Finding Text
Significant Deficiency – Enrollment Reporting Program: Student Financial Assistance Cluster Federal Agency: U.S. Department of Education Assistance Listing Number (ALN): Various Federal Award Identification Number: Various Federal Award Year: June 30, 2026 Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition/Context: For one of 25 students who were tested, the student’s withdrawal status was reported to NSLDS late, 71 days after the date of determination. For one of 25 students who were tested, the student’s graduation date was reported incorrectly to NSLDS. The College’s controls over enrollment reporting did not detect the errors. The sample was not a statistically valid sample. Cause: The College's enrollment reporting process relies on manual identification and follow-up of certain enrollment changes and did not include an effective reconciliation to ensure that all reportable changes were submitted and that the enrollment statuses and effective dates ultimately reflected in NSLDS agreed with the College's underlying institutional records. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update and verify student enrollment statuses, effective dates of the enrollment status and the anticipated completion dates, then the Title IV student loan records will be inaccurate and the U.S. Department of Education may not correctly start grace periods, repayment, etc. Questioned Costs: Not applicable. Recommendation: The College should review and update its enrollment reporting policies and procedures to establish documented controls that ensure all reportable enrollment changes, including changes requiring manual reporting, are identified and submitted within the required timeframes. The College should also reconcile enrollment statuses and effective dates transmitted through the National Student Clearinghouse to the information ultimately reflected in NSLDS and timely investigate and correct rejected, omitted or inconsistent records. Management's Response: Management agrees with the finding and is committed to strengthening its procedures to avoid similar issues in the future. Beginning in September 2026, a second and new Registrar’s Office staff member will be trained in to complete an additional review of the National Student Clearinghouse status for all students withdrawing after a particular semester. This secondary review will be completed at the end of January and at the end of June to ensure the 60-day reporting period is met. The College will manually update the graduated enrollment status start date for the impacted student to the correct date through the National Student Clearinghouse. The College will reach out to the National Student Clearinghouse to determine why the graduation date that was reported on the degree file does not match the date that was used when the student’s enrollment record was updated by the Clearinghouse using the graduated enrollment status from the degree verified process.