Finding Text
Federal Program Information: Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Enrollment Reporting – The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the University becomes aware of the change in enrollment status. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements, it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.
According to the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days.
Condition: For a certain student whose status changed during the year, the University failed to submit a timely notification to the NSLDS website. Additionally, the University’s fiscal year SCHER1 report, included multiple instances in which error records were not corrected within the required timeframe.
Cause: Administrative oversight.
Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements.
Questioned Costs: None.
Context: For 1 of 40 students sampled whose status changed during the year, the University failed to submit a timely notification to the NSLDS website. Additionally, error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple errors during the 2023 fiscal year.
Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2022-003 in the prior year schedule of findings and questioned costs.
Recommendation: We recommend that the University implement procedures to ensure that that all status changes are submitted to the NSLDS website within the required timeframe and that error records are corrected and submitted timely.
Views of Responsible Officials: Liberty acknowledges that there was one instance in which a student’s enrollment status was not reported within compliance timeframes. Additionally, Liberty recognizes that there were multiple months in the year in which there were repeat errors found in the SSCR error file.
Liberty University continues to work to ensure the enrollment reporting process is handled compliantly and within allowable timeframes. There were multiple errors that were proactively addressed with National Student Clearinghouse (NSC) as Liberty was unable to resolve them internally. This was one of the contributing factors in having multiple months of repeat errors as NSC did not resolve. We will continue to work with NSC to resolve timing issue that result in errors outside of compliance timeframes.
Additionally, the Registrar’s Office will work with ADS Academics to review the standard report used through Ellucian’s Banner to report student enrollment status to NSC. The goal of this review will be to better identify the source of errors and reduce error count for future submissions.
Finally, over the last year, Liberty’s Financial Aid Office has hired an employee whose primary focus will be to provide an additional Quality Control (QC) process for enrollment reporting. This employee will work collaboratively with the Registrar’s Office to ensure roster errors and student enrollment level changes are resolved and reported within the permissible timeframes. While this position has been filled, we have been limited by the U.S. Department of Education’s National Student Loan Data System (NSLDS), as they transitioned to a new system and reporting used for this QC process was not released until July of 2023 and was not functional until September 2023 due to run-time errors that went unresolved. Liberty reached out to the U.S. Department of Education on multiple occasions (Case# 220920-00436 and Case# 230718-000084) in order to obtain a working report.