Finding Text
2025-006. FINDING - Noncompliance with Enrollment Reporting Requirements Federal Agency: Department of Education Assistance Listing Numbers: 84.268, 84.063 Program Names: Federal Direct Student Loans, Federal Pell Grant Program Award Numbers: P268K251350 - 2025; P063P241350 - 2025 Questioned Costs: None Northeastern Illinois University (University) did not have adequate procedures and controls in place to ensure that the effective date of students who unofficially withdrew was accurately reported to National Student Loan Data System (NSLDS). CONDITIONS FOUND & CRITERIA: During our testing of the University’s compliance with enrollment reporting requirements for Direct loan programs via the NSLDS (OMB No. 1845-0035), we noted the University did not update program-level and campus-level effective enrollment dates for the students’ appropriate withdrawal date. We noted the following: Two of 25 (8%) of the students originally tested withdrew during the Spring semester; however, they were reported to NSLDS as withdrawn with an effective enrollment change date in the following Fall semester and were not updated retroactively. NSLDS requires that the date the current enrollment status is to be reported when the change was first effective (See 4.4.2 of NSLDS Enrollment Reporting Guide). Ten of 15 (67%) additional students tested as a result of the error withdrew during their respective fall and spring semester; however, they were reported to NSLDS as withdrawn with an effective enrollment at the end of the semester and were not updated retroactively, thus bringing total errors to 12 of 40 students (30%). NSLDS requires that the date the current enrollment status is to be reported when the change was first effective (See 4.4.2 of NSLDS Enrollment Reporting Guide) and can be retroactively reported to reflect the accurate effective date (See 4.4.5 of NSLDS Enrollment Reporting Guide). The sample was not intended to be, and was not, a statistically valid sample. The NSLDS Enrollment Reporting Guide (4.4.5) does speak to continuing education as a way of determination of student’s enrollment status. However, this is only applicable when evaluating the end of the current school year, during the spring and summer semester, with respect to the upcoming school year’s fall semester. CAUSE: University officials stated due to timing issues between the University’s enrollment file certification process and the NSLDS’s roster creation process, the exceptions above were noted. EFFECT: Failure to meet enrollment reporting requirements is noncompliance with federal regulations and could result in loss of loan/grant funding in future years. (Finding Code No. 2025-006, 2024-006) RECOMMENDATION: We recommend the University's implement greater controls and oversight of the University's current Roster Verification process to ensure that a more accurate determination of the last date of attendance for withdrawal determination are reported to NSLDS. UNIVERSITY RESPONSE: The University agrees with the recommendation. To prevent a recurrence of roster timing conflict, the University will coordinate with the NSC to determine the most appropriate submission date for the Unofficial Withdrawal file. Implementing this solution will require the Financial Aid Office to provide the Registrar’s Office with the complete Unofficial Withdrawal file (Last Dates of Attendance included) earlier, as all students on that file are reported to the NSC as actively enrolled students.