Finding Text
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Enrollment Reporting – The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements, it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.
According to the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days.
Condition: For a certain student whose status changed during the year, the University failed to submit a timely notification to the NSLDS website. Additionally, the University’s fiscal year SCHER1 report included multiple instances in which error records were not corrected within the required timeframe.
Cause: Administrative oversight and insufficient internal control.
Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements.
Questioned Costs:
None.
Context: For 1 of 40 program level records tested, the University failed to report an enrollment change to NSLDS. Additionally, error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple repeat errors during the 2024 fiscal year.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2023-001 in the prior year schedule of findings and questioned costs.
Recommendation: We recommend that the University implement procedures to ensure that that all status changes are submitted to the NSLDS website within the required timeframe and that error records are corrected and submitted timely.
Views of Responsible Officials:
Liberty University acknowledges that its FY24 single audit identified one instances where students’ enrollment reporting was not updated in a timely manner in accordance with U.S. Department of Education (ED) requirements. Additionally, Liberty acknowledges that there were numerous instances where Clearinghouse error reports identified students with repeat errors which were not corrected within the required timeframe. Liberty has invested significant effort into ensuring its enrollment reporting process is handled compliantly and within alignment with ED’s best practices. Liberty’s Registrar’s Office created a new Director of Clearinghouse Reporting position, which was filled in May 2024, to specifically address any enrollment reporting deficiencies. This new position is responsible for monitoring Clearinghouse feeds and any associated error reports and works closely with Liberty’s Financial Aid and Information Technology (ADS) offices to ensure enrollment reporting compliance.
Liberty has continued the work of developing a more comprehensive quality control (QC) process. The QC process utilizes National Student Loan Data System (NSLDS) reporting and compares it to Banner, Liberty’s system of record, to identify students who may not have been accurately reported for a variety of reasons. This process relies on the NSLDS Enrollment History Report -SCHHS1, which is a very large and somewhat unstable report due to the volume of enrollment reporting that Liberty completes. Because of the complexities of this report, and the many changes that occurred with NSDLS updates to reporting, Liberty had to file numerous inquiries with ED to be able to run a functioning report, including an NSLDS ticket submitted on September 20, 2022, (Case # 220920-000436). The report was first successfully run in January 2024, though it took several months for Liberty to build QC reports internally that could leverage the report results. Liberty seeks to run the report at least once per month, though failures at NSLDS are unfortunately somewhat common and require escalation to ED for resolution.