Finding Text
Special Tests and Provisions – Enrollment Reporting: Significant Deficiency
in Internal Control over Compliance (See table in Schedule of Findings and Questioned Costs). Criteria – 34 CFR section 668.22(c): For a student who ceases attendance at an institution that is not required to take attendance, the students’ withdrawal date is:
(v) if a student does not return from an approved leave of absence, the date that the institution
determines the student began the leave of absence; or
(vi) if a student takes a leave of absence that does not meet the requirements of an approved
leave of absence, the date that the student began the leave of absence. Condition/context – A sample of 70 federal aid recipient students were selected from system-generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per Art Center’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes.
Of the 70 students who had a change in address, graduated, or withdrew, 5 withdrawn students had an
incorrect effective date reported to NSLDS.
Cause – For students who did not return from an approved leave of absence or those that took a leave of absence that did not meet the requirements of an approved leave of absence, predominantly being leaves of absences in excess of 180 days in any 12-month period, Art Center did not consistently report to the NSLDS the effective date of the withdrawal as the date the student began the leave of absence. Effect – The NSLDS database did not include accurate information for when the student was considered to be withdrawn from Art Center. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat finding – This is not a repeat finding. Recommendation – We recommend Art Center establishes a formal policy requiring students who do not
return from an approved leave of absence, or students who begin a leave of absence planned to span more than 180 days in any 12-month period, be immediately reported to the NSLDS as a withdrawn student effective the date their leave of absence began.
Views of responsible officials and planned corrective actions – Art Center management acknowledges that some incorrect Enrollment Reporting data were transmitted through the National Student Clearinghouse (NSC) to the National Student Loan Data System (NSLDS). However, this error was not due to any insufficiencies in ArtCenter’s policies; rather, it was due to a technical misunderstanding regarding which data fields are extracted for NSC reporting. More specifically, if a student takes a second Leave of Absence (LOA), it had been ArtCenter’s practice to record the student’s actual last date of attendance in the “Last Date of Attendance” field on the Student Hiatus Summary screen in Colleague, but the file that NSC requires schools to use to extract reporting data does not pull
data from this field; as a result, the resulting reported information was inaccurate. Art Center now will modify its process to record the date of a student’s first LOA in the “Start Date” field for the second LOA so that the correct data will be extracted and submitted to NSC. Art Center also will be conducting appropriate testing to ensure the adequacy of this process modification.