Finding Text
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063; 84.268
Award Period: July 01, 2022 – June 30, 2023
Type of Finding:
Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion)
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 of enrollment information at both the program and campus-level detail, we noted the following:
15 out of 40 students were reported to the NSLDS with an incorrect campus-level enrollment status
17 out of 40 students were reported to the NSLDS with an incorrect effective date per campus-level records
25 out of 40 student enrollment effective statuses were not reported to the NSLDS in a timely manner
1 out of 40 students’ published program lengths reported to the NSLDS was not correct
6 out of 40 students’ program begin dates were reported incorrectly to the NSLDS.
21 out of 40 students were reported with an incorrect effective date and effective status on the program-level detail in the NSLDS
Cause: The University uses a third-party servicer to submit their enrollment reports to the NSLDS. The enrollment information that was sent to the third-party servicer did not have enrollment information that followed the NSLDS guidelines. The University was calculating student's anticipated time for program lengths on a student-by-student situation instead of using published or common lengths for students in the program. The University was also not reporting summer term status changes.
Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin.
Repeat finding: Yes, 2022-005.
Recommendation: We recommend the University evaluate its procedures and review regulations set by the Department of Education around reporting requirements to the NSLDS to ensure the University is in compliance with enrollment reporting requirements.
Views of responsible officials: Management agrees with the finding.