Finding Text
FINDING 2025-001 Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268) Criteria or Specific Requirement: N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). 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 (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has 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. Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code – The Classification of Instructional Programs (CIP) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics (NCES). They were most recently updated in 2020 and are usually updated every ten years. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition: Campus Level: Certain students’ enrollment status changes were not reported or were reported outside of the required timeframe. Program Level: Significant data elements were inaccurately reported for certain students. Cause: Administrative oversight and insufficient internal control. Effect or Potential Effect: The University was not in compliance with the enrollment reporting requirements. Questioned Costs: None. Context: For 2 of 40 campus level records tested, the University did not certify the students’ enrollment data within the required timeframe. For 2 of 40 campus level records tested, the University did not notify the NSLDS of a change in the student’s enrollment. For 2 of 40 program level records tested, the University did not certify the students’ enrollment data within the required timeframe. For 40 of 40 program level records tested, the University did not accurately report one or more significant data elements to the NSLDS. Identification as a Repeat Finding: This is a repeat of prior year Finding 2024-001. Recommendation: We recommend the University enhances its procedures and internal controls over enrollment reporting to ensure students’ enrollment statuses are reported accurately and timely to NSLDS. Views of Responsible Officials: Audit testing identified errors in withdrawal effective dates, enrollment status changes, and program begin dates. Incorrect or untimely information was reported to NSLDS due to inconsistent internal communication and a lack of systematic reconciliation with National Student Clearinghouse (the “NSC”) reporting files. To ensure ongoing accuracy in enrollment reporting, Southern Virginia University is strengthening communication and coordination across departments involved in the reporting process. Beginning February 2026, the Financial Aid Office implemented a workflow to review NSC and NSLDS error reports more promptly and resolve discrepancies as they arise. Financial Aid will monitor this process monthly until errors are no longer identified, ensuring timely and accurate reporting going forward. The Registrar's Office will receive training on date reporting requirements and expectations for NSLDS so that they use the correct enrollment change dates.