Whenever you have questions about a compliance audit, check with the Audit Resource Center to get the answers you need.
What are the major changes in the NSLDS Enrollment Reporting Guide, released in November 2016?
On November 22, NSLDS released its new NSLDS Enrollment Reporting Guide. The following are some of the changes of which the Clearinghouse feels you should be aware:
- Section 2.2 (begins on page 4) has updated links to NSLDS/ED correspondence (i.e., NSLDS Newsletters, DCLs, etc.)
- Section 3.2 (page 8) no longer contains specific information on the types of grants/loans that should be reported. Now state schools should report enrollment information for students who have received or benefited from any Title IV grant or loan either at your school or a previously attended school.
- Section 4.2.2 (begins on page 12) includes published program length as a component of a unique program (i.e., Unique Program=OPEID, CIP code, Credential Level, and now includes published program length)
- Chapter 4 section 4.4 (begins on page 15) contains information related to program-level data
- Section 4.4.2 (begins on page 15) covers “W” and “G” effective dates and provides greater detail than the previous NSLDS Enrollment Reporting Guide
- Section 4.4.5 (begins on page 17) has additional examples of published program length (page 18) and a resource table (pages 19-20) to assist schools
- Section 220.127.116.11.1 (begins on page 82) provides information related to viewing program enrollment detail on the NSLDS site:
- Section 18.104.22.168 (begins on page 142) is on the NSLDS Enrollment Reporting Statistics page
- Section 22.214.171.124.1 (begins on page 144) is on the Certification Statistics available from the NSLDS site
- Appendix D: SSCR Error Definitions:
- SSCR error code 21’s definition has been revised. Enrollment status effective date must be “less than 30 years in the past” has been changed to must be “less than 45 years in the past.”
- Three new SSCR error codes have been added (77, 78, and 79)
Some students appear not to have been submitted to NSLDS in a timely fashion. How can I evaluate the correct reporting timeframe for these students?
Typically, when an auditor is questioning reporting timeliness, it means that he or she has found that information appears not to have been submitted to the National Student Loan Data System (NSLDS) in a timely fashion. In many cases, this type of finding just needs a closer look to establish the NSLDS reporting timeframe. (Reference federal regulation(s) 682.610/685.309.)
For example, Sally Smith dropped to less than half-time during the fall semester on October 14, but her instructor did not notify the institution until November 12. While the date Sally began attending as less than half-time is October 14, the institution did not become aware of the change until November 12. When evaluating compliance reporting, it is important to remember that the “compliance clock” starts to tick the date your institution is made aware of a status change.
What is an SSCR?
An Student Status Confirmation Report (SSCR) is a roster of students who have Title IV loans or grants disbursed by your school. The roster is populated by your school when your financial aid office enters information into the COD (Common Origination Disbursement) system to start the loan process for your students.
Once the information is entered into COD, it is transmitted to NSLDS, which populates the roster. The student roster is then sent to the Clearinghouse, who as your institution’s authorized agent, responds to the rosters. The response the Clearinghouse sends is comprised of the most recent information your school reported in your enrollment transmissions.
How often does the Clearinghouse respond to Student Status Confirmation Reports (SSCRs)?
The Clearinghouse schedules and processes a Student Status Confirmation Report (SSCR) every month for each of our participating schools. Typically, each roster is received from the National Student Loan Data System (NSLDS) around the first day of the month and processed within 15 days of receipt, per guidance from Dear Colleague Letter 14-07.
How often is enrollment reported to the Clearinghouse?
Each institution that participates with the Clearinghouse has a unique enrollment reporting schedule, tailored to its academic calendar. The Clearinghouse recommends reporting at least every 30-45 days, and submitting First-of-Term enrollment files within about three weeks of your institution’s term start date. This timeframe helps ensure your institution’s compliance with federal requirements.
