Special Tests and Provisions – Enrollment Reporting
Information on Federal Program(s) - Student Financial Assistance Cluster (Federal Assistance Listing #84.063 and #84.268)
Criteria or Specific Requirement - 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 SFA 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; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify 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 which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Campus Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month.
Program Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including OPEID number, CIP code, CIP year, credit level, program enrollment status, program enrollment effective date, program length, and program begin date.
Error Records: After the institution sends the Enrollment Reporting Roster Submittal to NSLDS, NSLDS evaluates the Enrollment Reporting Roster Submittal 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 – The conditions at the campus level, program level and error records were as follows:
Campus Level: For 5 students that had enrollment status changes, the Institute did not subsequently certify updated enrollment status to NSLDS within the required time frames. For 2 of these 5 students, the Institute did not report the correct type of enrollment status change.
Program Level: For 10 students, the Institute did not correctly report all enrollment status data elements to NSLDS as follows:
• For 1 of these 10 students, the enrollment status was reported as withdrawn instead of graduated.
• For 1 of these 10 students, the program length and the program begin date data elements were incorrectly reported.
• For the remaining 8 of 10 students, the program begin date data element was incorrectly reported.
Error Records: For 1 error record related to program length, the Institute did not correct the record reported to the NSLDS within the required time frames.
Cause - Administrative oversight in internal controls over enrollment reporting requirements.
Effect or Potential Effect - The Institute was not in compliance with the enrollment reporting requirements.
Questioned Costs – None.
Context – The context at the campus level, program level and error records is as follows:
Campus Level: 5 of 17 students selected for campus level testing.
Program Level: 10 of 17 students selected for program level testing.
Error Records: 1 of the error records occurring during the current fiscal year.
Indication of Repeat Finding - This is a repeat of prior year finding 2022-001.
Recommendation – We recommend that the Institute enhances its procedures and its internal controls over enrollment reporting requirements.
Views of Responsible Officials – The Institute agrees with this finding. The finding is related to required enrollment information being reported to National Student Loan Data System by the registrar’s office. The errors noted in 2023-001, as well as 2022-001, were primarily related to a lack of internal systems, staff, and expertise in the reporting requirements. A new registrar was hired September 2023, and much work has been done to increase staffing and technology support for the office. The administration is working with the registrar’s office to implement controls to reduce errors and improve timeliness. However, reporting requirements are rigorous, and there will always be challenges. With new systems only recently put in place and the staffing issues continuing in FY23-24, this finding may be noted again next year.