Finding 1181755 (2025-001)

FINDING 2025-001 Federal Program Information: Federal Direct Student Loan Program (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. NSLDS Reporting – The School is required to report enrollment information under the Federal Direct Student Loan Program via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035). 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. Campus Level: Institutions are responsible for accurately and timely 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full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month. Program Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including OPEID number, CIP code, CIP year, credit level, program enrollment status, program enrollment effective date, program length, and program begin date. Condition: During our testing of student enrollment reporting, we noted the following exceptions: • For 30 of 40 selected students, the campus level enrollment effective date was not correctly reported to NSLDS. • For 13 of 40 selected students, the campus level enrollment status was not correctly reported to the NSLDS. • For 33 of 40 selected students, the campus level enrollment effective date was not certified in NSLDS within the required timeframe. • For 37 of 40 selected students, the School did not accurately report the student’s program level information to NSLDS. Cause: Insufficient administrative oversight and internal controls with respect to enrollment reporting requirements. Effect or Potential Effect: The School is not properly following its policies and procedures to ensure that compliance is maintained with respect to all aspects of enrollment reporting. Questioned Costs: None. Context: We tested a sample of students and found exceptions as noted in the condition. Identification as a Repeat Finding: This is a repeat finding from prior the year. This was reported as finding 2024-001 in the 2024 report. Recommendation: We recommend that the School enhance its procedures and internal controls to ensure that all status changes are submitted to the NSLDS website within the required timeframe and all required data elements are reported on the NSLDS website. Views of Responsible Officials and Planned Corrective Actions: We concur. Due in part to frequent turnover in the Registrar's Office, there have been reporting errors in Clearinghouse which have been reflected in NSLDS. In addition to changes in personnel, the Office of the Dean will provide joint oversight with the Office of Student Affairs on matters impacting regulatory requirements. Specifically, there will be a monthly review of the NSLDS database on the second Monday of each month with a regular tracking system. The Registrar, Associate Dean of Students and Dean’s Office representative will provide quarterly “audits” to the Dean on accuracy of data and reporting compliance. Annual NSLDS training, appropriate to the role, will be provided for all team members in the Registrar's Office and others as appropriate.