Finding Text
Finding 2025-001 Special Tests & Provisions – NSLDS Reporting Federal Program Information: Funding agency: US Department of Education Title: Student Financial Aid Cluster ALN: 84.007, 84.033, 84.063, 84.268 Criteria: Federal regulations (34 CFR 685.309 and NSLDS Enrollment Reporting guidance) require institutions to report enrollment status changes to National Student Loan Data System (NSLDS) accurately and timely. Enrollment status changes must generally be reported within 30 days of the status change if the institution does not file roster reports, or within 60 days of the date the institution becomes aware of the status change when following normal roster reporting cycles. Condition: During our examination of 17 student files with enrollment status changes, we noted 3 students whose enrollment statuses were either inaccurately reported to NSLDS or reported outside of the required timeframe. Student A - Institutional records show an LDA of 10/9/24; NSLDS reflects a withdrawal effective date of 12/6/24. Student B – Withdrawal not reported within the required 60 day timeframe. The student withdrew on 5/9/25; the date of determination (DOD) was 5/14/25; NSLDS certification occurred on 9/4/25. Student C – Withdrawal not reported within the required 60 day timeframe. The student withdrew on 5/9/25; the date of determination (DOD) was 5/14/25; NSLDS certification occurred on 9/4/25. Context: The College processes enrollment data for a substantial number of Title IV-eligible students. Of the 17 students selected for testing, 3 (18%) had inaccurate or incomplete NSLDS reporting. Errors were not concentrated in a single academic program or term, indicating that the issue may be broader within the enrollment reporting process. These inconsistencies increase risk because NSLDS relies on accurate enrollment data to determine in-school status, grace periods, and repayment dates. Questioned Costs: $0 Effect: NSLDS did not accurately reflect the students’ enrollment status changes. Inaccurate or late reporting may result in: incorrect repayment notifications, improper deferment or grace period calculations, and potential noncompliance with federal reporting requirements. Cause: The College reported the last day of the term rather than the student’s actual last date of attendance, resulting in inaccurate effective dates being transmitted to NSLDS. The College did not submit the enrollment status updates within the required 60‑day reporting window. Repeat: Yes - Years as Repeat Finding: One Auditor’s Recommendation: The College should implement stronger internal controls over NSLDS enrollment reporting, including: periodic spot checks comparing NSLDS reflected statuses and effective dates to institutional records; verification of LDA/DOD accuracy prior to certification; and monitoring compliance with the 60 day reporting requirement to ensure enrollment changes are transmitted timely. Management should consider incorporating a secondary review process. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan.