Marist UniversityHigher Education

Finding 2025-001 - Special Tests and Provisions - NSLDS Reporting (Significant Deficiency) U.S. Department of Education - Student Financial Assistance Cluster Federal Pell Grant Program (84.063) Federal Direct Loan Program (84.268) Federal Award Year: 2024-2025 Criteria: Under the Federal Pell Grant and William D. Ford Federal Direct Loan (“Direct Loan”) programs, institutions are required to report enrollment information via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035). 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 verify 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. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus-Level” and “Program-Level,” both of which need to be reported accurately and have separate record types. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record: OPEID, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. When a Direct Loan is made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceases to be enrolled on at least a half- time basis or fails to enroll on at least a half-time basis for the period for which the loan is intended, or a student who is enrolled at the institution and who receives a loan under Title IV has changes his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Enrollment information is used to determine the borrower’s eligibility for in-school status, deferment, interest subsidy, and grace period. Enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported. The enrollment information is merged into the NSLDS database and reported to guarantors, lenders, and servicers of student loans. Context: The University distributes Direct Loans and Pell grants to students and is thus required to report the Campus-Level and Program-Level enrollment information of these students to NSLDS both timely and accurately. Condition: We identified the following instances of noncompliance related to enrollment reporting to the NSLDS for three (3) graduated students from a total of forty (40) students selected for enrollment reporting testing: • For one (1) student, the reporting of final enrollment status was not updated at both the Campus‑Level and Program‑Level. The student completed program requirements outside of standard academic sequencing, and the student’s final enrollment information was not reported to NSLDS within required timeframes. • For two (2) students, the reporting of final enrollment status at the Campus‑Level was not updated following degree conferral occurring after the institution’s customary end‑of‑term enrollment reporting had been submitted. While final enrollment information was subsequently reported at the Program‑Level in a later reporting cycle, Campus‑Level enrollment status was not updated within required reporting timeframes. Cause: Based on discussions with management, the delays in reporting enrollment status changes were related to instances where students completed program requirements or had degrees conferred outside of standard end‑of‑term reporting cycles. In these situations, coordination between degree conferral processes and enrollment reporting processes was not consistently aligned to ensure that Campus‑Level and Program‑Level enrollment records were updated within required reporting timeframes. Effect: The University did not accurately report enrollment status for three (3) of the students tested within the required reporting timeframe. Questioned Costs: None noted. Identified as a Repeat Finding: No. Recommendation: The University should strengthen policies and procedures to ensure that Program-Level & Campus-Level enrollment information is reviewed and submitted within the required reporting timeframes to NSLDS. Views of Responsible Officials: With respect to the findings relating to the timeliness of enrollment reporting, the University agrees with this finding and will take appropriate actions to improve processes to ensure enrollment status records are updated timely in the NSLDS at both the Campus-Level and Program-Level.

Criteria: Pursuant to Federal Register Volume 82, Number 122, an institution must submit Pell Grant disbursement records to the Common Origination and Disbursement (?COD?) system no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. As defined in 34 CFR 668.164(a), the disbursement date is the date that a school credits a student?s account at the school or pays a student or parent borrower directly with Title IV funds received from the U.S. Department of Education or with institutional funds in advance of receiving Title IV program funds. Condition: From a selection of 65 Pell Grant disbursements tested, we identified two disbursements that were reported to the COD system more than 15 days after the respective disbursement dates. Context: Each of the two disbursements were reported to the COD system 16 days after the respective disbursement dates. Cause: Origination records for the 2 students were initially sent on August 31, 2021 and rejected based on pending ISIR transactions not yet processed by CPS. Pell was paid for both students on September 8, 2021. The origination records were resolved and sent to COD on September 24, 2021, 16 days after the Pell paid to the student account. It should be noted that both instances involved a professional judgement review allowing the college to award additional Pell to families. This process can create delays in the process. Effect: Two Pell Grant disbursement were not reported to the COD system within the 15-day timeframe stipulated in Federal Register Volume 82, Number 122. Questioned Costs: None noted. Identified as a Repeat Finding: There was no similar finding in 2021. Recommendation: The College should review the effectiveness of its procedures governing the timely submission of Pell Grant disbursements to the COD system to ensure such records are submitted within the appropriate timeframe. Views of Responsible Officials: We concur. 2021-22 audit indicated that two Pell Grant disbursements were not reported within the 15-day timeframe stipulated in Federal Register Volume 82, Number 122. The origination records were resolved and sent to COD (processing platform) 16 days after Pell paid to the account. Both instances involved a professional judgment review allowing the College to award additional Pell to families. This process can create delays.