Note
On April 17, 2023, we published guidance that applies to audits of institutions with fiscal years ending after Feb. 28, 2023. Refer to the April 17, 2023 Electronic Announcement for more information.
Federal Student Aid (FSA) is issuing this Electronic Announcement to summarize the issues that arose following the July 2022 implementation of the modernized NSLDS Professional Access website and to communicate our expectations of auditors evaluating institutional compliance with enrollment reporting requirements in light of those issues.
As FSA prepared for the retirement of the current National Student Loan Data System (NSLDS®) website and the launch of the enhanced website, FSA temporarily paused data reporting to NSLDS. Batch reporting was accepted until July 19, 2022, and online updates and submittal spreadsheets were accepted until July 20, 2022. Due to issues encountered following the conversion, data reporting and data processing did not resume as scheduled, which impacted institutions’ ability to comply with enrollment reporting requirements through the date of this Electronic Announcement. During this time, there was a period when institutions were encouraged not to provide updates or had their submissions canceled, as well as periods when regular enrollment reporting rosters were suspended along with enrollment history update functionality. There was also a period during which processing of received updates was paused.
The Department issued Electronic Announcements between June and November 2022, detailing enrollment functionality and identified issues. The Electronic Announcements stated that institutions should retain copies of the announcements as documentation for audit purposes. See recent Electronic Announcements from Nov. 23, 2022, Nov. 14, 2022, and Oct. 7, 2022. The Oct. 7, 2022, Electronic Announcement has links to all previous Electronic Announcements (refer to the section titled “Published Information”).
Institutions have not been able to comply with enrollment reporting requirements for the period July 19, 2022, through the date of this Electronic Announcement. Therefore, for institutions with fiscal years ending through Feb. 28, 2023, auditors would not be expected to include any enrollment reporting data due from July 19, 2022, through Feb. 28, 2023, in their evaluation of the institution’s compliance with the enrollment reporting requirements. Institutions were expected to be in compliance with the enrollment reporting requirements for all other periods within their fiscal year.
For impacted single audits of public and private-nonprofit institutions performed in accordance with the 2021 and 2022 Compliance Supplement, the following revised Audit Objective and Suggested Audit Procedures should be used for the Student Financial Assistance Cluster’s Special Test 4, Enrollment Reporting. No later than March 1, 2023, FSA will issue additional audit guidance for institutions with fiscal years ending after Feb. 28, 2023.
Audit Objectives: Determine whether the institution is notifying ED of changes in student enrollment information at the Campus Level and Program Level in a timely and accurate manner, for periods during which the institution was required and able to comply with enrollment reporting requirements.
Suggested Audit Procedures:
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Identify a population of Pell and Direct Loan students from the institution’s records that had a reduction or increase in attendance levels, graduated, withdrew, dropped out, or enrolled but never attended during the audit period and for whom the institution was required to report such change in enrollment status from the beginning of the institution’s fiscal year up to the last regularly scheduled Enrollment Roster prior to July 19, 2022. From the population identified, select a sample of students and compare the data in the student’s NSLDS Enrollment Detail to the students’ academic files and other institutional records and verify that the institution is accurately reporting the significant Campus-Level and Program-Level enrollment data elements that ED considers high risk.
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For instances in the sample tested in procedure a. above where a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student 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 a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, determine whether the institution reported the change in its next updated Enrollment Roster file.
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Have the institution access the NSLDS website and create the Enrollment Submittal File Tracking Report (SCHET1) or access the Enrollment Submittal Tracking Page. For regularly scheduled roster files during the audit period with “Date Sent” prior to July 5, 2022, compare the dates the roster files were sent to the return dates to verify that the institution returned the roster files within 15 days.
For impacted proprietary school compliance audits performed in accordance with the 2016 OIG Audit Guide, Guide For Audits of Proprietary Schools and For Compliance Attestation Engagements of Third-Party Servicers Administering Title IV Programs, OIG will be issuing a Dear CPA Letter to provide a revised objective and revised procedures for Enrollment Reporting testing.