Finding 2025-001
significant deficiencyother matters
- Program
- STUDENT FINANCIAL ASSISTANCE (84.063)
- Compliance requirement
- Special tests and provisions
- FAC record
- FY2025 audit on fac.gov
Finding text from the filing
Finding 2025-001 — Special Tests and Provisions- Enrollment Reporting- Significant Deficiency
Criteria: Federal regulations and related guidance governing Title IV student aid programs require schools to report the enrollment of students who receive federal student aid (U.S. Department of Education, National Student Loan Data System (NSLDS) Enrollment Reporting Guide, November 2022, Chapter 2). At a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.
Laredo College (College) uses the services of the National Student Clearinghouse (NSC) to report status changes to NSLDS. Under this arrangement, the College reports all students enrolled and their status to NSC. NSC then identifies any changes in status and reports those changes to NSLDS when required. Although the College uses the services of the NSC, the College still has the primary responsibility for ensuring any changes in student enrollment status is reported accurately and in a timely manner (NSLDS Enrollment Reporting Guide, November 2022, Chapter 3).
Condition: For 18 out of 25 (72 percent) students tested, the College did not accurately and timely report enrollment status changes to NSLDS. Specifically:
· For thirteen (13) students, the College did not report the students' withdrawal status until approximately eleven months after the student withdrew; additionally, for each of these students, the withdrawal date documented in the College's student records did not agree to the withdrawal dates documented in the NSLDS system.
· For two (2) students who both attended and withdrew from the College in the Spring 2025 semester, the NSLDS system showed a withdrawn status effective in December 2024 that was reported to NSLDS ten months later in October 2025.
· For one (1) student who attended and withdrew from the College in February 2025, the NSLDS system did not have a withdrawal record. The most recent record shown was received in October 2025 and it shows a status of "L — Less than Half-time" effective in January 2025.
· For one (1) student who attended and withdrew from the College in the Spring 2025 semester, the most recent records in the NSLDS system were from 2017, with no status to show enrollment or withdrawal from the College in 2024-2025.
· For one (1) student who attended and withdrew from the College in the Spring 2025 semester, the NSL DS enrollment details show a status of "Z — No Record Found".
Deficiencies noted above were discovered in a review of 25 complete student withdrawals during the respective semester. Considering the high percentage and similarity in deficiencies noted in the sample, the issues noted appear to be pervasive, leading to the possibility that there may be issues noted in a greater number of student records, related to changes in enrollment status, for the College's whole student population.
Questioned Costs: None.
Cause: The majority of the deficiencies appear to be due to delays in report processing incurred during the migration to a new student information system.
Effect: Noncompliance with federal compliance requirements and errors that may affect determinations that guarantors, lenders, and servicers of student loans make related to in-school status, deferments, grace periods, and repayment schedules.
Recommendation: The College should ensure all pertinent staff are sufficiently trained and knowledgeable on the requirements of the Enrollment Reporting requirements. Additionally, the College should revise current or implement new policies and procedures to strengthen its controls to ensure that all status changes are reported accurately and in a timely manner to NSLDS.