Finding Text
Finding 2025–001 – Special Tests and Provisions – NSLDS Reporting (Significant Deficiency) U.S. Department of Education – Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Loan Program (84.268) Federal Award Year: 2024-2025 Criteria and Context: Institutions are required to report enrollment information under the Pell Grant and the Direct loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. 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. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Enrollment information is used to determine the borrower’s eligibility for in-school status, deferment, interest subsidy, and grace period. Enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported. The enrollment information is merged into the NSLDS database and reported to guarantors, lenders, and servicers of student loans. Condition, Cause, and Effect: Due to personnel turnover in in the Department of Enrollment Services at the College during the period under audit, the College experienced significant delays in reporting enrollment statuses to the NSLDS. We identified the following instances of noncompliance from a selection of eight (8) graduated students and two (2) withdrawn students selected for enrollment reporting testing: • Ten (10) students whose Program-Level Enrollment and Campus-Level Enrollment Statuses were reported to the NSLDS outside of the required 60-day reporting timeframe. Although the reporting was submitted late for the students noted above, the information contained in both the Program-Level and Campus-Level data (e.g., OPEID Number, CIP Code, CIP year, etc.) was accurate and consistent with institutional records. Questioned Costs: None noted. Identification of a repeat finding: This is not a repeat finding. Recommendation: The College should strengthen its policies and procedures to ensure that student status transmission reports are submitted timely to the NSLDS throughout the entire award year. Views of Responsible Officials and Planned Corrective Action: Management acknowledges the finding and agrees that delays in enrollment reporting occurred due to staffing transitions within the College’s Department of Enrollment Services. The College has implemented revised internal procedures and has hired a Vice President of Enrollment and a Senior Registrar with the requisite skills and experience to ensure timely and accurate NSLDS reporting going forward.