Finding Text
Federal Program Information: Federal Pell Grant Program (ALN: 84.063), Federal Direct Loan Program (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): N. Special Tests and Provisions - Enrollment Reporting: The University is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 60 days of the date the University becomes aware of the change in enrollment status. 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. Institutions are responsible for accurately reporting the significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements, it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.
Per the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days.
Condition: During our testing of student enrollment reporting, we noted the following exceptions:
• For 3 of 25 students selected for testing, the University failed to submit the student’s graduated or withdrawn status to NSLDS within the required timeframe.
• For 5 of 25 students selected for testing, the University did not accurately report the student’s enrollment status.
• Multiple error records identified in Error/Acknowledgment files were not corrected within the required timeframe.
Cause: Administrative oversight with respect to enrollment reporting compliance requirements.
Effect or Potential Effect: The University is not in compliance with enrollment reporting compliance requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs: None.
Context:
We tested a sample of 25 students and found exceptions as noted in the condition. This is a condition identified per review of the University’s compliance with specified requirements using a statistically valid sample.
Identification of Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the University properly follow its policies and procedures over enrollment reporting to ensure that all status changes are submitted to the NSLDS website within the required timeframe and that error records are corrected and submitted timely, consistent with federal regulations.
Views of Responsible Officials and Planned Corrective Actions: The University concurs with this finding. This action is completed through a third-party service (National Student Clearinghouse) which updates the NSLDS automatically. As student enrollment changes and awards are adjusted, the Director of Financial Aid updates the Registrar who makes adjustments in NSC and those adjustments are noted in NSLDS. The University Registrar will check behind NSC on a monthly basis to ensure that enrollment dates are correct and have been submitted to NSLDS in a timely manner.