensure best practices are implemented to ensure ongoing and timely accuracy. The University’s Registrar’s Office will also continue to review the QC reports in an appropriate manner, as well as evaluate the processes for withdrawal/graduated student files. Liberty will continue to review and implement updates as necessary to maintain enrollment reporting compliance and believes these new processes will allow us to be compliant in subsequent years.