Finding 1180820 (2025-004)

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.007; 84.063; 84.268 Cluster Name: Student Financial Assistance Cluster Program Names: Federal Supplemental Education Opportunity Grants; Federal Pell Grant Program; Federal Direct Student Loans Award Numbers: N/A; Federal Award Year 2024-2025 Questioned Cost: None Program Expenditures: $768,137; $45,573,205; $87,147,867 Cluster Expenditures: $137,694,385 The Illinois State University (University) did not accurately report student enrollment information to the U.S. Department of Education’s National Student Loan Data System (NSLDS) and internal controls in place did not identify the errors. Condition Out of twenty-five students tested, we noted fourteen students’ (56%) enrollment status changes had discrepancies in Enrollment Effective Dates between the NSLDS Campus-Level Record and the NSLDS Program-Level Record, with the NSLDS Program-Level Record dates being inaccurate by 17 days. The sample was not intended to be, and was not, a statistically valid sample. Criteria According to the NSLDS Enrollment Reporting Guide, a student’s Program-Level enrollment status should be reported with the same enrollment status as student’s Campus-Level enrollment status for all programs the student is enrolled in at a location, even if the student is not currently taking coursework which 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 If the student has withdrawn or graduated from an academic program, a “terminal enrollment status” of ‘W’ or ‘G,’ as appropriate, should be reported for the program, even if the student is still taking coursework applicable to other programs in which the student is enrolled. The NSLDS Enrollment Reporting Guide also states the University is responsible for accurately reporting all Program-Level Record and Campus-Level Record data elements. 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 statutes, regulations, and terms and conditions of the federal award. Effective internal controls should include procedures to ensure accurate student enrollment information is submitted to NSLDS. Cause University management indicated the failure to report accurate enrollment information was due to a technical error in the University’s process to transfer data to NSLDS. Effect Failure to accurately report Campus-Level student enrollment information to NSLDS resulted in noncompliance with federal guidelines and inaccurate NSLDS records. (Finding Code No. 2025-004) Recommendation We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure student enrollment information is reported accurately. University Response The University acknowledges the above finding. The identified issue was isolated and only impacted fall graduates. This issue was fully addressed when the university filed its fall 2025 enrollment reporting. The university has conducted an internal audit to identify students that were reported incorrectly and has manually updated files to ensure dates were properly reflected. At current state, internal monitoring and manual edits are made if discrepancies appear. It is expected that the Enterprise Resource Planning System will launch an automatic fix for this issue in a software update for all users in the first quarter of calendar year 2026. Should the software issue not result in an automation of the fix, the University plans to continue the manual edits, then customize the NSLDS reporting logic to ensure continued future alignment.