Finding 500270 (2023-001)

Until August 2023, the College followed its regular schedule for updating students’ enrollments in the NSLDS enrollment reporting system. The updates were always performed on time every 30 days at the beginning of each month. The process began each month with NSLDS generating a list of students that needed to be updated. Only students who received Title IV funds appeared on the list. Our procedure to update the students in NSLDS was done manually, and it involved running a report on the NSLDS website to update each student individually with his or her corresponding enrollment status. Sometimes students did not appear in the NSLDS database during the semester that they started until months after they started. The timing of appearance in the database depended on when the student’s aid was disbursed. Once the student appeared in the database, the College would update the enrollment and indicate that the effective date of the status went back to a date before the student appeared on the database. The College believes this is the reason why it appears that it was late in reporting the two students cited, since they did not appear on the database at the beginning of the term when they started classes but rather at a later date. The College stopped reporting manually to NSLDS as of August 2023 and started reporting electronically via the Clearinghouse in September 2023. This process involves reporting on all students, not just those on the NSLDS database. For example, the auditors identified a student who was reported on time to the Clearinghouse pursuant to that new process, but who did not appear on the NSLDS database until almost 3 months later. The new process allowed the auditors to see the reporting trail. The College believes this same situation happened to the two students cited. Unfortunately, the manual process of reporting to NSLDS does not provide the same audit trail as does the new electronic process using the Clearinghouse. Now that the College is using the Clearinghouse process, this issue should not recur.