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Audit Peak Season Is Here: How to Find the Answers You Need

The Clearinghouse’s Audit Resource Center (ARC) is hard at work during this peak audit season. As many of our participating schools are currently undergoing their annual A-133 compliance audit, the ARC is fielding inquiries as quickly as possible and with urgency. However, because this is the peak summer season, our response time may be delayed by three business days. Therefore, we wanted to provide some helpful resources to you that you can use to answer your compliance- and audit-related questions.

  • Download and/or print our Audit Guide and the Clearinghouse’s most recent annual audit. Our annual audit is currently underway, so we’ve also provided you with a bridge letter you can use until it is completed and published to our web site.
  • Visit our Frequently Asked Questions. These are the most common questions we’ve received from schools and auditors and may assist you quickly in answering your question.
  • Log onto our secure online portal to view:
    • Student Reporting Details, including:
      • Transmission History
      • NSLDS Reporting (Enrollment Reporting to NSLDS)
    • Student Look-Up Details:
      • Enrollment reporting history, including the information your school submitted for the student, as well as the information sent to NSLDS for the student
  • Understand the 60-day, timely reporting requirement. Per the Department of Education (ED), “accurate and timely reporting” requires Title IV aid recipient enrollment to be certified every 60 days, at a minimum. ED’s requirement aligns with that of the Code of Federal Regulations to report students who “ceased to be on at least a half-time basis,” as stated in regulations 610/685.309.
    • Therefore, to comply with federal reporting requirements, you must submit a Student Status Confirmation Report (SSCR) a minimum of every 60 days. On your behalf, the Clearinghouse complies with this requirement by scheduling an SSCR every month of the year.
  • Count the 60 days from the Date of Determination. Per federal requirements, after a student ceases to be enrolled at least half-time, an institution has 60 days from the date of determination to report the student’s enrollment to NSLDS. The date of determination is the date your institution became aware of the student’s enrollment status change. Typically, the date of determination is subsequent to the effective date of the enrollment status.
  • Select the most comprehensive search options when reviewing student information on NSLDS.In order to confirm your reporting timeliness, make sure you choose the optimal selections from the “Advanced Display Options” drop-down menus on the NSLDS “Enrollment Detail” screen.
    • Select all active and inactive records for all schools, then click “Apply.” These search conditions will yield the most comprehensive details, including the first instance when NSLDS accepted an enrollment status and its corresponding effective date.

Thank you for your continued collaboration as we work together to create another incredibly successful academic year. For any other questions, please contact auditresource@studentclearinghouse.org.

Resources

NSLDS Statistics:

Compliance Central
Audit Resource Center blog
Clearinghouse Academy

Summer Reporting Update

The following update to our June 29, 2017, post provides information on our plans to help ensure your school’s compliance with the Department of Education’s April 20, 2017, announcement regarding modifications to summer enrollment reporting.

Reporting “Ws” During Summer

The Clearinghouse has approached ED’s guidance on summer reporting conservatively to help ensure your school’s compliance with both ED’s summer reporting requirements and the NSLDS Enrollment Reporting Guide’s requirement to report students via the NSLDS Reporting Roster/SSCR process “…no less frequently than every two months.” Our conservative approach also helps ensure data integrity by allowing for the release of a student’s true last date of attendance (LDA) to NSLDS, if a student who withdraws from all courses does not return for the next regularly scheduled term. As we mentioned in our June 29 post, summer less than half-time statuses are being suppressed by the Clearinghouse on your school’s behalf, as a result of our May 15, 2017, enhancement.  Our update, highlighted below, is surrounding the reporting of withdrawal statuses.

To accommodate ED’s new summer guidance requirements, we recommend you report withdrawals to the Clearinghouse in your summer enrollment/non-required term files, if you are certain the student will not return for the next regularly scheduled fall term. This enrollment reporting should be consistent with and reflect your school’s policies and procedures surrounding these types of withdrawals. The Clearinghouse will subsequently report the withdrawal to NSLDS via the standard Enrollment Reporting Roster/SSCR process, providing the withdrawal’s status effective date as reported by your institution to the Clearinghouse.

Note: The withdrawal record and summer effective date provided by your school will be sent to NSLDS via the standard SSCR process and indicate that the student has separated from your school. However, if the student does return for the next regularly scheduled term, their enrollment will place the student back into deferment and reset the student’s grace period. This conservative approach helps maintain data integrity by supporting ED’s requirement to report the student’s summer LDA if the student does not return for the fall semester.

