Finding Text
Federal Program Information: Federal Pell Grant Program (ALN: 84.063), Federal Direct
Student Loans (ALN: 84.268), Teacher Education Assistance
for College and Higher Education Grants (ALN: 84.379)
Criteria or Specific Requirement
(Including Statutory, Regulatory
or Other Citation):
N. Special Tests and Provisions - Enrollment Reporting: The
University is required to update students’ statuses on the
National Student Loans Data System (“NSLDS”) website if they
graduate, withdraw or have an increase/decrease in
attendance level during the year within 60 days of the date
the University becomes aware of the change in enrollment
status. 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
significant data elements under the Campus-Level Record and
Program-Level Record that ED considers high risk.
Additionally, institutions are responsible for timely reporting,
whether they report directly or via a third-party servicer. As
with any school/servicer arrangement for the administration
of the Title IV programs, if the school uses a third party to
meet the NSLDS enrollment reporting requirements it is the
school that must ensure that enrollment information is
submitted timely, accurately, and completely.
Per the Federal Student Aid Handbook, schools are required
to certify enrollment for all students who are included on
their roster file scheduled at least every two months, and
within 15 days of the date that NSLDS sends a roster file to
the school or its third-party servicer. Any errors identified
and returned by NSLDS in an Error/Acknowledgement file
should be corrected and resubmitted within 10 days.
Condition: The University did not submit an accurate status change
notification or timely notification to the NSLDS website for
certain students who graduated, withdrew, or had an
increase/decrease in attendance level during the year.
Additionally, the University’s fiscal year SCHER1 report
included multiple instances in which error records were not
corrected within the required timeframe.
Cause: Administrative oversight with respect to enrollment reporting
compliance requirements.
Effect or Potential Effect: The University is not in compliance with enrollment reporting
compliance 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 as a result of our
procedures:
• For 1 of 40 students sampled whose status changed
during the year, the University failed to accurately
report all significant data elements under the Campus-
Level Record in a timely notification to the NSLDS
website.
• For 4 of 25 students sampled whose status changed
during the year, the University failed to accurately
report all significant data elements under the
Program-Level Record in a timely notification to the
NSLDS website.
• For 5 of 6 Error Reports tested, error records identified
in Error/Acknowledgment files were not corrected
within the required timeframe.
Identification of Repeat Finding: This is a repeat finding from prior year. This was reported as
Finding 2022-003 in the prior year schedule of findings and
questioned costs.
Recommendation: We recommend that the University properly follow its policies
and procedures over enrollment reporting to ensure that all
status changes are submitted to the NSLDS website within the
required timeframe and that error records are corrected and
submitted timely, consistent with federal regulations.
Views of Responsible Officials and
Planned Corrective Actions:
With regards to Error #2023-007, some of the findings were
related to incorrect reporting of graduation status,
graduation date, and program begin date. We identified that
some dates had not been correctly entered. We are working
with our student information system software consultants and
National Student Clearinghouse personnel to ensure that all
staff understand reporting requirements, and we have taken
steps to correct errors before we submit reports.
Another finding was that error records were not corrected
within the required timeframe. There has been a change in
staffing in the office since the time periods of the audit
findings, so a different person is now correcting error records.
That individual has been made aware of the audit findings and
has committed to work with office personnel and National
Student Clearinghouse on correcting reported errors
promptly.