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How to Properly Report a Student’s Primary Location Code

It used to be traditional for students to enroll in coursework at only one location. However, traditional is no longer the norm. Today’s students often attend multiple institutions or locations, whatever best satisfies their needs. To meet student demand, institutions offer courses at numerous locations and deliver course material through a variety of ways. A student can attend a morning course close to home, an evening course close to work, and even take a course offered online. If all these courses are offered by the same institution, it is the institution’s responsibility to determine which location is the student’s primary attending location.

The student’s primary location should be reported to the National Student Clearinghouse and associated with the eight-digit official Office of Postsecondary Education Identification (OPEID) location. This is the information that the Clearinghouse uses to respond to the Enrollment Rosters from the National Student Loan Data System (NSLDS).

The NSLDS Enrollment Reporting Guide (page 11, section 4.1 – Location/Campus) provides guidance on this subject. According to the guide, “A student’s primary location is the location where the student is taking more coursework than at any other location… If a school cannot determine which location is a student’s primary location, because they are taking the same number of credits at each location, then the school may choose a primary location to report for the student from the locations at which the student is enrolled.”  The guide also states that students should be reported at the location they are attending and not the location from which aid was disbursed.

What does this mean for Clearinghouse Enrollment Reporting? Students should appear on the eight-digit NSLDS Roster associated with the student’s primary location of attendance.

The Clearinghouse suggests that institutions confirm that the procedures between their financial aid and registrar offices are aligned to ensure that:

  • Student aid is processed properly
  • Data reported to the NSLDS through the COD (Common Origination and Disbursement) system by the financial aid office is consistent with the information maintained and reported by the registrar’s office to the Clearinghouse. This includes enrollment statuses, status effective dates, and information related to the student’s program(s) of study.

If you have any questions about proper reporting, please contact the Clearinghouse at 703.742.4200 (select options #7, #4) or service@studentclearinghouse.org.

We also invite you to “Join the Journey” as the Clearinghouse gets a head start on our 25th anniversary as your trusted partner in 2018 with an academic year filled with new events, services, and more.

Resources

Clearinghouse Academy: Learning resources and events

Compliance Central: Updates, tips and resources to help you stay in compliance

ED to Stop Using Transfer Monitoring and Financial Aid Queries to Add Students Back to Enrollment Rosters

We have important news to share on a change that has been made by the Department of Education (ED) regarding an issue that was negatively impacting the Enrollment Statistics score that the NSLDS calculates for institutions. (NSLDS, or the National Student Loan Data System, is the ED’s central database that keeps track of how much federal student loan debt a student has.)

Why Were Transfer Monitoring and Financial Aid Queries a Problem?

Financial Aid History and Transfer Student Monitoring reports were causing students to be added to the NSLDS’s Enrollment Roster for an institution. Frequently, there was no program-level information associated with these students because they were last reported prior to the 150 percent reporting regulations (when program-level data was not required) or they had not yet enrolled. This resulted in a lower percentage of students with program information being reported and, ultimately, a lower Enrollment Statistics score being assigned by NSLDS for the institution.

New ED Guidance Expected Soon from Federal Student Aid (FSA)

Through our ongoing collaboration with Department of Education (ED), the Clearinghouse was recently advised that ED will no longer use Transfer Student Monitoring or Financial Aid History queries to add students to rosters. The immediate result will be to prevent “pre-150 percent” students and students that have not enrolled from impacting an institution’s certified with program-level score. If your institution’s score has been negatively impacted by this issue in the past, it should not be an issue moving forward.

Federal Student Aid (FSA), the Department of Education office that manages the student financial assistance programs authorized under Title IV, has advised us that they will publish guidance on this change in the near future.

Updates on this topic will continue to be posted. So stay tuned to our Compliance Central page and Audit Resource Center blog for more information as we learn additional details!

We also invite you to “Join the Journey” as the Clearinghouse gets a head start on our 25th anniversary as your trusted partner in 2018 with an academic year filled with new events, services, and more.

Resources

Clearinghouse Academy: Learning resources and events

Compliance Central: Updates, tips and resources to help you stay in compliance

 

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.

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.

2015’s Top 10 Audit Review Findings from FSA Conference

Each year at the annual Federal Student Aid (FSA) Conference, the Department of Education gives a presentation on the “Top 10 Audit Findings.” And every year the findings (for the most part) seem to be the same.