Historically, the Clearinghouse has reported withdrawals during summer terms and will continue to do so. We are happy to work with you on including withdrawals in your summer enrollment files. Please contact SchoolOp@studentclearinghouse.org for assistance with your enrollment reporting file questions.

The second phase of our enhancement will be implemented in the coming weeks and includes:

  • Suppressing “L” (Less Than Half-Time) enrolled students reported in a non-required term from being added to your school’s SSCR roster.
  • Sending previous non-standard greater than “L” (Less Than Half-Time) enrollment in lieu of Less Than Half-Time enrollment during a non-standard summer term

As we receive additional information and clarification from FSA/NSLDS, we will post updates on our Compliance Central page.

Summer, Less Than Half-Time Reporting for Non-Required Terms to Date

On April 20, 2017, the Department of Education (ED) released new summer enrollment reporting guidance.  The announcement relates specifically to how to report students who are “L” (Less Than Half-Time) time during a non-required, summer term.  Because we understand the impact of this change and when it was announced as the summer term began, the Clearinghouse requested clarification on specific items noted within the announcement from ED on May 1, 2017. We also posted a communication to Clearinghouse participating schools the same day, advising of our inquiry to ED.

In response to the above guidance and the urgency of this, we implemented and released an enhancement on May 15, 2017, that changes how “L” (Less Than Half-Time) enrollment statuses are reported to NSLDS during non-required summer terms.

  • This change complies with ED’s requirements as it suppresses “L” (Less Than Half-Time) statuses during non-required, summer terms, and therefore, prevents them from being reported to NSLDS.

This is the first of multiple enhancements to fulfill this requirement.

PLEASE NOTE: The Clearinghouse will notify NSLDS of students reported to us by schools in a withdrawn status during the summer term.  Your institution should only report withdrawn statuses during the summer if you do not anticipate the student returning during the fall term.

What’s Coming

We will continue to seek clarity from the Department of Education on how to appropriately certify and send out spring enrollment data during the summer instead of summer data as is cited in the new summer enrollment reporting guidance.

In addition, to best adhere to the evolving guidance from ED and the data integrity needs of our participating institutions, by September 1st, we will be completing the following enhancements:

  • Suppressing “L” (Less Than Half-Time) enrolled students reported in a non-required term from being added to your school’s SSCR roster.
  • Sending previous non-standard greater than “L” (Less Than Half-Time) enrollment in lieu of Less Than Half-Time enrollment during a non-standard summer term

This newly implemented change to Clearinghouse reporting to NSLDS assists schools by allowing them to report the actual enrollment status of a student during the non-required, summer term while still meeting the requirement noted by ED.

We value our partnership with you and encourage you to please continue to visit our Compliance Central page for updates on the summer “L” (Less Than Half-Time) requirements, as well as for a “Coming Soon! G from DegreeVerify Enhancement” announcement and other resources. Also, please be on the lookout in August for our new Fall 2017 Clearinghouse Academy Live in Your Neighborhood Schedule.

For additional information, see our FAQs below. If you have any questions, please contact SchoolOp@studentclearinghouse.org.

Frequently Asked Questions


What did the Department of Education announce regarding reporting Summer LTH records and when?

On  April 20, 2017, the Department of Education published an e-announcement regarding the compliance requirements for reporting less-than half-time (L) students during non-required summer terms.  The letter indicates that students should not be reported to NSLDS as less than half time during non-required summer terms.  In lieu of reporting the less than half time status, ED indicates that the student’s last certified spring enrollment status should be sent throughout the summer with a new certification date.


Does this new requirement require a change to my compliance enrollment reporting that I send to the Clearinghouse?

No.


What has the Clearinghouse done in response to the announcement from ED?

The Clearinghouse requested clarification on specific items noted within the announcement from ED on May 1, 2017 and posted a communication to Clearinghouse participating schools on May 1, 2017, advising of our inquiry to ED.  On May 15, 2017, we implemented a change to how Less Than Half-Time (L) enrollment statuses are reported to NSLDS.  This change complies with ED’s requirements as it suppresses less than half-time statuses during non-required, summer terms, and therefore, prevents them from being reported to NSLDS.


Will the Clearinghouse continue to send out Withdrawal “W” statuses during non-required terms?

Yes. The Clearinghouse will continue to send out “W” statuses during non-required terms for compliance reporting purposes.  Withdrawal statuses that are reported to the Clearinghouse for students who have financial aid and are included on the SSCR roster from NSLDS will be sent to NSLDS on your school’s SSCR roster response.


