Finding Text
Finding 2024-001 – N. Special Tests and Provisions – Enrollment Reporting
Information on Federal Program(s) – Federal Direct Student Loan Program (Federal Assistance Listing
#84.268)
Criteria or Specific Requirement - Institutions are required to report enrollment information under
the Pell grant and the Direct and Federal Family Education Loan (FFEL) loan programs via the
National Student Loan Data System (NSLDS) (OMB No. 1845-0035), although FFEL loans are no longer
made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would
require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610;
Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs
depends heavily on the accuracy and timeliness of the enrollment information reported by
institutions. Institutions must review, update, and certify student enrollment statuses, program
information, and effective dates that appear on the Enrollment Reporting Roster file or on the
Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the
financial aid administrator can access for the auditor. The data on the institution’s Enrollment
Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified
enrollment. There are two categories of enrollment information, “Campus Level” and “Program
Level,” both of which need to be reported accurately and have separate record types. The NSLDS
Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment
details using the NSLDS Enrollment Reporting Process.
Campus Level: Institutions are responsible for accurately and timely reporting certain significant
data elements under the Campus-Level Record that the U.S. Department of Education considers
high risk, including enrollment status, which is the student’s enrollment status as of the reporting
date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence
(A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At
a minimum, institutions are required to certify enrollment every 60 days or every other month.
Program Level: Institutions are responsible for accurately and timely reporting certain significant
data elements under the Program Level Record that the U.S. Department of Education considers
high risk, including OPEID number, CIP code, CIP year, credit level, program enrollment status,
program enrollment effective date, program length, and program begin date.
Condition – The University did not accurately report a student’s significant data elements under the
Program-Level record on the NSLDS website.
Cause – Administrative oversight in internal controls over enrollment reporting requirements.
Effect or Potential Effect – The University was not in compliance with the enrollment reporting
requirements.
Questioned Costs – None.
Context – 1 of 25 students selected for testing.
Indication of Repeat Finding – No similar finding identified during the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls
over enrollment reporting requirements.
Views of Responsible Officials – Management acknowledges the finding regarding the inaccurate
reporting of student data elements under the Program-Level record on the NSLDS website. To
address this issue, the University has implemented a corrective action plan that includes updating
our reporting frequency and enhancing our data review processes:
Updated Reporting Frequency: As of January 2025, the University now includes the non-compulsory
terms, summer 1 and winter sessions, in its reporting. Previous institutional practice did not include
reporting program level data for these terms given that said terms do not involve federal financial
aid. This change ensures that all Program-Level data, regardless of federal financial aid
involvement, is accurately reported.
Secondary Check Process: Each month, the Compliance Officer will review a sample of 100 students
from NSLDS to verify significant data elements, including program enrollment effective dates. After
the initial review, the Compliance Officer will summarize the findings and share them with the
Associate Registrar and Registrar for a secondary review. Any necessary edits will be made,
followed by a review of an additional 25 students to ensure accuracy.
We believe these corrective action steps are critical to ensuring accurate reporting and preventing
this issue in the future.