Finding Text
Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that – (iii) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (iv) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated November 2025: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the University to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, we noted 10 students, out of a sample of 40, that had incorrect effective dates reported to NSLDS. Cause The University did not have adequate procedures in place to ensure that students with status changes had their effective date correctly reported to NSLDS. For graduates, the last day of the semester is typically used. The University should have reported the students’ last date of the semester as the effective date, but instead used a different date as the effective date. All ten students were Fall 2024 graduates and this finding likely applies to all Fall 2024 graduates. Effect The University did not report the students’ correct effective dates to NSLDS, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 10 students, or 20% of our sample, had incorrect effective dates reported to the NSLDS. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the effective date of a student’s graduation, the importance of reporting the correct effective date and the consequences of incorrect reporting. This oversight should also ensure that the effective date reported to NSLDS is consistent with the date the student separated from the University. Additionally, submission of additional rosters may reduce the likelihood of the finding in the future. View of Responsible Officials The University agrees with the finding and has implemented the corrective action plan listed within the management corrective action plan section of this report.