Finding Text
Program Information: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loan Program (ALN 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035). Although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). 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 information. There are two categories of enrollment information, “Campus Level” and “Program Level,” each with separate record types requiring accurate reporting. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (“SAIG”) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. After the institution submits the Enrollment Reporting roster to NSLDS, NSLDS evaluates the Enrollment Reporting roster and provides the institution an Error/Acknowledgement file. If errors are identified, institutions have 10 days to correct the errors and resubmit to NSLDS.
Condition: For certain students selected for testing who graduated or withdrew during the year, the University did not submit status change notification or failed to submit timely notification to the NSLDS website. Additionally, the University’s fiscal year SCHER1 report, included multiple instances in which error records were not corrected within the required timeframe.
Cause: Lack of internal controls and administrative oversight.
Effect or Potential Effect: The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs: None.
Context: We noted the following exceptions:
• For 9 of 60 campus level records tested, the University failed to notify NSLDS of the change in student enrollment.
• For 51 of 60 campus level records tested, the University did not certify the enrollment status within the required timeframe.
• For 10 of 60 program level records tested, the University failed to report the enrollment change to NSLDS.
• For 50 of 60 program level records tested, the University did not certify the enrollment status within the required timeframe.
Additionally, error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple errors during the 2021 fiscal year.
Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2020-011 in the prior year schedule of findings and questioned costs.
Recommendation: We recommend that the University follow its internal controls, policies and procedures over the applicable compliance requirements of the Enrollment Reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe.
Views of Responsible Officials and Planned Corrective Actions: Enrollment reporting is required for all schools participating in Title IV aid programs. Schools are required to certify enrollment for all students included on their roster files. SAU was without a Registrar during the 2019-2020 award year however, in August 2020 this position was filled. In addition more staff was hired to assist in these reporting functions. The Registrar had to submit the missing reports before submitting new ones. This backlog led to late status changes being reported. Primarily, the University implemented a comprehensive ERP software tool, Ellucian Colleague in FY2021 and FY2022 and hired more staff. The built-in internal control structure which includes access to enrollment reports and data coupled with a complete reconciliation process with the Office of Financial Aid, Office of the Registrar and Student Accounts will prevent this from recurring. Professional development is encouraged for the University’s staff to stay current on compliance, regulatory and legal guidelines and adopt industry best practices.