So for this post, we are going to give you the list of the findings along with ways to help prevent those related to “NSLDS Roster Reporting Inaccurate/Untimely Reporting.”

Top 10 Audit Findings, according to the Department of Education:

  1. Repeat Finding – Failure to Take Corrective Action
  2. NSLDS Roster Reporting – Inaccurate/Untimely Reporting
  3. Return of Title IV (R2T4) Calculation Errors
  4. Return of Title IV (R2T4) Made Late
  5. Verification Violations
  6. Pell Overpayment/Underpayment
  7. Student Credit Balance Deficiencies
  8. Entrance/Exit Counseling Deficiencies
  9. Qualified Auditor’s Opinion Cited in Audit
  10. G5 Expenditures Untimely/Incorrectly Reported

“NSLDS Roster Reporting – Inaccurate/Untimely Reporting” is usually one of the top three audit findings each year at the FSA Conference. At the Clearinghouse, our processes are designed to help your school ensure compliance. Here are some ways you can prevent this finding from occurring at your institution.

  1. Review your Clearinghouse schedule: Are you reporting every 30-45 days? If not, modify your schedule on our secure website.
  2. Review the data you submitted to the Clearinghouse: Are enrollment status changes being transmitted properly? Feel free to log onto our secure site to complete random reviews of your students’ enrollment reporting for compliance.
  3. Check your SSCR submission history on our secure site. The reporting should show monthly submissions to NSLDS.
  4. Complete quality checks on your data: Does your data match what is stored in the Clearinghouse database? If not and a correction is needed, feel free to complete an online update via our secure site.
  5. Contact the Clearinghouse with any data integrity or quality issues or questions. We are always happy to help!

2014’s Top 10 Audit & Program Review Findings

Each year at the annual Federal Student Aid (FSA) Conference, the Department of Education gives a presentation on the “Top 10 Audit Findings.” And every year the findings (for the most part) seem to be the same. So for this post, we are going to give you the list of the findings along with ways to help prevent those related to “Student Status – Inaccurate/Untimely Reporting.”

Top 10 Audit Findings, according to the Department of Education

  1. Repeat Finding – Failure to Take Corrective Action
  2. Return of Title IV (R2T4) Calculation Errors
  3. Student Status – Inaccurate/Untimely Reporting
  4. R2T4 Made Late
  5. Verification Violations
  6. Pell Overpayment/Underpayment
  7. Qualified Auditor’s Opinion Cited in Audit
  8. Student Credit Balance Deficiencies
  9. Entrance/Exit Counseling Deficiencies
  10. G5 Expenditures Untimely/Incorrectly Reported*

“Student Status – Inaccurate/Untimely Reporting” is usually one of the top three audit findings each year at the FSA Conference. At the Clearinghouse, our processes are designed to help your school ensure compliance. Here are some ways you can prevent this finding from occurring at your institution.

  1. Review your Clearinghouse schedule: Are you reporting every 30-45 days? If not, modify your schedule on our secure website.
  2. Review the data you submitted to the Clearinghouse: Are enrollment status changes being transmitted properly? Feel free to log onto our secure site to complete random reviews of your students’ enrollment reporting for compliance.
  3. Check your SSCR submission history on our secure site. The reporting should show monthly submissions to NSLDS.
  4. Complete quality checks on your data: Does your data match what is stored in the Clearinghouse database? If not and a correction is needed, feel free to complete an online update via our secure site.
  5. Contact the Clearinghouse with any data integrity or quality issues or questions. We are always happy to help!

*New finding added in 2014.

 

 

What Do You Know About Date of Determination?

Enrollment compliance reporting is based on the date a school discovers that a student dropped below half-time, not necessarily the actual date that the student’s status dropped. Sometimes there is confusion as to when the compliance “clock” starts ticking when evaluating compliance reporting.

According to Volume 5, Chapter 1 of the FSA Handbook:

Date of the institution’s determination that the student withdrew

The date of the institution’s determination that the student withdrew varies depending on the type of withdrawal. For example, if a student begins the official withdrawal process or provides official notification to the school of his or her intent to withdraw, the date of the institution’s determination that the student withdrew would be the date the student began the official withdrawal process or the date of the student’s notification, whichever is later. If a student did not begin the official withdrawal process or provide notification of his or her intent to withdraw, the date of the institution’s determination that the student withdrew would be the date that the school becomes aware that the student ceased attendance.

Keep this guidance handy for you next audit. Questions on date of determination? Contact the Audit Resource Center.