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 June 2020:
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 University to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, we noted 2 students, out of a sample of 40, who were reported to NSLDS beyond the required timeframe. Both students were administrative withdrawals processed in spring 2023.
Cause
The University did not have adequate procedures in place to ensure that students with status changes were reported to NSLDS within the required timeframe.
The University's Registrar's office sent the roster including the Spring 2023 withdrawals to the National Student Clearinghouse, the service entity that processes their uploads to NSLDS, within the acceptable 60 day timeframe. The National Student Clearinghouse took longer than anticipated to upload the status updates to NSLDS and did so beyond the 60 day timeframe.
Effect
The University did not report the students’ status changes to NSLDS within the required timeframe, which may impact the students’ loan grace periods.
Questioned Costs
Not applicable
Perspective
Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 2 students, or 5% of our sample, had status changes that were not reported to NSLDS within the required timeframe.
Identification as a Repeat Finding, if applicable
Not applicable
Recommendation
The University 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 University’s date of determination of withdrawal, the importance of reporting the timely and the consequences of late reporting. The University should also discuss the required processing lead times with the National Student Clearinghouse to ensure a timely upload to NSLDS. Additionally, submission of additional rosters may reduce the likelihood of the finding in the future.
View of Responsible Officials
The University agrees with the finding.