How does the new Summer/Non-required ED guidance impact a student’s Subsidized Usage Limit (SULA)?

The new summer/non-required ED does not impact a student’s SULA, as during non-required terms, students are considered to be continuously enrolled, unless, they have indicated otherwise to the institution.  The NSLDS Enrollment Reporting Guide states:

“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 reenroll for the fall term. In this case, schools should continue to report the student’s last enrollment status through the summer months (or through another non-required period of attendance). However, if the student does not return as expected, the status must be changed to “Withdrawn” with the appropriate effective date.”


What can I do to ensure my summer enrollment reporting is correct/reported correctly?

Typically, many schools calculate credit or clock hours differently during non-required summer terms than during required fall and spring terms. For example, a student may be considered half time during the summer months for taking one course, because the summer term is shorter in length and credit/clock hour calculations differ.  Please ensure that withdrawal statuses are only sent to the Clearinghouse during non-required terms when the student has withdrawn completely from the institution, not when the student drops a course during a non-required term.

In addition, if your school has an articulation/consortium agreement with another institution, please ensure to only report the student population that falls under the agreement and is attending your home institution.   Reporting students that fall under a consortium agreement that are not attending your institution as their home institution can cause students to be added to two different institution’s SSCR rosters which is considered inaccurate reporting.

Accuracy in reporting the enrollment status for students enrolled in the summer is crucial compliance enrollment reporting. Please review your enrollment reporting calculations to ensure your summer calculations are accurate prior to submitting your summer file.  If you have any questions, please contact SchoolOp@studentclearinghouse.org.

Federal Student Aid’s (FSA’s) Guidance on Summer Term Enrollment Reporting

On April 20, FSA released its guidance related to Summer Term Reporting. After careful review, the Clearinghouse believes that additional clarity is needed related to the guidance in order to confirm institutional compliance. As a result, we have asked FSA to clarify how the following should be handled by schools:

  1. Correctly determining the certification dates on spring semester data and when that data should be reported, instead of reporting the “Less Than Half Time” statuses during optional summer terms
  2. Accurately capturing a student’s withdrawn status during a summer term with respect to the “Date of Determination” logic
  3. Accurately capturing the correct dates for a student who was “Less Than Half Time” during optional summer terms and who does not return in the fall

Our objective in asking for the above clarifications is to ensure the highest standards of data quality and integrity are reflected in the information being reported. The Clearinghouse is also working to determine if any changes are needed within our process to ensure our summer reporting aligns with the needs of both loan servicers and NSLDS.

We do not anticipate that your school will need to make any changes in your reporting to the Clearinghouse.

Please stay tuned as we await further clarification from FSA, which we will share with you.

If you have any audit or compliance related questions, please contact our Audit Resource Center at auditresource@studentclearinghouse.org.

If you have questions regarding how you should submit your enrollment information, please contact our Data Integrity and Operations Department at schoolops@studentclearinghouse.org.

Important Information about Your NSLDS Enrollment Reporting Score

Federal Student Aid Office to Send Letters of Non-Compliance

On Thursday, March 9, representatives from the American Association of Collegiate Registrars and Admissions Officers (AACRAO), the National Association of Student Financial Aid Administrators (NASFAA), and the National Student Clearinghouse participated in a conference call with staff from the U.S. Department of Education’s Federal Student Aid (FSA) and National Student Loan Data System for Students (NSLDS) offices.

The purpose of the call was to discuss the Enrollment Reporting Statistics score that is calculated and reported for each school, every month on the NSLDS site. During the call, FSA stated that they intend to send letters of non-compliance in the coming weeks to institutions that have a score below 90 percent.

Other key points discussed:  

  • The first series of letters will be sent to an institution’s financial aid administrator and enrollment reporting contacts as designated in NSLDS. Make sure these roles are updated by logging into NSLDS and verifying the correct individuals are assigned to your school.
  • Clearinghouse, AACRAO and NASFAA representatives shared reporting scenarios and examples of student behaviors that can negatively impact the scores. Based upon the information shared, FSA committed to releasing guidance to address several reporting scenarios.
  • FSA agreed to share information on the process schools can follow to request a customized score threshold that will be driven by the behaviors of their students.
  • If you think that the score calculated for your institution is negatively impacted by specific reporting scenarios and/or student enrollment behaviors, you can use the “Leave a Reply” comment feature below to provide private comments to the Clearinghouse or email us at schoolops@studentclearinghouse.org.

