Finding Text
Criteria: Per 34 CFR 685.309, Schools are required to accurately report enrollment information under the Direct Loan program via the NSLDS. Enrollment status changes for students should be reported to NSLDS within 30 days, or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the effective change in status, or the date of determination if the date of determination was determined after the withdrawal date. At a minimum, schools are required to certify enrollment every 60 days. The NSLDS Enrollment Reporting Guide further states that the information that is reported to the Department of Education should be accurate and timely. Per the NSLDS Enrollment Reporting Guide section 4.4.3, when a student withdraws during a term, the effective date for the withdrawn status is the withdrawal date used by the institution. In the case of a student who completes a term does not return for the next term, leaving the course of study uncompleted, the effective date of the withdrawn status is the final day of the term in which the student was last enrolled. The effective date for graduation status is the date that the school assigns to the completion/graduation.
Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is completed properly.
Condition: During our testing of students that were disbursed financial aid during the 2022-2023 school year, there were 13 instances of students that withdrew or graduated during and after the Spring 2023 semester that were not reflected in the NSLDS within 60 days. RSM observed through Empower (student portal) and other internal reports (including transcripts) that these students should have shown statuses of graduated/withdrawn on their NSLDS reports as of the audit period. Additionally, we noted that the NSLDS report showed three students who withdrew from the College but the NSLDS reflected an incorrect Enrollment Effective date for both campus-level and program-level, as the students withdrew during March and April of the Spring 2023 semester but the campus-level enrollment effective date listed on the NSLDS report was May 5, 2023 (the last day of the Spring 2023 semester) while the program-level enrollment effective date listed was December 16, 2022.
Cause: The institution did not properly report the Spring 2023 students with enrollment status changes to the Clearinghouse/NSLDS by leaving out the program level information, which created error codes that were not properly addressed by the institution. The dates reported for the three student withdraws was not correctly documented.
Effect: The administration of the Title IV program depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Without accurate and timely NSLDS reporting there is a diminished ability for the Department of Education to properly administer the program.
Context: 13 of the 13 status changes tested. In accordance with the OMB Compliance Supplement, our sample did not include any enrollment reporting data due from July 19, 2022 through February 28, 2023 in our evaluation of the enrollment reporting requirements due to the NSLDS system modernization. Our sample was not statistically valid.
Questioned Costs: None.
Repeat Finding: No.
Recommendation: Management should review the controls and procedures in place to verify that accurate, timely, and complete data is being submitted to NSLDS. This should include separation of the preparation of data and review and completion of the submission, as well as additional methods to help identify errors.
Views of responsible officials: Management agrees with this finding. See corrective action plan.