Posted Date: May 13, 2016

Subject: 150% Direct Subsidized Loan Limit: Electronic Announcement #22 - Important Reminders About Program-Level Enrollment Reporting to NSLDS

This Electronic Announcement reminds schools of the critical importance of complete and accurate reporting of program-level enrollment information to the National Student Loan Data System (NSLDS^®). Information to help schools meet the reporting requirements is also provided below.

Complete and Accurate Program-Level Enrollment Reporting

Complete and accurate reporting of a student’s academic program enrollment information includes reporting, among other things, the program’s length, CIP code, and credential level:

• For all students who are on the NSLDS Enrollment Roster;

• Who are enrolled in a program that leads to a degree or certificate; and

• Who are enrolled in certain coursework that does not lead to a degree or certificate, but for which the student may receive Title IV aid (such as preparatory coursework and certain teacher certification coursework).

Nearly all of a school’s students should have program-level information reported about them.

In particular, program length is used to determine a student’s Maximum Eligibility Period for Direct Subsidized Loans to determine whether the student might lose interest subsidy under the 150% Direct Subsidized Loan Limit. A school’s failure to timely and correctly report this information could, under the 150% limit, lead to retroactive application of the loss of interest subsidy or the improper continuance of loss of interest subsidy.

In addition, the student’s program-level enrollment status—in particular, a graduation status—is used to determine whether the student’s Direct Subsidized Loans can be protected from ever losing interest subsidy.

Inaccurate Reporting of Program Length

We have previously informed schools of issues with program length reporting (in an Electronic Announcement dated December 23, 2014, and 150% EA #17). However, we continue to see program lengths that are illogical and likely incorrect because they appear to be much too short considering the program’s credential level.

Some of these errors appear to be due to incorrect formatting of the Published Program Length field. One example of such an error is reporting 0.4 years instead of 4 years for a Bachelor’s degree program. As we explained in 150% EA #17, the program-length field has six positions and should be zero-filled on either side of an implied decimal point between the third and fourth position. Therefore, a program length of 4 years should be entered as “004000” and a program length of 1.5 years should be entered as “001500”.

In our analysis, we have found program lengths reported for associate and bachelor’s degree programs (credential levels “02” and “03”) that appear to be unusually short given these program’s typical lengths of 2 and 4 years, respectively. As a reminder, a student’s program length is not the period of time that the student being reported has left in the program or the time it is expected for the student to complete (for example, a student attending less than full-time) and it is not affected by circumstances such as transfer credits. Instead, the program length to be reported is how long the program is designed to take a full-time student to complete. For more information on how to determine what program length to report for a particular program, see 150% FAQ MEP-Q7.

With the above framework in mind, we believe that most associate degree programs are traditional programs, and should be reported as being 2 years in length. In cases where the program is an “accelerated” program or a program that is longer than a traditional associate degree program, the program length could reasonably be as short as 1 year and as long as 3 years. Similarly, we expect that most bachelor’s degree programs are traditional programs, and should be reported as being 4 years in length. In cases where the program is an “accelerated” program or a program that is longer than a traditional bachelor’s degree program, the program length may reasonably be as short as 2 years or as long as 6 years.

Because there is a significant number of program-level enrollment records with program lengths that are shorter than the “reasonable” minimums described, NSLDS will be implementing minimum program length edits later this year and will begin rejecting records with program lengths deemed too short for the reported credential level. Before we implement these edits, we will continue to monitor and analyze program lengths that are reported, and plan to reach out to the community to determine whether the minimum program lengths discussed above should be modified. We will also take into consideration, bachelor’s degree completion programs and special admission associate degree programs, both of which should be reported as 4-year programs regardless of their actual program length or what is considered traditional for the credential level. For more information about these special programs, see 150% EA #8.

We have also noted that some of the values reported for a student’s program in the NSLDS “Weeks in Title IV Academic Year” field are not consistent with the “WeeksProgramsAcademicYear” values reported by the school to the Common Origination and Disbursement (COD) System. The value reported for this field is used to convert program lengths that are reported in weeks or months to years. Because the 150% limit is based on program length, the “WeeksProgramsAcademicYear” tag will affect whether the COD System will accept a loan record for a student who is subject to the 150% limit and the “Weeks in Title IV Academic Year” field will affect whether NSLDS determines that the student should keep or lose interest subsidy on outstanding Direct Subsidized Loans. As a reminder, the “Weeks in Title IV Academic Year” field and “WeeksProgramsAcademicYear” reported to NSLDS and the COD System should contain the number of weeks of instructional time that the school has established for its Title IV academic year for the program under 34 CFR 668.3.

Note: For information about common inquiries about the 150% limit received by the COD System, refer to 150% EA #21, posted to the Information for Financial Aid Professionals (IFAP) Web site on May 11, 2016.

Correcting Errors

If a school determines that it had incorrectly reported any of a student’s program-level enrollment information which is used by NSLDS to identify a unique program (CIP Code, Credential Level, and Published Program Length), it must:

• Report the student as never having attended (status X) the program that was associated with the inaccurate reporting, with an effective date equal to the Program Begin Date for that program; and

• Re-establish the student’s program-level enrollment information by reporting the accurate program-level information.

Both of these reporting actions may be submitted in the same batch response file, using two separate program-level (type 002) records.

When NSLDS rejects records for failing edits, NSLDS sends an Error/Acknowledgement file in response to each batch file submitted by the school. Schools are required to correct any errors on this file within 10 days of receipt. We find, however, that many schools (or their servicers) routinely return the same data with the same errors. This practice does not correct the error, and does not meet the requirement to correct errors. Enrollment records that fail NSLDS edits will also lower a school’s enrollment reporting statistics percentage, which could lead to enforcement actions against the school. Schools should refer to the NSLDS Enrollment Reporting Guide, Appendix B – Reporting Instructions, and Appendix D – Error Codes, for guidance on correct reporting. Contact the NSLDS Customer Support Center if there are questions.

Later this year, NSLDS will be creating an ad hoc error report that schools can run to help identify and correct errors.

Reporting of Graduations and Withdrawals

It is very important that schools report graduations and withdrawals in a timely manner, at both the Campus level and at the Program level, as appropriate. These enrollment statuses need to be certified on two consecutive submittals before the student will no longer appear on the school’s NSLDS Enrollment Roster. Many schools have students that remain on their Enrollment Roster for many months or years after the students have withdrawn or graduated. This incorrect reporting will also lower the school’s enrollment reporting statistics percentage, and the school’s published completion/graduation rates.

On March 20, 2016, NSLDS implemented a new Late Enrollment Certifications report. Schools may use this report to identify students that have not been certified recently enough to be counted in the school’s percentage. See NSLDS Newsletter 53 for information on this report. Schools that report online on the NSLDS Professional Access Web site may use the Advanced Search Options on the Enrollment Update page to search for students with a Certification Date end date more than 60 days in the past to identify students needing to be certified with an updated or terminal status. Schools may also use this page to search for specific enrollment status codes, such as to search for students last certified as withdrawn (‘W’) which need to be updated to graduated (‘G’). Please refer to the NSLDS Enrollment Reporting Guide for more information.

NSLDS Enrollment Reporting Resources

For more information about NSLDS enrollment reporting requirements, refer to the October 2015 version of the NSLDS Enrollment Reporting Guide, available on the IFAP Web site. Additional information is available in the NSLDS Reference Materials section of the IFAP Web site.

Contact Information

If you have questions about NSLDS or the above information, contact the NSLDS Customer Support Center at 800/999-8219. You can also contact Customer Support by e-mail at [email protected].

Publication Date: 5/13/2016