Finding Text
Condition Found:
The Institution utilizes the National Student Clearinghouse (the Clearinghouse) as a service provider for
transmissions of its enrollment reporting changes to the National Student Loan Data System (NSLDS). The
University receives the Enrollment Reporting Roster and updates it for changes in student status. The file is
sent to the Clearinghouse who transmits the updated information to NSLDS.
For a sample of 40 students who were recipients of Direct Loans or Pell Grants between January 1, 2023
and December 31, 2023 who had been identified as having withdrawn, graduated, or modified their
enrollment status as defined by the University’s Satisfactory Academic Progress Policy through a change in
course load, the following were noted:
• 2023-003: For 2 of the 40 students selected for enrollment reporting testing, the student’s program
level enrollment effective date did not agree to that of their campus level data and/or the data per the
institution’s records. This represents 1 out of 9 high-risk data elements within the program level data
element requirements.
• 2023-004: For 1 student out of 40 selected for testwork, comparison of the institution’s records to that
of NSLDS evidenced that enrollment reporting for these students were not reported to NSLDS on a
timely basis. Therefore, management did not report the status changes to NSLDS within the required
timeframe of 60 days from the date they became aware of the change.
Cause and Possible Asserted Effect:
2023-003: The Institution’s controls over its review of the recording and communication of these status
changes does not operate consistently to ensure that individuals’ enrollment statuses are completely and
accurately communicated to NSLDS at the program level details.
2023-004: Management’s review over its enrollment reporting requirements for SFA was not operating as
designed to ensure timely reporting of status changes. Management sent the status change to the
Clearinghouse within the required timeframe; however, NSC did not send the data to NSLDS until after the
60-day requirement. As such, management’s control did not operate at a precise enough level to detect
and prevent noncompliance.
Further, the institution failed to maintain adequate review and documentation over student enrollment
status changes, resulting in a delay timeliness and inaccuracy of reporting to NSLDS.