Finding Text
FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant
Deficiency in Internal Control over Compliance (See "Schedule of Findings and Questioned Costs" for table). Criteria – 34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment
report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after
the date the school 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 school, 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 school and who received a loan under title IV of the Act
has changed his or her permanent address. Condition/context – A sample of 18 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 the College’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 18 students who had a change in address, graduated, or withdrew, one was not reported to the
NSLDS within the required timeframe.
Cause – The College does not have formally documented policies requiring information submitted to
the NSLDS be reviewed for completeness and accuracy, or policies for monitoring reporting
deadlines.
Effect – The NSLDS database did not include accurate information until the point at which it was
corrected. 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 the College establish a formal policy requiring a review of
student status information submitted to the NSLDS, by a third-party intermediary on the College’s
behalf, for completeness and accuracy. We also recommend the College establish a cadence of
monitoring reporting deadlines, particularly those around classes of graduating students.
Views of responsible officials and planned corrective actions – The College acknowledges the
delay in transmitting a student's graduation status to the Clearinghouse/NSLDS. This was due to a
retroactive graduation date change following a thesis review. We are revising our internal policy to
ensure timely submission of enrollment status changes and will implement sample checks after each
transmission date.