Finding Text
Finding 2025-001: Special Tests and Provisions – NSLDS Reporting Student Financial Assistance Cluster U.S. Department of Education Award Period: July 1, 2024 – June 30, 2025 Criteria: Institutions are required to report enrollment information under the Pell Grant and the Direct Loan and FFEL programs via the NSLDS (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA 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; Perkins 34 CFR 674.19(f)). 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 certify 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. 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. Condition: Institutions are responsible for accurately reporting all Campus-Level Record data elements and one of the Campus-Level Record data elements which ED considers to be high risk is the “Enrollment Effective Date”. Enrollment Effective Date is the date that the current enrollment status reported for a student was first effective. For 1 student out of an initial sample of 40 for NSLDS Reporting compliance and control testing, we noted that the Enrollment Effective Date reported by the College to the NSLDS did not reflect the underlying records of the College and was therefore inaccurate. Additionally, internal College policy for determining the Enrollment Effective Date was not followed despite internal College records matching those of NSLDS. Cause: Lack of precision in the review of reporting of Enrollment Effective Dates to the NSLDS as well as the review of the consistency of information between NSLDS and the College’s internal records, before submission. Effect: For 1 student out of an initial sample of 40 for NSLDS Reporting compliance and control testing, we noted that the Enrollment Effective Date reported by the College to the NSLDS did not reflect the underlying records of the College and was therefore inaccurate. An additional sample of 40 was made due to this error for a total of 80 students tested. Additionally, for 2 out of the 40 students within the second sample tested, internal College policy for determining the Enrollment Effective Date was not followed despite internal College records matching those of NSLDS. Lastly, for 1 out of the 40 students within the second sample tested, the effective date per internal College records did not match NSLDS. Questioned Costs: None. Context: For 1 student out of an initial sample of 40 for NSLDS Reporting compliance and control testing, we noted that the Enrollment Effective Date reported by the College to the NSLDS did not reflect the underlying records of the College and was therefore inaccurate. This student was noted per the College as having a status of “LOA” (Leave of Absence), but this LOA was not reported to the NSLDS appropriately as Program-Level Enrollment data indicated this student as being withdrawn but the Campus-Level Enrollment data did not. An additional sample of 40 was made due to this error for a total of 80 students tested. Additionally, for 2 out of the 40 students within the second sample tested, internal College policy for determining the Enrollment Effective Date was not followed despite internal College records matching those of NSLDS. Lastly, for 1 out of the 40 students within the second sample tested, internal College policy for determining the Enrollment Effective Date was followed, but the Date per College records did not match that of NSLDS. Repeat Finding: No. Recommendation: It is recommended that the College enhances the precision of its review of both categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types which are accurate and do not contradict each other. Views of Responsible Officials: In response, the College implemented standardized processes for processing LOA and withdrawal actions. This documentation provides a framework for staff to ensure that effective dates per the College are aligned with what is transmitted to the NSLDS. Additionally, the College revised its reporting schedule to ensure that LOA and withdrawal updates are transmitted on a regular, recurring basis. Refer to the Corrective Action Plan for Current Year Findings.