Finding Text
Criteria
According to 34 CFR 685.309(b)(2):
Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that –
(i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has 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
(ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address.
The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients.
According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2018:
Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer.
Condition
The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, we noted 5 students, out of a sample of 10, that had incorrect effective dates reported to NSLDS. We noted 5 students, out of a sample of 10, were not reported to NSLDS within the required timeframe, and 2 out of a sample of 10, that were not reported at all to NSLDS.
Cause
The College did not have adequate procedures in place to ensure that students with status changes had their effective date correctly reported to NSLDS. For unofficial withdrawals, an administrative withdrawal form is completed once determined by the College. As the College is an attendance-taking institution, the College should have reported the students’ last date of attendance as the effective date, but instead used the date that the College completed withdrawal form as the effective date.
Effect
The College did not report the students’ correct status changes to NSLDS, which may impact the students’ loan grace periods and enrollment reporting statistics collected by the Department of Education.
Questioned Costs
Not applicable
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 10 students selected for testing, 5 students, or 50% of our sample, had incorrect effective dates reported to NSLDS. We also noted 5 students, were not reported within required timeframe of 60 days and 2 students, were not reported at all to NSLDS. Such instances reflect 50% and 20% of our population, respective
Identification as a Repeat Finding, if applicable
See finding 2023-007, 2023-008, and 2023-009 included in the summary schedule of prior year findings.
Recommendation
The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the effective date of a student’s withdrawal, the importance of reporting the correct effective date and the consequences of incorrect reporting. Moreover, the College should emphasize the importance of distinguishing the last date of attendance (Activity Date) and completion date of Administrative Withdrawal Form (Date Completed). This oversight should also ensure that the effective date reported to NSLDS is consistent with the date the student separated from the College.
View of Responsible Officials
The College agrees with the finding and has implemented the corrective action plan listed within the management corrective action plan section of this report.