Federal Student Aid (FSA) is issuing this Electronic Announcement to update our expectations of auditors evaluating institutional compliance with enrollment reporting requirements in light of the National Student Loan Data System (NSLDS®) issues previously identified in our Jan. 12, 2023, Electronic Announcement (Suggested Single Audit Procedures Related to NSLDS Enrollment Reporting). The guidance in this Electronic Announcement applies to audits of institutions with fiscal years ending after Feb. 28, 2023.
In our January 2023 Electronic Announcement we identified system issues that began July 19, 2022, that impacted institutions’ ability to comply with enrollment reporting requirements. FSA resumed sending enrollment reporting rosters to schools on their established schedules beginning March 1, 2023. The Department recognizes that institutions were not able to be in full compliance with the enrollment reporting requirements from July 19, 2022, through Feb. 28, 2023, and would not expect auditors to include enrollment reporting data due during that period in their evaluation of an institution’s compliance with the enrollment reporting requirements during a single audit. However, any required enrollment reporting data due prior to July 19, 2022, and after Feb. 28, 2023, should be evaluated by auditors performing single audits of participating institutions.
For impacted single audits of public and private-nonprofit institutions performed in accordance with the 2021 or 2022 Compliance Supplements, the following revised Audit Objective and Suggested Audit Procedures should be used for the Student Financial Assistance Cluster’s Special Test 4, Enrollment Reporting. With Office of Management and Budget approval, these revised objectives and procedures will be included in the 2023 Compliance Supplement as well.
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 impacting enrollment status, 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 and/or from the last regularly scheduled Enrollment Rosters after Feb. 28, 2023 up to the fiscal year end. 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, and/or after Feb. 28, 2023, compare the dates the roster files were sent to the received dates to verify that the institution responded to 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 issued Dear CPA Letter CPA-23-01: Modified Enrollment Reporting Testing Due to National Student Loan Data System Issues to provide a revised objective and revised procedures for Enrollment Reporting testing.