What is the timeframe for reporting to NSLDS? Is it 30 or 60 days
The regulations published by the Department of Education require that institutions complete and return their Student Status Confirmation Reports (SSCR) within 15 days of receipt. Not to worry, sending your data to the Clearinghouse in a timely fashion and following the guidelines for your planned transmission schedule and error resolution enables the Clearinghouse to complete this requirement on your school’s behalf.
The other portion of the regulations state that an institution must report a student status change whenever a student drops below half-time (i.e., less than half time, withdrawn, or graduated) within 60 days of determining the status change. You can report the status change via another SSCR, if your school plans to send one within 60 days. The NSLDS Enrollment Reporting Guide notes that schools must report enrollment information at least every 60 days, see page 38.
Do SSCRs go out at least every 60 days?
Yes. The Clearinghouse schedules and processes a Student Status Confirmation Report (SSCR) every month for each of our participating schools. Each roster is typically received from the National Student Loan Data System (NSLDS) around the first day of the month and is processed within 15 days of receipt, per guidance from Dear Colleague Letter 14-07.
How does the Clearinghouse know who to send my enrollment data to if the information is not requested through the SSCR process?
While the Clearinghouse primarily serves school clients, our participants also include members of the education finance community. These organizations provide the Clearinghouse with their borrower portfolios, typically monthly. The Clearinghouse uses the student borrower lists to identify which lenders, servicers, and guarantors need to know about specific students’ changes.
Is compliance for retroactive status changes determined by the status change effective date or the certification date?
When a status change is discovered after it has occurred, compliance is determined based on the date your institution identifies the status change (“date of determination”). The applicable regulatory references are §682.605 and §668.22(b) or (c).
A student did not tell me that he or she wasn‘t returning in the fall and wasn’t enrolled for the summer term. The student just didn’t show up when the fall semester started. Is the student’s withdrawal status start date effective the end of the spring semester? Is this a compliance issue?
Because summer is not a required term for many schools, the regulations make room for situations like this one.
There is specific guidance on handling students who do not inform you that they are not returning for the next regularly scheduled term in the NSLDS Enrollment Reporting Guide, see pages 17-18. As long as you have “reason to believe” that the student will return for the next regularly scheduled term, the student should not be reported as withdrawn until the determination is made that the student is not coming back, or until 30 days from the start of your school’s new term.
The Clearinghouse assists your school in this process by generating withdrawals based on your First-of-Term transmission. We compare your First-of-Term file for the new term to the last file for the previous term to identify missing students. Once missing students are identified, we generate a “Withdrawal” status on their records, which is effective on each student’s last reported date of attendance.
There are students in my sample who were not enrolled during the summer and did not attend in the fall, but their withdrawal wasn’t sent to NSLDS until after the fall term started. These records appear to be out of compliance. How do I evaluate the timeliness of these records?
Follow the guidance on pages 17-18 of the NSLDS Enrollment Reporting Guide, which explains that:
“Students are considered to be in school and continuously enrolled during academic year holiday and vacation periods, as well as during the summer between academic years (even if not enrolled in a summer session) as long as there is reason to believe that they intend to enroll for the next regularly scheduled term. For example, students should not be reported as “Withdrawn” at the end of the spring term if they are expected to re-enroll for the fall term. If they do not return as expected, the status must be changed to “Withdrawn” within 30 days of that determination, or within 30 days of the start of the new term, whichever occurs first, with an effective date of the last date of attendance.”
The Clearinghouse helps schools determine which students did not return for the next regularly scheduled term by generating withdrawals based on the school’s First-of-Term transmission. We compare your First-of-Term file for the new term to the last file for the previous term to identify missing students. Once missing students are identified, we generate a “Withdrawal” status on their record, which is effective on each student’s last reported date of attendance.
Evaluating compliance for these records falls within the guidance contained in the paragraph above from the NSLDS Enrollment Reporting Guide and federal regulation(s) 682.610/685.309. We also recommend you review the date of determination regulation, 682.605.
Our auditor asked me to provide enrollment reporting for specific students. How do I do this?
The Clearinghouse secure site provides information regarding enrollment reporting for each of the student records your institution transmits.
