Finding Text
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. In addition, per the Uniform Guidance 2 CRF 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: During our enrollment reporting testing, we noted the University did not update student enrollment data correctly or timely.
Questioned costs: None reported.
Context: During our testing, we noted that the University did not accurately report to National Student Loan Data System (NSLDS) the enrollment status for 2 of the 40 students tested. The enrollment effective date of 6 of the 40 students tested was not reported correctly to NSLDS. The status change of 28 of the 40 students tested was not reported timely to NSLDS. The enrollment was not certified every 60 days for 1 of the 40 students tested. The program enrollment effective date of 3 of 40 students tested did not match the institutions records. The program enrollment status of 2 of 40 students tested did not match the status per the institution.
Cause: The University did accurately report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Additionally, NSC did not report all status changes timely which caused the University to not meet the requirements.
Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS.
Repeat Finding: No.
Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely.
View of Responsible Official: The University agrees with the finding.