Federal programs: Federal Pell Grant Program; Federal Direct Loan Program
Compliance requirement: Special tests and provisions - Enrollment reporting
Condition and context.
During our enrollment reporting test, for a statistically valid sample of ten (10) students from a
population of thirty-five (35) records that had a reduction or increase in attendance levels,
graduated, withdrew, dropped out, or enrolled but never attended during the audit period, we
noted the following deficiencies:
In three (3) cases, we noted that the Institution did not report the correct enrollment status for
these students.
a. In one (1) case, the student enrollment status was notified as being enrolled in six (6)
credits instead of being a withdrawal (W) since the student was not enrolled for studies
at the institution.
b. In one (1) case, the student enrollment status was notified as being a withdrawal (W)
instead as being enrolled in nine (9) credits.
c. In one (1) case, the student enrollment status was notified as being enrolled in ten (10)
credits instead of being enrolled in thirteen (13) credits.
The enrollment status for these students was reported correctly in the subsequent Enrollment
Reports that were submitted.
Additionally, the enrollment reporting requirement applicable to institutions under the Pell Grant
and ED loan programs requires that institutions complete and return within 15 days the Enrollment
Reporting roster file (formerly the Student Status Confirmation Report (SSCR) placed in their
Student Aid Internet Gateway (SAIG) mailboxes sent by ED via NSLDS. Regarding this, during
our evaluation of compliance with the Roster File return requirement, we were unable to verify
that the institution completed and returned any Enrollment Reports for the period from August
through December 2022.
Criteria
Dear College Letter (DCL) GEN-74-07, Subject: Changes to NSLDS Enrollment Reporting:
Program - Level Reporting and More Frequent Reporting, states that, under the authority of these
regulations, beginning July 1, 2014, we will request enrollment information from schools every 60
days and schools will be required to respond to those requests within 15 days of the date that we
send the electronic enrollment reporting roster to the school or to its designated third-party
servicer. Also, the section of the letter titled Program-Level Enrollment Reporting Required, states
that if the student is or was enrolled in more than one program, the student's enrollment
information must be reported for each of the programs. The NSLDS enrollment reporting rosters
include recipients of all Title IV loans and Federal Pell Grants. Including Pell Grant recipients will
allow the Department to meet the Congressional reporting requirements noted earlier. Note that
a student will only be included on the roster once, regardless of the number of different Title IV
programs from which the student received funding.
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Universidad Teológica del Caribe, Inc.
Schedule of Findings and Questioned Costs (continued)
July 31, 2023
34 CFR 690.83 (b) (2) establishes that an institution shall submit, in accordance with deadline
dates established by the Secretary, through publication in the FEDERAL REGISTER, other
reports and information the Secretary requires and shall comply with the procedures the Secretary
finds necessary to ensure that the reports are correct.
34 CFR 685.309 (b) (1) and (2) establish that upon receipt of an enrollment report from the
Secretary, a school 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, 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.
Cause
The Institution's internal controls for tracking and reporting the enrollment changes failed to
identify the enrollment status changes performed manually by the Registrar's office personnel.
Effect
A student's enrollment status determines eligibility for in-school status, deferment, and grace
periods, as well as for the payment of interest subsidies to FFEL Program loan holders by ED.
Enrollment reporting in a timely and accurate manner is critical for effective management of the
programs. Failure to report will likely result in the school being out of compliance with the
regulatory requirements and possibly subject to sanctions. Also, failing to report completions at
all may cause borrowers to lose interest subsidy when they should not. And, because such
determinations are based on the student's enrollment (and completion) at the program level, it is
critically important that schools correctly and promptly report a student's completion at the
program level.
Questioned costs
None.
Identification as a Repeat Finding
A finding related to this compliance requirement was included in the prior year audit as Finding
No. 2021-004.
Recommendations
We recommend the Institution to determine what parts of the manual processes for this
requirement can be monitored electronically or using tools available in the USDE website with the
assistance of the IT consultant to help the Institution to comply with the deadline of the roster
reporting. Also, we recommend reinforcing the controls to report the enrollment status changes
of the participant students of the Pell and Direct Loan programs. In addition, a compliance officer
may assist in the reporting process.
Page | 42
Universidad Teológica del Caribe, Inc.
Schedule of Findings and Questioned Costs (continued)
July 31, 2023
Views of Responsible Officials
Refer to the Institutional comments included in the Corrective Action Plan.
Compliance requirement - Special tests and provisions – Enrollment Reporting
Institutional Comments on Findings and Recommendations:
The institution agrees with the auditor on this finding in that there were (3) three cases where the
enrollment status was not reported correctly. Although as was observed by the auditor, the
enrollment status for the three students in question were corrected in the next enrollment report
that was submitted.
During the audit period, the institution was unable to update, submit or complete in a timely
manner Enrollment reports for the period of July through December 2022. This was mainly due
to problems with the implementation of a new format for enrollment reporting through the NSLDS
Modernized Website.
The institution has on file, multiple inquiries to the NSLDS Customer Support Center in relation to
this issue.
The Department of Education also posted various Electronic Announcements updating and giving
continued guidance to institutions on this issue.
The auditors were provided with copies of all of ED’s posting and updates as related to this issue.
Nevertheless, during the subsequent months from January 2023 to June 2023 covered in this
audit period, the institution was able to complete and report the current enrollment status of
students to the NSLDS platform.
Actions Taken or Planned:
The matter as related to this finding has already been discussed with the Registrar who is
responsible for the completion and submission of the Enrollment Reports to the Department of
Education
To continue to improve on the reporting to student’s enrollment status, the institution would
continue to submit its Enrollment Reports monthly instead of every two months as schedule.
Status of Corrective Actions on Prior Findings:
The issue as related to this finding occurred in the past audit.