Finding 2023-001 - Special Tests and Provisions - Enrollment Reporting
U.S. Department of Education - Student Financial Assistance Cluster
Federal Pell Grant Program (84.063)
Federal Direct Loan Program (84.268)
Federal Award Year: 2022-2023
Criteria:
Under the Federal Pell Grant Program and U.S. Department of Education (ED) loan programs, institutions are required to report enrollment information via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035). 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 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. 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.
Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date.
Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date.
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 the Department of Education (“ED”) via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website
(Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309).
Enrollment information is used to determine the borrower’s eligibility for in-school status, deferment, interest subsidy, and grace period. Enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported. The enrollment information is merged into the NSLDS database and reported to guarantors, lenders, and servicers of student loans.
Context:
The University distributes Direct Loans and Pell grants to students and is thus required to report the Campus-Level and Program-Level enrollment information of these students to NSLDS both timely and accurately.
Condition:
We identified the following instances of noncompliance from a selection of forty (40) graduated students selected for enrollment reporting testing:
• Two (2) students whose graduation effective dates were reported incorrectly. Both students, who were awarded a combined $37,820 in Direct Loans and Pell grants, graduated effective May 9, 2023, but were reported to NSLDS as graduated effective June 19, 2023, and July 6, 2023.
Cause:
For both students, their undergraduate program graduation effective dates for the Spring 2023 semester (May 9, 2023) were originally reported correctly to the National Student Clearinghouse. However, both students were subsequently enrolled in a Summer 2023 semester graduate program and due to a bug within Ellucian Colleague, the University’s ERP system, their undergraduate program graduation effective dates were overwritten by their graduate program start dates (June 19, 2023, and July 6, 2023) upon the University’s submission of the Summer 2023 enrollment file to the National Student Clearinghouse.
Effect:
The University did not accurately report graduation effective dates for two (2) students.
Questioned Costs:
None noted
Identified as a Repeat Finding:
No
Recommendation:
The University should strengthen policies and procedures to ensure that enrollment effective dates are reviewed and submitted accurately to NSLDS.