When Being #1 is Not a Good Thing: NSLDS Reporting 

By: Lawrence Britton, MBA, and Delinda Hall, Ed.D, MBA, Executive Consultants, Financial Aid Services 

Since Fiscal Year (FY) 2016, inaccurate or untimely student status (enrollment) reporting to the National Student Loan Data System (NSLDS) has consistently ranked as one of the top two issues in program reviews or audits, appearing prominently in the Top Ten Findings for Domestic Institutions report. This is often followed closely by “Repeat Findings – Failure to Take Corrective Action.” If your institution has been cited for inaccurate or late enrollment reporting in the Uniform Guidance Single Audit, it is likely a recurring issue flagged as a “repeat finding” (see more details at this studentaid.gov link). Unfortunately, if this has been a concern in the past, it probably remains a current compliance challenge for your institution. If your institution has not faced this issue, be sure to thank your Registrar’s Office, Financial Aid Office, and Information Technology Services team for their collaboration and effective work in navigating this complex area of Title IV federal financial aid compliance. 

Why has enrollment reporting consistently been the top audit or program review finding for educational institutions over the past decade? 

Possible reasons might include: 

• Many institutions mistakenly believe that managing Title IV aid is solely the responsibility of the Office of Financial Aid. 
• Institutions often overlook the importance of implementing routine quality control measures to ensure the accuracy of data submitted to NSLDS, whether they use a third-party servicer or submit enrollment data directly to NSLDS. 
• Institutions often fail to designate a primary department responsible for the accurate and timely reporting of enrollment data to NSLDS. 
• In some cases, the population of student records, enrollment statuses, and program-level details are missing or being inaccurately reported to NSLDS. 
• Untimely reporting of specific student information and submission of the NSLDS roster file. 

Best Practices for Your Reporting Timeline

• Respond to Roster within 15 days, 

• Correct errors within 10 days, 

• Certify enrollment data at least every 60 days.

Critical Components of Enrollment Reporting 

• Campus Level Reporting – enrollment status: 
  • Full-time 
  • Three-quarter time 
  • Half-time 
  • Less than half-time 
• Program Level Reporting  
  • Academic program 
  • Credential level 
  • Published program length 
• Changes in the student’s enrollment status  
  • Effective date of the status 
  • Anticipated completion date 
  • Timing of reporting 

Why NSLDS Enrollment Reporting Matters 

Effectively managing Title IV programs relies significantly on the accuracy of enrollment information reported by schools. Enrollment reporting matters because the data is used to: 

• Determine if the student is still considered enrolled in school,  
• Ascertain whether the student must begin repayment of their federal student loans 
• Decide if the student is eligible for an in-school deferment. 
• Calculate the student’s loan repayment grace period, based on their last date of attendance. 
• Contribute to data used to calculate Gainful Employment/Financial Value Transparency (GE/FVT) reporting.  

Which administrative area of the institution is responsible for executing the enrollment reporting requirements?   

At most institutions, this question is a subject of intense debate.  No administrative area is eager to assume this responsibility for enrollment reporting, because of the complex regulations mired in the details of students’ academic records, and the frequent reporting requirements. Collaboration between Academic Records/Registrar, Financial Aid, and Information Technology Services is essential for consistent and precise reporting. Since enrollment and program-level data are academic records at most institutions, the Registrar is typically responsible for ensuring the accuracy and timeliness of reporting enrollment data to NSLDS. 

What if my institution contracts with a third-party servicer to comply with the Enrollment Reporting requirements?   

Many institutions utilize the National Student Clearinghouse (NSC) to fulfill enrollment reporting requirements to NSLDS. While your institution may find NSC’s services reliable, the institution, not the third-party servicer, is ultimately responsible for notifying NSLDS of student enrollment status changes. Relying on the Clearinghouse as a third-party servicer for Enrollment Reporting and not validating the data in NSLDS exposes the institution to increased risk. 

Remember: The administration of Title IV Federal Financial Aid programs is an institutional responsibility. 

What if my institution faces an Audit or Program Review finding of Inaccurate or Late Student Status? 

Often the program review requires corrective action that includes file reviews covering certain periods — either specific term(s) or academic year(s). The resolution to such a finding is both time and labor intensive. Completing the file review amid ongoing operations by academic records staff members is nearly impossible to complete within the constraints of the deadline offered. A deep understanding of enrollment history recorded in the Student Information System and NSLDS is needed. Please contact Financial Aid Services (FAS) if you would like to discuss how we can assist your institution in addressing some of these compliance challenges.  

Best Practice Checklist 

Timeliness: 

• Submit enrollment data within established deadlines.  

• Develop an electronic enrollment reporting schedule. 

• Continuously track reporting schedules to ensure timely updates. 

Accuracy and Data Integrity: 

• Routine validation and confirmation of data that resides at NLSDS 

• Confirm student details such as name, program, campus, and enrollment status before submitting data. 

• Perform data quality checks to identify and correct errors. 

• Does the system include the required population for each enrollment reporting instance? 

• Is the system identifying enrollment status changes at both campus and program levels for each reporting instance? 

• Regularly review and update institutional contact information for both submission purposes and inquiries. 

• Develop clear procedures for handling changes in enrollment, including withdrawals and transfers. 

• Originate loans as early as possible. 

• Add students to the transfer monitoring process. 

Standardization: 

• Institutions have the option to report the enrollment data directly to NSLDS by using the online process or batch process through the Student Aid Internet Gateway (SAIG). 

• Consider using a third-party servicer for enrollment reporting. 

• Adhere to standard data fields and reporting formats. 

Communication and Training: 

• Keep open lines of communication with the reporting system provider for troubleshooting and inquiries. 

• Ensure stakeholders are informed about updates and reporting schedules. 

• Routine training and knowledge transfer (amidst staffing turnover) for all departments collaborating on the requirements for Enrollment Reporting. 

• Create and monitor institutional policies and procedures.

Financial Aid Services understands the complexities of NSLDS reporting and can help you navigate confidently these challenges. We offer expert guidance and support to ensure your institution maintains accurate data, meets deadlines, and avoids costly penalties.  

Partner with FAS and learn how we can help your institution achieve seamless NSLDS reporting. 

 

REFERENCES 

2024-2025 Federal Student Aid Handbook, Volume 2, Chapter 3

NSLDS Enrollment Reporting Guide – November 2022. 

Federal Student Aid Training Center, Learning Track, School Eligibility, 2024-2025 Audits and Program Reviews