This is the second in a series of 10 blog posts related to the Top 10 Audit Findings of the U.S. Department of Education.

Steve_Bastardi-resizedAccording to the U.S. Department of Education, one of the top 10 audit findings is inaccurate or untimely reporting of NSLDS rosters. Less than satisfactory reporting can have a negative impact on students’ records and details related to their financial aid status and history. Negative impacts on institutions of higher learning include:

- Enrollment records being rejected by NSLDS
- Out-of-compliance issues
- Sanctions

The negative impacts on borrowers include:

- Over awards of subsidized loans
- Loss of interest subsidy
- Unsatisfactory loan servicing

According to the U.S. Department of Education, most of the audit findings related to enrollment reporting include NSLDS Roster files (formerly known as the SCCR) not submitted on time, specific student information not submitted timely, failure to provide notification of last date of attendance/changes in student enrollment status, and failure to report accurate enrollment types and effective dates.

While considering report submission timing requirements involved with general and other more detailed compliance requirements it’s important to remember the enrollment reporting flow, which includes four basic steps:

  1. Institutions send enrollment school code(s) on grant and loan disbursement records to the Common Origination and Disbursement (COD) System,
  2. COD sends the grant, disbursement, and program data to NSLDS and disbursement records to the loan servicer,
  3. NSLDS uses the Enrollment School Code and program-level data from COD to place aid recipients on Enrollment Rosters, and
  4. NSLDS sends the Enrollment Roster to the school.

Remember, according to the U.S. Department of Education (ED), “accurate and timely reporting” requires Title IV aid recipient enrollment to be certified at least every sixty days. This is consistent with the requirements listed in the Code of Federal Regulations (CFR’s), which indicates reporting student status changes including when a student becomes enrolled less than half time. According to the federal requirements, in this situation an institution typically has thirty days from the date of determination to report the student’s enrollment to NSLDS. If a roster file is expected within 60 days, then you may provide the updated data on that roster file. The date of determination is the date your institution becomes aware of a student’s enrollment status change. Typically, the date of determination is subsequent to the effective date of the enrollment status.

Determining, or defining the “date determination”, can be a source of confusion. Enrollment compliance reporting is based on the date an institution discovers that a student dropped below half-time, not necessarily the actual date that the student’s status dropped. Sometimes there is confusion as to when the 60 days starts and stops when evaluating compliance reporting due dates.

The FSA Handbook states that the date of an institution’s determination that a student withdrew varies depending on the type of withdrawal. For example, if a student begins an official withdrawal process or provides official notification to the school of intent to withdraw, the date of the institution’s determination that the student withdrew would be the date the student began the official withdrawal process or the date of the student’s notification, whichever is later. If a student did not begin the official withdrawal process or provide notification of intent to withdraw, the date of the institution’s determination that the student withdrew would be the date that the school becomes aware that the student stopped attending.

Here are a few tips to avoid costly errors in NSLDS enrollment reporting:

- Continuously update and improve your policies and procedures.
- Providing comprehensive training and continuing education for staff.
- Diligently review, update, and verify student statuses, effective dates of enrollment, and completion dates.
- Designate responsibility for monitoring reporting deadlines.
- Monitor the NSLDS reporting website for updates, https://www.nsldsfap.ed.gov/nslds_FAP/default.jsp
- Be sure to use proper enrollment status update codes.

- Access and review your enrollment statistics report (ENLST1), which includes information about completeness and quality of the enrollment reporting provided by schools participating in federal student aid.

So, in order to avoid possible NSLDS enrollment reporting errors and being on a list of institutions that have audit findings consistent with the top 10, remember the compliance rules and regulations, and monitor these rules and regulations for changes and updates. Also, consider some of the suggestions listed for improving best practices.

If you’re interested in further reading please take a look at the following references:

- NSLDS Enrollment Reporting Guide: October 2015
- Dear Colleague Letter GEN-14-07: April 14, 2014
- Dear Colleague Letter GEN-14-17: August 29, 2014
- Newsletter 47: Recent NSLDS Enhancements
- Newsletter 49: Enhancements to NSLDS for Enrollment Reporting and Gainful Employment
- Regulation: 34 C.F.R. § 685.309(b)
- NSLDS Reference Materials section of the IFAP Web site- NSLDS Enrollment Spreadsheet Submittal at the following link: https://www.fsadownload.ed.gov/software.htm

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Topics: Institutions of Higher Learning, Audit