Finding Text
2023 – 002 – National Student Loan Data System (NSLDS) Reporting
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Federal Assistance Listing Number: 84.268
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309).
Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR 682.610).
Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS.
Questioned costs: None.
Context: During our testing, we noted the following out of our sample of 40 students tested:
3 students had effective dates at the campus level that did not agree between the University’s records and the NSLDS
1 student had the incorrect status reported at the campus level
3 students were not reported to the campus level record in the NSLDS in a timely manner. At a minimum, schools are required to certify enrollment every 60 days.
1 student had an incorrect status and effective dates reported at both the campus and program levels reported to the NSLDS but status was reported as ‘no record found’. Effective dates reported did not match that of the University.
Cause: The University’s process in place for timely reporting and updating effective dates within the Banner system were not functioning properly.
Effect: Inaccurate reporting to the NSLDS can impact when students enter repayment periods or affect their interest rates.
Repeat Finding: Yes, 2022-001.
Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations.
Views of responsible officials: Management agrees with the finding.