Finding Text
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.268
Award Period: July 1, 2022 – June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools
participating (or approved to participate) in the Federal Student Aid programs must have an
arrangement to report student enrollment data to the NSLDS through a roster file.
The school is required to report enrollment status at both the school and program level. The school is
required to report changes in the student’s enrollment status, the effective date of the status and an
anticipated completion date. An academic program is defined as the combination of the school’s Office
of Postsecondary Education Identification (OPEID) number and the program’s Classification of
Instructional Program (CIP) code, credential level, and published program length. ED requires the
University to report changes in enrollment status and indicate the date that the changes occurred (34
CFR 685.309).
Changes in enrollment status must be reported within 30 days. However, if a roster file is expected
within 60 days, you may provide the date on that roster file. In addition, regulations require that an
institution make necessary corrections and return the records within 10 days for any roster files that
don’t pass the NSLDS enrollment reporting edits. ED requires the University to report changes in
enrollment status within 30 or 60 days that the University determined the changes occurred (34 CFR
682.610).
Condition: Certain students’ enrollment information was not reported accurately to the NSLDS.
Questioned costs: None.
Context: During our testing, we noted the following:
2 students out of a sample of 40 students tested were reported to the NSLDS with the incorrect
enrollment status on both the campus-level and program-level records in the NSLDS.
1 student out of a sample of 40 students had an enrollment effective date in the program-level
records that did not match what was reflected in the University’s records and the campus-level
record in the NSLDS.
8 students out of a sample of 40 students tested were not reported to the campus-level record in
the NSLDS in a timely manner.
2 students out of a sample of 40 students tested did not have their summer 2023 term
enrollment information reported to both the campus-level and program-level records in the
NSLDS.
Section III – Findings and Questioned Costs – Major Federal Programs (Continued)
2023-002 – NSLDS Reporting (Continued)
1 student out of a sample of 40 students tested did not have their summer 2023 term reported to
the program-level records in the NSLDS.
Cause: Management's procedures to report accurate and timely information to the NSLDS were not
operating effectively.
Effect: Incorrect reporting to the NSLDS can result in incorrect determination of when the students’
grace period should begin.
Repeat Finding: No.
Recommendation: We recommend the University evaluate its procedures and review policies in
overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we
recommend the University review its policies and procedures on reporting enrollment information to the
NSLDS to ensure that all relevant information is being captured and reported timely in accordance with
applicable regulations.
Views of responsible officials: There is no disagreement with the audit finding.