Finding 1179940 (2025-003)

Federal Agency: US Department of Education (ED) Program Name: Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Pell Grant Program ALNs: 84.268; 84.063 Award Numbers: P268K171370, P063P161370; Federal Awards Year 2024 – 2025 Questioned Costs: None Repeat Finding: Yes 2025-003. Finding: Errors in Reporting for NSLDS Northern Illinois University (University) did not properly report enrollment changes for certain students who received federal student aid to the National Student Loan Data System (NSLDS) and the internal controls in place did not prevent and detect errors. Condition: We noted 2 (5%) of 40 students tested in which the University did not report the correct enrollment status to the NSLDS at the Program Level. The sample was not intended to be, and was not, a statistically valid sample. Criteria: The Code of Federal Regulations (34 CFR 685.309) requires enrollment status changes for students to be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status to include an accurate effective date. According to the NSLDS Enrollment Reporting Guide, a student’s Program-Level enrollment status should be reported with the same enrollment status as that student’s campus-level enrollment status for all programs the student is enrolled in at that location, even if the student is not currently taking coursework that applies to a particular program. If the student has withdrawn or graduated from an academic program, a “terminal enrollment status” of ‘W’ or ‘G,’ as appropriate, should be reported for that program, even if the student is still taking coursework applicable to other programs in which the student is enrolled. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is completed properly. Cause: University officials indicated the two exceptions were the result of manual processing errors. Specifically, Program-Level enrollment status updates were not completed for two students who unofficially withdrew. Effect: If the NSLDS is not properly updated with the student information by the University, overawards could occur should the student transfer to another institution and the student may not properly enter the repayment period. (Finding Code No. 2025-003, 2024-003) Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. University Response: Accepted. The University acknowledges the importance of accurate and timely enrollment reporting to the National Student Loan Data System (NSLDS). As it relates to the prior year finding and repeat finding status, the University corrected the system configuration issue and provided additional training regarding effective date reporting requirements. The exceptions identified in the current year were unrelated to the prior system logic issue and instead resulted from manual processing errors involving Program-Level updates for unofficial withdrawals. The University will review and strengthen its current enrollment reporting procedures to ensure Program-Level updates are completed consistently, particularly in cases involving unofficial withdrawals. The University will develop a batch reporting process for unofficial withdrawals to facilitate accurate enrollment reporting at both the program and campus level. Additional verification steps will be implemented prior to submission to confirm that both campus-level and program-level enrollment statuses are properly updated. The University will also reinforce staff training related to NSLDS reporting requirements and enhance supervisory review procedures to reduce the risk of similar errors occurring in the future.