Finding 7543 (2023-001)

2023-001 - Non-Compliance with Timely Student Enrollment Change Submissions to the National Student Loan Data System (NSLDS) Grantor: U.S. Department of Education Program Name: Student Financial Assistance Cluster Award Names: Federal Pell Grant Program and Federal Direct Loan Program Award Year: 7/1/2022 - 6/30/2023 Award Number: Not applicable Assistance Listing Numbers: 84.063 and 84.268 Criteria: In accordance with 34 CFR 690.83(b)(2) and 685.309, institutions are required to report enrollment information under the Federal Pell Grant and Federal Direct Loan programs through the NSLDS. The enrollment information, inclusive of Campus Level and Program Level data, must be reviewed, updated and validated by the institution in a timely manner. Furthermore, specific to the Federal Direct Loan program, for a student who received a Direct Loan and was enrolled or accepted for enrollment at the institution, and the student had 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, the institution must report the change within 60 days from which the change was identified. Condition: We reviewed a sample of twenty-five students enrolled at the University who received either Pell and/or Direct Loans and had a change of enrollment status during the periods of time July 1, 2022 through July 18, 2022 and March 1, 2023 through June 30, 2023 of the fiscal year. Of the twenty-five students tested, nine students were not reported within the 60-day reporting timeframe. For seven of the students tested, the change in enrollment was reported to the NSLDS between 87 and 161 days from the date the change was identified. For two of the students tested, the change in enrollment was reported to the National Student Clearinghouse (NSC) for upload to the NSLDS however the student status has not yet been updated within the NSLDS records. Cause: There were three causes identified from the condition:  For four students, who each changed status during the spring semester and were not planning on returning in the fall semester, the University identified student status changes at the end of the spring semester, however waited until the beginning of the fall semester to communicate these changes to the NSC through their fall enrollment data submission rather than manually communicating them to the NSC upon identification;  For three students, who were each subject to a late degree certification, the University’s internal verification process was not adequately designed to meet the NSC’s two-step verification process to ensure that graduation status was timely updated to the NSC; and  For two students, the student status changes were timely reported to the NSC, however were not reported by NSC to the NSLDS. The University does not have an internal process in place to verify all student status changes communicated to the NSC are completely, accurately and timely communicated to the NSLDS. Effect: A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies all of which are impacted by late reporting. Recommendation: We recommend the University perform the following:  Increase the frequency in which it reports enrollment updates to the NSC throughout the summer semester to allow for enrollment changes to be received by the NSLDS in a timely manner;  Enhance the University’s degree verification process for late certifications to include the two steps now required by the NSC which will ensure the status change of all graduates are timely communicated to the NSC and ultimately reported to the NSLDS; and  Implement a periodic reconciliation process between the NSC and the NSLDS to verify that the NSLDS timely and completely received communication of all student status changes. Additionally, the University should discuss this matter with the NSC and the NSLDS to understand why the student status changes were not communicated to the NSLDS and determine if additional action can be taken by the University to ensure these status changes are updated.