Finding Text
2023-002 Enrollment Reporting – Significant Deficiency
United States Department of Education—
ALN 84.268 Federal Direct Student Loans Program
Criteria: Per CFR §658.309, unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school 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 school, 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 school and who received a loan under title IV of the Act has changed his or her permanent address.
Condition: For one out of 25 students sampled, the effective date reported in NSLDS was incorrect. For four out of 25 students sampled, the status change was not reported in NSLDS in the next enrollment report or within 30 days of the date of determination.
Cause: The Law School does not have a formalized policy to address enrollment reporting for summer terms.
Effect: Enrollment reporting was inaccurate. Federal loan servicers utilize this information to determine the appropriate status for repayment terms and as such, had incorrect information. Enrollment reporting was not submitted within the required time frame.
Questioned Costs: None.
Context: See condition above.
Recommendation: We recommend the Law School enhance their procedures and formalize a written policy for all terms of enrollment reporting.
View of Responsible Officials: The Law School agrees with the finding and will ensure that enrollment reporting is accurate and timely.