2024-002 – Special Tests and Provisions - Enrollment Reporting – Material Weakness in Internal Controls over Compliance
Student Financial Assistance Cluster
Department of Education
Federal Assistance Listing Number: 84.063, 84.268
Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans
Federal Award Number: P063P230357, P268K230357
Award Year: 2023-24
Criteria: The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the College’s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR § 685.309.
Condition/context: The auditors selected a sample of 34 students out of a population of 1,454 who had received Federal aid and had withdrawn or graduated from the College during the 2023-2024 fiscal year. The auditors compared the withdrawal or graduation date per the College’s records to NSLDS.
The auditors noted eight students were not reported to NSLDS within the 60-day requirement.
In addition, the auditors identified ten students who graduated but were not reported as graduated to NSLDS.
Corrective Action: LCC reports enrollment to the National Student Clearinghouse: in the second, sixth and the tenth week of each standard term. There is an error report that the Clearinghouse returns with discrepancies in enrollment status which we respond to and correct within five business days. Once all errors are resolved and the report is accepted the NSC will post the data and report to NSLDS.
Lane is an open access institution and therefore does not have a formal withdrawal policy. Two weeks after the end of each term, Lane sends the enrollment report and the “degree verify” extract to NSC.
We are in the process of reviewing our NSC reporting strategies and including additional staff who will be supporting the process. We are reviewing NSC reporting times to ensure that we are reporting often enough to meet the required 60 day timeline for NSLDS. We are considering moving the enrollment and degree verify extract to a 30 day reporting period to meet the 60 day timeline.
Phase 1: Issue an off cycle report to the NSC by June 6th, which is our next anticipated enrollment reporting cycle (week ten). We will send both the enrollment report and the “degree verify” extract to catch any updates to graduation information that may have changed since our last end of term report.
Phase 2: Review updates to NSC processes that were issued through Banner and Ellucian and revise the “degree verify” process to capture regular graduation or withdrawal updates outside our standard reporting window. Unless it is discovered that the 30 day cycle does not meet the requirements of the reporting cycle, we will update our processes to - at a minimum - report every 30 days or in alignment with the weeks two, six and ten current enrollment report to the NSC.
Additionally, the students noted in the finding will be reviewed to address any potential anomalies with reporting and to identify the cause of why these were not updated. This will be another consideration during the assessment for any updates to our reporting cycles.
Following spring term, we will report graduated and withdrawn students, as is our current practice and after student degree awarding is complete.
Name of Contact Person Responsible for Corrective Action: Dawn Whiting
Anticipated Completion Date for the Corrective Action: A review process of 90 days should result in refined practices and an implementation of those practices to meet required reporting. All reporting changes will be finalized and followed by Aug 21, 2025.