Finding Text
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 time
frame 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: The University was not able to provide the Auditor with a population of student
status changes for which to sample from to complete the enrollment reporting testing.
Cause: The University does not have a consistent procedure for reporting student status changes
accurately and timely and is unable to generate a report of student status changes to verify that the
appropriate reporting requirements were followed.
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.
Questioned Costs: Not applicable.
Recommendation: It is recommended that policies and procedures are put in place to verify that the
correct program level effective dates and enrollment statuses are reported to the NSLDS within the
required time frames after the information has been submitted through the servicer (NSC). This could
include a review of withdrawal or graduation dates compared to the effective dates and enrollment
statuses reported to the NSLDS to make sure they are accurate.
Management Response: The University is implementing a new student information system which is
expected to improve this and other processes. Implementation is anticipated to be complete by July
2024.