Finding Text
Finding 2023-001
Special Tests and Provisions - Enrollment Reporting Compliance and Internal Control (Significant
Deficiency)
U.S. Department of Education - Student Financial Assistance Cluster
Federal Direct Student Loans (Assistance Listing #84.268) Federal Award Number: P268K201866
Federal Pell Grant Program (Assistance Listing #84.063) Federal Award Number: P063P191866
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 student 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 website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS maintains as the most recently certified enrollment information. 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. Required program-level data includes, but is not limited to: *Program enrollment status; *Program enrollment effective date; *Program begin date; *Published program length and measurement; and *Classification of Instructional Program (“CIP”) code. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change).
Context and Condition: From a selection of forty (40) students tested, we identified the following instance of noncompliance: 1) For seven (7) students, the change in status was not submitted timely (within 60 days) to the NSLDS
per the student records and internal documentation provided by the University.
Cause: For students who withdrew at the end of the Spring 2023 term, but completed the full Spring semester, management did not report the status change until the start of the Fall 2023 term. Management determined that these students had the option to change their mind and enroll in Fall 2023 classes without being readmitted since these students did not miss a mandatory term. Therefore, students who completed the Spring 2023 term and subsequently withdrew were not reported to the NSLDS timely.
Effect: The enrollment status for seven (7) students were not reported timely to the NSLDS.
Questioned Costs: None identified.
Identified as a Repeat Finding: No.
Recommendation: The University should update their policy regarding the reporting of Spring term withdrawals to ensure that these enrollment changes are reported timely to the NSLDS.
Views of Responsible Officials: Molloy University understands the finding and has devised a process to ensure students who submit a request to withdraw after the completion of the current semester get processed manually in NSLDS once grades for the current semester have been submitted. This process supersedes our past practice of utilizing attendance data from faculty to verify that students are not attending prior to officially withdrawing them from the University. To aid in this updated practice, a separation coversheet will be utilized to provide a checklist of steps and internal signatures that will be completed for each student who indicates they wish to withdraw from the University. This will ensure that the withdrawal status is promptly provided within the required timeframe.