Finding Text
Finding 2025-001: NSLDS Reporting Federal Program: Student Financial Assistance Cluster U.S. Department of Education: Federal Pell Grant Program – ALN 84.063 Federal Direct Loan Program – ALN 84.268 Statistically valid sample: No and it was not intended to be. Prior year finding: Not a repeat finding Finding Type: Significant Deficiency and Noncompliance Criteria: Institutions are required to report enrollment information under the Pell grant and the Direct loan program via the NSLDS (OMB no, 1845-0035). Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page. Enrollment information includes both, “Campus Level” and “Program Level” record types, both of which need to be reported accurately. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer; roster files must be completed and returned within 15 days or receipt. (Pell, 34 CFR 690.83(b)(2); Direct Loan 34 CFR 685.309) In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure enrollment information is reported accurately, at both the Campus Level and Program Level. Condition and Context: The University submits enrollment information to the NSLDS, through the National Student Clearinghouse (NSC), several times throughout the year. While the University submitted the enrollment information timely, there were certain students whereby the Campus Level record did not match the Program Level record. We selected a sample of forty students who received a Federal Direct Loan or a Pell Grant and whose enrollment status changed during the year and noted the following exceptions: - For nine students, the effective date of the student withdrawal at the Campus Level record did not match the effective date at the Program Level record. We noted that the nine students with discrepancies were students who withdrew during the semester, not students who graduated. There were a total of 80 students who withdrew during the fiscal year. Cause: The University uses the National Student Clearinghouse (NSC) to process enrollment status changes in NSLDS. For the students where the effective dates were not accurately reported at both the Campus Level and the Program Level, there was a processing error during the submission to the NSC which was not timely identified by the University. While management had a control in place to ensure accurate enrollment information was submitted on a timely basis, the control did not include a post-submission review to ensure the Campus Level record and Program Level record matched. Effect: The effective dates of withdrawal for certain students who withdrew during the semester did not match between the Campus Level record and Program Level record. This inaccuracy could impact the student repayment status. However, this discrepancy did not have an impact on the timeliness of the selected student entering repayment on their loans. Questioned Costs: There were no questioned costs related to this finding. Recommendation: We recommend that the University strengthen its policies and procedures to ensure that student enrollment changes are accurately reported to NSLDS between Campus Level and Program Level records. The University should enhance their post-submission review to include a periodic review of the accuracy of the student status change reporting. View of Responsible Officials: Management agrees with the finding. Management performed a review of all students reported to the NSLDS for the fiscal year. Management identified a total of 61 students who withdrew, out of a total population of 80 students who withdrew during the fiscal year, where the effective date of the withdrawal did not match the Campus Level record and Program Level record. The University understands the importance of accurate and timely reporting of enrollment status and has corrected the student Campus Level and Program Level records in the NSLDS system for all 61 students. In addition, management instituted a control whereby they will periodically perform a post-submission review of the data submitted to the NSLDS and correct any discrepancies prior to the end of the fiscal year. This review will be documented by the student Financial Services office and then reviewed by the Controller or Chief Financial Officer.