Finding 2024-001 – N. Special Tests and Provisions – Enrollment Reporting
Information on Federal Program(s) – Federal Pell Grant Program (Federal Assistance Listing #84.063)
and Federal Direct Student Loans (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full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z).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 conditions at the campus level and program level were as follows:
Campus Level: For certain students that had enrollment status changes, the Institute did not subsequently certify updated enrollment status to NSLDS within the required time frames and/or the Institute did not report the correct type of enrollment status change.
Program Level: For certain students that had enrollment status changes, the Institute incorrectly reported enrollment status, the program begin date, and/or the program enrollment effective date.
Cause - Administrative oversight in internal controls over enrollment reporting requirements.
Effect or Potential Effect - The Institute was not in compliance with the enrollment reporting requirements.
Questioned Costs – None.
Context – The context at the campus level and program level is as follows:
Campus Level:
• For 13 of 17 students selected for testing, the Institute did not subsequently certify updated enrollment status to NSLDS within the required time frames.
• For 4 of 17 students selected for testing, the Institute did not report the correct type of enrollment status change.
Program Level:
• For 4 of 17 students selected for testing, the enrollment status was incorrectly reported.
• For 2 of 17 students selected for testing, the program begin date was incorrectly reported.
• For 3 of 17 students selected for testing, the program enrollment effective date was incorrectly reported.
Indication of Repeat Finding - This is a repeat of prior year finding 2023-001.
Recommendation – We recommend that the Institute enhance its procedures and its internal controls over enrollment reporting requirements.
Views of Responsible Officials – The Institute agrees with the finding. The sudden departure of the former registrar in early September 2023 placed a gap in services and processes on the newly appointed registrar that took several months to resolve. There was a lack of continuity in reporting due to technological deficiencies that required a team of resources beyond the one office. Once technological deficiencies were addressed, reporting had not been performed since September 2023 and the first enrollment report submitted under the new registrar caused data issues as it was for a new semester (Spring 2024). The corrective action plan includes:
• Continued student information system (“SIS”) training with Ellucian-Banner software personnel to include permissions-based access to data and software upgrades.
o Access to data is permissions-based and our IT department monitors this to make sure registrar staff has the correct access.
• Sweet Briar has authorized additional training for Registrar staff who are not familiar with the Banner SIS to ensure proper coding of student records.
• Working with the National Student Clearinghouse (“NSC”) to resolve issues with data uploads and training on how to resolve errors.
• Consistent reporting per the NSC transmission schedule so data is reported correctly and timely.
• Consistent reporting of separated students (withdrawn and graduated) within 30 days of departure.
• The registrar has conducted several reviews of SIS databases and tables to ensure the data is consistent with the Crosswalk provided by the National Student Clearinghouse, especially in enrollment status based on hours taken in a semester.
• Creation of a manual with step-by-step directions on how to generate a report, submit the data to the NSC, and how to resolve errors on the NSC portal so the loss of a key person in the registrar’s office assures compliance with reporting and continuity.