Finding Text
Special Tests and Provisions - Enrollment Reporting Compliance and Internal Control (Significant
Deficiency)
U.S. Department of Education - Student Financial Assistance Cluster
Federal Direct Student Loans (Federal Assistance Listing #84.268) Federal Award Number: P268K231804
Federal Pell Grant Program (Federal Assistance Listing #84.063) Federal Award Number: P063P221804
Federal Award Year: 2022-2023
Criteria and Context:
Under the Pell grant and U.S. Department of Education (“ED”) direct loan programs, institutions are required to report enrollment information via the National Students Loan Data System (“NSLDS”) (OMB No.18450035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information; “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2);
Direct Loan, 34 CFR 685.309). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods. Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence.
Institutions are also responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date.
Condition and Sample Method:
From a non-statistical sample of forty (40) students tested who graduated or withdrew during the year, we identified three (3) students whose withdrawal statuses were reported to the NSLDS more than 60 days after the students’ respective withdrawal dates (ranging from 75 to 78 days late). In addition, due to an inconsistency between the College’s and NSLDS’s approach to calculating program lengths, we identified all forty (40) students had Published Program Length Measurements and Published
Program Lengths that were inaccurately reported.
Cause:
While the College has established policies and procedures to ensure that the required reports are accurately completed and submitted on a timely basis to the NSLDS, we noted oversight on the timely reporting for three (3) withdrawn students. This resulted in the College missing the 60-day timing requirement for NSLDS reporting and resulted in the non-compliance noted.
The NSLDS Enrollment Reporting Guide provides a caution that institutions should report associate and bachelor degree programs in years and not months. When program length is reported in months or weeks, NSLDS uses this value along with the Weeks in Title IV Academic Year value to calculate a length in years. This resulted in program lengths that are shown in the NSLDS system as being longer in years
than the actual program length.
Effect:
There is a delay in the NSLDS obtaining the required information regarding the enrollment status changes
of students. The accuracy of the Published Program Length Measurement and Published Program Length in Years were inaccurately reported to the NSLDS for the forty (40) students selected for testing.
Questioned Costs:
None identified.
Identified as a Repeat Finding:
Yes.
Recommendation:
The College should strengthen policies and procedures to ensure that student status transmission reports
are submitted accurately to the NSLDS at least every 60 days, or more often, as determined to be
appropriate.
The College should also ensure that student Published Program Length Measurements are listed in years
and that the Published Program Lengths are calculated in years as recommended by the NSLDS Enrollment Reporting Guide so that the Published Program Length calculation is accurate to the true
length of the program for each student.