Finding Text
2024-001 National Student Loan Data System (NSLDS) Program and Enrollment Reporting
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing Numbers: 84.007, 84.268, 84.063, 84.033
Award Period: July 1, 2023 – June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states that:
1) Schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report the student status every 60 days at a minimum throughout the academic year. If the student withdrew or graduated from the institution, the status must be reported twice.
2) Schools must have some arrangement to report student program enrollment effective date.
Condition:
During our testing, we noted:
1) Ten of 40 students were not reported within 60 day timeframe.
2) Sixteen of 40 students were reported to NSLDS with an incorrect program enrollment effective date.
Questioned costs: None.
Context:
During our testing we noted the College did not have a proper procedure in place for:
1) Unofficial withdrawals or students who withdrawal during the add/drop period in order to ensure the enrollment effective date reported to NSLDS matches the College’s records..
2) Students who withdrew during the add/drop period in order to ensure the student’s program status was reported.
Cause:
The College did not have a process in place to ensure:
1) the effective date reported to NSLDS matches the effective date of the student’s last date of attendance.
2) the student's program enrollment effective date was being accurately reported.
Effect:
1) The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By not reporting a correct effective date, the grace period begin date for the student will be incorrect.
2) The program enrollment effective date reported to NSLDS is used to determine the student’s 150% limit for direct loans as well as when grace period should begin. By not reporting the correct status, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect.
Repeat finding: No.
Recommendation:
We recommend the College reevaluate its procedures and review policies surrounding reporting:
1) status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the College’s last date of attendance.
2) program enrollment effective dates to NSLDS.
Views of responsible officials: Management agrees with the findings and has developed a plan to correct the finding.