Finding Text
Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report
from the Secretary, institutions must update all information included in the report and return the
report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within
the timeframe prescribed by the Secretary. Unless it expects to submit its next updated
enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary
within 30 days after the date the institution discovers that: (i) 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 institution
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; or (ii) a student who is
enrolled at the institution and who received a loan under Title IV of the Act has changed his or her
permanent address.
Condition/Context: The change in student status for 7 of 25 students tested was not reported to
the National Student Loan Data System (NSLDS) timely when the students graduated at the end
of the spring term. The change in status for 2 of 25 students tested was not reported to NSLDS at
the campus level.
The sample was not a statistically valid sample.
Questioned Costs: Not applicable.
Cause: The Registrar's data collection was not reviewed after submission to National Student
Clearinghouse (NSC) by another responsible individual to ascertain the accuracy of graduated
students being reported. The College received a response from NSC of no errors, therefore the
graduated students in question were not reported in a timely manner.
Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the
enrollment information reported by schools. If an Institution does not review, update and verify
student enrollment statuses, effective dates of the enrollment status and the anticipated
completion dates, then the Title IV student loan records will be inaccurate.
Recommendation: It is recommended that the College review policies and procedures in place to
resolve reporting issues with the third-party servicer in a timely manner or implement an
alternative reporting method to facilitate compliance with Title IV regulations.
Management’s Response: Management has reviewed policies and procedures for accurate
reporting of enrollment status and changes to be in compliance with federal regulations. The
College will designate a secondary responsible individual to conduct a review of the preparation
of the digital file and review the digital file of student enrollment changes before it is submitted to
the National Student Loan Clearinghouse. The Office of Financial Planning will conduct monthly
review as a secondary review of enrollment reporting in the National Student Loan Data System
(NSLDS).