Finding Text
2024-002 Special Tests (Enrollment Reporting)
Student Financial Assistance Cluster:
U.S. Department of Education
Federal Direct Student Loans (ALN 84.268)
Federal Grant Numbers and Years: P268K240460 (9/1/2023-8/31/2024)
Statistically Valid Sample: No, and it was not intended to be
Prior Year Finding: No
Finding Type: Significant Deficiency and Noncompliance
Criteria:
Under the Pell grant and the Direct and Federal Family Education Loan programs, institutions are required to report 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 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. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information.
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 all Campus-Level Record data elements. The Department of Education (ED) considers the
following data elements to be high risk:
• OPEID number, enrollment effective date, enrollment status and certification date Institutions are responsible for accurately reporting all Program-Level Record data elements. The Department of Education (ED) considers the following data elements to be high risk:
• 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 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); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309: Perkins 34 CFR 674.19(f)).
Additionally, in accordance with federal requirements, the College shall maintain internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the federal award that could have a direct and material effect on a federal program.
Condition and Context:
The College utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for transmission of its enrollment reporting changes including, but not limited to withdrawals and graduate status to the National Student Loan Data System (NSLDS). The College receives the Enrollment Reporting
Roster and makes necessary updates for changes in student status. A final file is then sent to the Clearinghouse who transmits information or corrections to NSLDS.
For 4 out of the 26 students selected for testwork, the enrollment status did not match between the institutions records, NSLDS Campus-Level Records, and NSLDS Program Level Records due to a DegreeVerify service limitation within the National Student Clearinghouse and two of the four students also
were certified by NSLDS 82 days after the 60 day certification requirement past the status effective date. In addition to the 4 students previously discussed, one additional student’s status was certified 16 days beyond the 60 day certification day requirement.
Cause:
The College’s processes and procedures did not ensure that the Clearinghouse transmitted the change in status certification dates by the required 60 day reporting period and was properly reflected in NSLDS.
Effect:
Student status changes not reported in a timely or accurate manner may cause the student to not enter into repayment status for Federal Direct Student Loans on a timely basis.
Questioned Costs:
No questioned costs were noted as a result of the audit procedures performed.
Recommendation:
We recommend the College review and enhance its current policies and procedures to ensure that all status changes are reported to NSLDS timely and that all student statuses match between the College records, Campus-Level Records and Program-Level Records.
Views of Responsible Officials:
Management agrees with the finding.