As always, the Clearinghouse is committed to working with you on regulatory compliance matters as quickly as possible. Please contact us at schoolops@studentclearinghouse.org, if you have any questions.

Do You Know Your NSLDS Enrollment Reporting Score?

Each month, NSLDS calculates a score based upon the data it accepts through the NSLDS enrollment roster reporting (aka SSCR) process and displays it on this page. Any institution with a score below the acceptable 90 percent threshold of “Percent Certified with Program Enrollment” is subject to receiving a letter from FSA.

Make sure you read our NSLDS Enrollment Reporting Statistics Page FAQs for key summary-level information about the data fields and calculations.

Important NSLDS Change to the SSCR Error Corrections Process

As a part of your compliance reporting service, the National Student Clearinghouse responds to NSLDS on your behalf, providing up-to-date information on your students, who have been identified as possible Title IV Aid or Direct Loan recipients. We work closely with you to ensure your data passes a series of robust validations throughout our enrollment reporting data intake process. In certain instances, there are records reported to NSLDS during the SSCR Roster response process that do not pass NSLDS’s edits and, as a result, are rejected.

Historically, responding to the SSCR Error Report within 10 days fulfills the federal requirement. The Clearinghouse has consistently done this on your behalf and will continue to do so. Recently, NSLDS and FSA have focused on ensuring schools correct students with errors vs. the requirement to respond within the 10-day timeframe. This is emphasized in the most recent NSLDS Enrollment Reporting Guide, published in November 2016, which states on page 7: Schools must also correct any returned errors that are identified by NSLDS within 10 business days.

The Clearinghouse released new functionality in December 2016 so your institution can view and correct these SSCR errors. Our system automatically sends you an email notifying you that your SSCR errors are ready for review. This is a trigger to let you know that the Clearinghouse has received your SSCR Error Report from NSLDS and it is ready to be worked. You can now see and correct SSCR errors through the Clearinghouse’s secure site. (Note: SSCR errors are different than those associated with the enrollment reporting files you send to us, so it’s not unusual if this is the first time you have ever seen SSCR errors.)

Because NSLDS has started to focus more on schools fixing their errors from roster to roster, as your partner, we wanted to ensure we made you aware of this important change and are working in partnership with you to meet these new requirements.

We encourage you to sign up on our Clearinghouse Academy page for our live webinars on SSCR error resolution (as well as the other useful webinars that are also available) or one of our free in-person “Clearinghouse Academy in Your Neighborhood” events, when we come to your area.

Don’t forget to visit our Compliance Central page regularly for updates on this process and other key compliance information.

To learn how to use our SSCR Error Correction functionality, watch our short tutorial.

 

Watch Our Online SSCR Error Correction Tutorial

Our new online SSCR Error Correction system is now live!

For a look at our innovative functionality and to learn how you can view and correct your institution’s SSCR errors on the Clearinghouse secure site, watch our brief online tutorial now.

Correct SSCR/Enrollment Roster Errors Online!

The Clearinghouse is updating the way you view and correct errors on your SSCR Error Reports. We communicated earlier in the year that this new functionality was going to be delivered by year’s end. We are pleased to announce that these functions are now available for you to use.

Our new SSCR error correction functionality moves the entire process online so you can:

  • See which students have SSCR errors and the associated error description
  • Understand how to fix the errors
  • Have greater control of how to correct the errors online

And you can do it all on the Clearinghouse secure Web site.

As NSLDS outlines in its Enrollment Reporting Guide and its latest Newsletter #56, correcting SSCR errors is a compliance reporting requirement. In order to help keep you in compliance, the Clearinghouse returns your SSCR Error Report for you within NSLDS’s timeframe, which we will continue to do even now that our new functionality is in place.

Watch for more information and training on this exciting enhancement through our Clearinghouse Academy. In the meantime, contact us at SchoolOps@studentclearinghouse.org, if you have any questions.

Best Practices to Help You Accurately Report Anticipated Completion Dates

It’s critical that you report an accurate Anticipated Completion Date (ACD) — also commonly known as the Anticipated Graduation Date or AGD — for each student for whom it is required. This enables loan servicers to correctly communicate changing obligations to borrowers as they approach repayment and helps prevent student loans from being converted to repayment either too early or too late.

To help you with your ACD reporting, read the list of best practices on our Compliance Central page, which also contains other helpful enrollment reporting information and resources.