You can review the record for each student the auditor is questioning by following these steps:
- Log in to our secure site at www.studentclearinghouse.org by clicking “User Login.”
- Click the “Student Look Up” tab.
- Enter the student’s Social Security number.
- Select “Enrollment History” to view the enrollment information you reported to us.
- Select “Enrollment Data Reported to Lenders, Servicers, and Guarantors.”
- Select “NSLDS SSCR Notification History.”
These screens provide your auditor with a timeline of the available enrollment reporting. You can print any of the screens or save them as screen shots or PDF files and provide to your auditors.
How can I view enrollment reporting completion through the Clearinghouse website and NSLDS?
Clearinghouse participating schools can access student-level enrollment information via the Clearinghouse secure site. Please inquire with the school about its access and request the following from them:
- Enrollment history
- Enrollment data reported to lenders, servicers, and guarantors
- NSLDS notification history
My auditors are asking for a SCHER1 report. What is this report and where is it located?
The SCHER1 is a report generated by the National Student Loan Data System (NSLDS), which is the data system that collects enrollment information for the Department of Education. The SCHER1 report is a compilation of your institution’s transmitted SSCRs with a summary of the transmission dates, valid records, and error records.
The Clearinghouse cannot provide this report to you. Although we have a similar report that summarizes your institution’s SSCR transmission history, including the date an SSCR was created by NSLDS, the date the SSCR was received by the Clearinghouse, and the date the SSCR was returned to NSLDS. This report is located under the “Student Reporting” tab on the Clearinghouse secure site (select “History of NSLDS SSCRs Processed by the Clearinghouse”).
How should my school report unofficial withdrawals through the Clearinghouse to NSLDS?
Unofficial withdrawals are an extremely common occurrence among schools. The Clearinghouse understands this information needs to be reported to NSLDS and we offer two ways for your school to do so:
- Use the online update feature via the Student Look-Up tab on our secure site.
- Schedule an enrollment file that contains the withdrawals.
We recommend you report unofficial withdrawals as soon as possible. If a student re-enrolls after an unofficial withdrawal, it is important to remember that you must capture both the withdrawal and the enrollment. For more information on how to update both records, please contact us at firstname.lastname@example.org.
Is an audit of the Clearinghouse completed annually?
Yes, an audit of the Clearinghouse is completed annually, typically between June and October. Our annual audit complies with requirements contained in federal regulation 668.23.
When is the annual Clearinghouse available on the public Clearinghouse website?
The Clearinghouse’s annual audit is typically posted to our public website in mid-to-late October.
What documentation should I keep from my enrollment reporting processing at the Clearinghouse?
Audits sometimes prompt a need for documentation regarding enrollment reporting. In order to be prepared for a request for this information at any time, we recommend you maintain the following information for audit purposes:
- Electronic copies of your enrollment files submitted to the Clearinghouse.
- Copies of your error reports. While these are currently not printable, you can capture screenshots and print the errors as you correct them using our “Error Resolution on the Web” tool.
For compliance reporting purposes, what is the date of determination used for the “Approved Leave of Absence” (enrollment status code “A,” commonly known as “Approved LOA”) status?
Because the “A” (“Approved Leave of Absence/LOA”) status is deferrable, the date of determination doesn’t apply to it. The date of determination – for timely reporting within 60 days to NSLDS – is applicable specifically to non-deferrable statuses (i.e., “L,” “W,” “G”).
Please see 682.610/ 685.309, “Enrollment reporting process…Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that— (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has 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…”
For compliance reporting purposes, what is applicable for students who are on an Approved Leave of Absence (“A” enrollment status code)?
Students who are on an “Approved Leave of Absence” must have their enrollment certified at least every two months, per the Department of Education (NSLDS’ Guide, page 2). You can report these students to the Clearinghouse every 30-45 days (use the “A” enrollment status code) via the enrollment reporting you submit for your school’s student population.
Who can I contact to talk about specific compliance enrollment reporting questions?
To request assistance from a member of the Audit Resource Team, email us at email@example.com.