Finding Text
Finding 2025-06 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Inaccurate and Incomplete Enrollment Reporting to the National Student Loan Data System (NSLDS) (significant deficiency) Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. Criteria – Per 34 CFR § 685.309(b) and 34 CFR § 690.83, institutions are required to report accurate and timely student enrollment information to National Student Loan Data System (NSLDS). The enrollment information must reflect each student’s current enrollment status and must be submitted within 60 days of any change in student status or in accordance with the schedule established by the U.S. Department of Education. Condition – During review of enrollment reporting procedures, we noted that one (1) student record requested for testing was not provided, and two (2) sampled student records were not updated to reflect current enrollment status changes in NSLDS. As a result, the institution could not demonstrate that enrollment reporting was complete, accurate, or timely for the students tested. Subsequent to audit inquiry, the institution provided the requested student record and updated the enrollment status for the two (2) students identified during testing. The institution’s actions corrected the identified records following notification of the exception. Cause – It appears that the exception occurred because the College did not have adequate monitoring procedures in place to ensure compliance for updating and reconciling enrollment changes between the registrar’s system and the NSLDS submission system. Effect – Failure to accurately and timely report student enrollment statuses can result in incorrect loan deferment or grace period tracking for affected borrowers, potential early loan repayment obligations for students who are no longer enrolled, and findings in federal program reviews or compliance audits. There are also an increased risk of administrative capability concerns under 34 CFR § 668.16. Questioned Costs - $0 Perspective – Accurate enrollment reporting is critical because it directly affects borrowers’ repayment obligations and loan servicing timelines. In this instance, three (3) out of six (6) students tested (50%) had enrollment reporting issues, including the inability to provide one requested student record and failure to update enrollment status changes for two additional students. This high error rate indicates that enrollment reporting controls are not operating effectively. The Department of Education treats even single enrollment reporting failures as substantial because they disproportionately impact borrower rights and federal loan servicing. Repeat Finding – No Auditor’s Recommendation – The College should establish a formal reconciliation process to verify all student status changes are reported timely as well as conduct periodic reviews to ensure the accuracy of student status data. Management’s Response – The Institution has reviewed the finding and acknowledges that one student record was not submitted for review. The Institution has provided the NSLDS enrollment verification for that student. For the remaining two students, enrollment reporting was not updated within the required 30-day timeframe. The Institution has since updated their enrollment statuses in NSLDS and has provided updated records for review. The Institution respectfully requests that the finding be formally updated, if applicable, upon the auditor’s review and acceptance of all submitted NSLDS enrollment documentation. In response, the institution has updated its processes and procedures regarding student enrollment reporting with NSLDS, by ensuring accurate enrollments status matches the student transcript. Along with continuing to update within the 30 days established timeframe within NSLDS. Responsible Officials -The Registrar, the Financial Aid Office under the direction of the Vice President of Student Affairs, and Business Office under the direction of the Vice President for Business and Finance plans to have the finding resolved by its next fiscal year end audit (between July – October 2026). The College is aware of the need to review and mitigate compliance risks in this area and will use the described corrective action plan to reduce those risks and eliminate the potential for future audit findings. View of Responsible Officials – The College agrees with the finding