Finding 529407 (2024-004)

2024-004 – Enrollment reporting Cluster: Not applicable Sponsoring Agency: Department of Education Award Name: Pell Grant Program and Federal Direct Student Loans Award Number: Various Assistance Listing Title: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.033 and 84.268 Award Year: 2023-2024 Pass-through entity: Not applicable Criteria 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 (NSLDS). 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. (34 CFR 685.309) Additionally, when a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student 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 a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). (34 CFR 685.309) Condition Through testing of 100 students across four campuses of enrollment status changes, we noted the following: • Campus 1 o Five out of 25 student selections were not reported to NSLDS within 60 days of the effective change date. On average, they were reported 6 days late. o 11 out of 25 student selections had a graduation effective date that was not reported accurately in the program level information. o Three out of 25 student selections had status change effective dates per the student file that did not match with either program level information, campus level information, or both. • Campus 2 - Two out of 25 student selections were not reported to NSLDS within 60 days of the effective change date. On average, they were reported 80 days late. • Campus 3 o 3 out of 25 student selections were not reported to NSLDS within 60 days of the effective change date. On average, they were reported 73 days late. o Three out of 25 student selections had a graduation effective date that was not reported accurately in the program level or campus level information. Two of these students were also never reported as “graduated” to NSLDS, but rather remained noted as “withdrawn”. Additionally, one out of 25 student selections had a change in status that was not reflected correctly in the program level of information (the status date was 15 days prior to the actual status change date). • Campus 4 o Four out of 25 student selections were not reported to NSLDS within 60 days of the effective change date. On average, they were reported 23 days late. o For 24 out of 25 student enrollment status change selections, the effective date of the status change date did not agree to the program level information. Additionally, for two out of 25 selections, the status change date did not agree to the campus level information. Cause • Campus 1 o The Campus takes approximately four weeks to confer degrees to graduated students, but instead of reporting the student first as withdrawn and then switching the student status to graduated upon degree conferral, the campus waited until the degree conferral process was complete to report. As such, more than 60 days had elapsed before either a withdrawn or graduation status was reported to NSLDS. o Campus personnel noted that they report the actual graduation date at the campus level, but the date reported at the program level is the last day of instruction for the term. This cadence in reporting results in the different dates being captured versus the actual graduation date being consistent in both the program level and campus level information. o Campus personnel noted that the date inconsistencies are due to data