Finding Text
Federal Award Year: July 1, 2022 – June 30, 2023
Compliance Requirement: Special Tests, Enrollment Reporting
Criteria or Requirement
According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via the National Students Loan Data System (NSLDS) within 15 days of receipt. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. An institution must notify the Secretary of Education if it discovers that 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. Department of Education lists several certification methods for enrollment reporting, including certifying directly through the NSLDS web site, certifying through the NLSDS’s batch enrollment reporting process, or through certification of rosters provided to the National Student Clearinghouse (NSC). Additionally, there are two categories of enrollment information within NSLDS, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types.
Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition Found
The College generally certifies its enrollment reports through rosters provided to the NSC. Of the forty (40) students with enrollment changes we selected for test work, we noted that for four (4) students, the College did not report the student’s status/enrollment change timely to NSLDS. The College did not report the status change until 145 days following notification of the change in status.
Possible Cause and Effect
The College’s internal control processes did not operate consistently to ensure that all enrollment status changes are submitted timely to NSLDS. The students identified in our sample as being reported late were identified as graduates in their enrollment system however were missing certain requirements to complete their degree. The College reported them beyond the allowed 30 or 60 days as withdrawn (W) until their degree requirements are completed at which time they will change the status to graduated (G). Delayed submission of student enrollment status information affects the determination that lenders and servicers of student loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies.
Questioned Costs
None.
Statistical Sampling
The sample was not intended to be, and was not, a statistically valid sample.
Repeat Finding
This is not a repeat finding.
Recommendation
We recommend that the College review its process to ensure that any enrollment changes are accurately reported within the required 30 or 60 day time frame to NSLDS. The College should work with NSC as needed to ensure proper protocols of transmission to NSLDS occur.
View of College Officials
The Office of the Registrar recognizes the importance of both timely and accurate reporting of enrollment status changes for lenders and servicers of student loans to determine in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies.