Finding 503018 (2024-001)

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loans, Assistance Listing Number 84.268; May 31, 2024 Award Year; U.S. Department of Education Criteria or Specific Requirement Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves-of absence. It is the institution’s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (“NSLDS”). (NSLDS Enrollment Reporting Guide September 2021, and 34 CFR 685.309(b)). Condition Found Of the 17 students selected for enrollment reporting testing, 4 students within the sample were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Cause The College has a medical withdrawal policy as well as a voluntary withdrawal policy. These are not temporary interruptions of a student’s studies with an intent to return but are full withdrawals and reported as such. Students who later decide that they do want to return to the College must complete the readmission application. For all 4 students, the College’s internal code used to record students who were leaving for medical reasons triggered a leave of absence coding to NSLDS, not a withdrawal code as intended by College policy and were therefore missed by the School in the initial reporting to NSLDS. Management later identified the incorrect coding and reported these students as withdrawn but this was done outside of the required timeframe. Effect or Potential Effect For students entering into repayment, the change in enrollment effective date and status determines when the grace period begins and how soon a student must begin repaying loan funds. Therefore, timely and accurate notification to NSLDS is important. Questioned Costs None. Identification as a Repeat Finding Not a repeat finding. Recommendation The College should evaluate the reporting systems to ensure that withdrawals are not automatically reported as leaves of absence. The College should also consider a secondary review of status changes for accuracy prior to submission to NSLDS to ensure accurate and timely reporting. Views of Responsible Officials and Corrective Action See Corrective Action Plan.