Finding Text
Criteria:
Under the Federal Pell Grant Program and U.S. Department of Education (“ED”) loan programs, institutions are required to report student enrollment information via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035). 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 verify 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 website. 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.
Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date.
Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (“SAIG”) (OMB No. 1845 0002) mailboxes sent by the Department of Education (“ED”) via NSLDS. An 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 the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website
(Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309).
Enrollment information is used to determine the borrower’s eligibility for in-school status, deferment, interest subsidy, and grace period. Enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported. The enrollment information is merged into the NSLDS database and reported to guarantors, lenders, and servicers of student loans.
Context:
The University distributes Direct Loans and Pell grants to students and is thus required to report the Campus-Level and Program-Level enrollment information of these students to NSLDS both timely and accurately.
Condition:
We identified the following instances of noncompliance from a selection of forty (40) graduated students selected for enrollment reporting testing:
• Twenty (20) students whose graduation effective dates were not reported timely (within 60 days) to the NSLDS.
Cause:
The University uses Banner to create a file of graduates that is reported to the National Student Clearinghouse. A system error in Banner delayed creation of the file and the timely reporting of the graduates.
Effect:
While the data that was transmitted to the NSLDS was accurate, the University did not timely report graduation effective dates for twenty (20) students.
Questioned Costs:
None identified.
Identified as a Repeat Finding:
No.
Recommendation:
The University should strengthen policies and procedures to ensure that enrollment effective dates are submitted timely to the NSLDS.
Views of Responsible Officials:
There is a Banner process which creates the file containing graduates for degree verification submission to the National Student Clearinghouse. There was a systematic error with that process last spring rendering the process unable to generate a file. The error was not resolved until early May, which is when the submission for these students was completed. This was a one-time specific system failure occurrence which has been resolved, and the process has been working correctly since May 2024.
The Offices of the Registrar and Student Financial Services are working in conjunction with the University compliance team and Office of Institutional Research to enhance review and checks/balances of reporting deadlines to ensure that files are submitted within the required deadlines. Further, the Office of the Registrar will work with internal IT staff to research and implement backup reporting procedures for creating enrollment and graduation files in the event of another system issue.