Finding Text
Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the
Secretary, institutions must update all information included in the report and return the report to the Secretary:
(i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the
Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60
days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a
loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for
enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to
enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is
enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent
address.
Condition: Current controls did not prevent inaccuracy of the student loan records.
Cause: The Foundation failed to follow its procedures for reporting student status changes correctly and/or
within the required timeframe.
Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment
information reported by institutions. If an institution does not review, update, and verify student enrollment
statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV
student loan records will be inaccurate.
Questioned costs: Not applicable.
Context: For two out of a sample of 25 students, the effective date reported to NSLDS for a status change
student was not updated in a timely manner at the program level. The sample was not a statistically valid
sample.
Recommendation: It is recommended that policies, procedures and effective controls are put in place to
verify that the correct program level effective dates and enrollment statuses are reported to the NSLDS within
the required timeframes after the information has been submitted through the servicer (National Student
Clearinghouse). This could include a review of withdrawal, change in status, or graduation dates compared to
the effective dates and enrollment statuses reported to the NSLDS to make sure they are accurate.
Management Response: The Foundation will ensure that policies and procedures are in place to both verify
the correct program level effective dates and enrollment statuses are reported timely and are also reviewed
by a second person to ensure the accuracy of the data as well as the timeliness of reporting the data. The
initial reporting and the subsequent reviews will be documented with names of staff and dates of
work/reviews.