By Joan Berkes, Policy & Federal Relations Staff

NASFAA has learned that the Department of Education (ED) suspects a reporting requirement with widespread impact may have a significant number of institutions in danger of compliance findings, to the point where letters to institutional presidents are probably forthcoming. Relatively new data submission requirements for virtually all enrolled students, regardless of program of study or Title IV aid status, seem to be tripping up a significant number of institutions. 

When the 150% limit on Direct Loan subsidy was implemented, the Department of Education (ED) determined that certain new program-level information for individual students would be necessary to calculate and track the duration and usage of a student’s eligibility for loan subsidies. Because this tracking affects students who borrowed loans in the past as well as current borrowers, the information is required for students whether or not they are currently receiving aid, and whether or not their current program is Title IV-eligible.

Specifically, ED expanded the data collected by NSLDS to include a student’s credential level (e.g., certificate, associate's degree, bachelor's degree), Classification of Instructional Program (CIP) code, and the published length for the student’s educational program.

All schools that participate in any of the Title IV programs must report this program-level information for all students who appear on the roster file that is sent to the school (or the school's servicer) from NSLDS. This reporting requirement includes:

• All students who are enrolled in a program leading to a degree or certificate (including those with undeclared majors), even if the program is not Title IV-eligible.
• Students enrolled in coursework that does not lead to a degree or certificate, but for which the student may nevertheless receive Title IV aid (e.g., preparatory coursework, certain types of teacher certification coursework, and comprehensive transition programs for student with intellectual disabilities). For reporting purposes, this type of coursework is considered a “program” even though the school awards no credential.

ED expects that the overwhelming majority of students should have program-level enrollment reported about them. However, an ED review of NSLDS data shows that a large number of schools have program-level enrollment that is significantly lower than expected, indicative of a possible reporting compliance issue. ED plans to contact these schools in the coming months, probably by letters to presidents.

NASFAA urges schools to check the percentage of their students for whom program-level enrollment has been reported by viewing the Enrollment Reporting Statistics page on the NSLDS Professional Access site. If the percentage seems low, ED encourages the school to investigate further whether there are some students for whom program-level enrollment is missing. 

Schools should also check their procedures to ensure their reporting is complete and accurate. For example, ED has found that program length is sometimes missing or likely misreported, even though other data is present and appears logical.

Additional information can be found in an Electronic Announcement posted May 13, 2016 (150% Direct Subsidized Loan Limit: Electronic Announcement #22), and on IFAP’s "150 Percent Direct Subsidized Loan Limit Information" page.

Publication Date: 6/17/2016

Comments Disclaimer: NASFAA welcomes and encourages readers to comment and engage in respectful conversation about the content posted here. We value thoughtful, polite, and concise comments that reflect a variety of views. Comments are not moderated by NASFAA but are reviewed periodically by staff. Users should not expect real-time responses from NASFAA. To learn more, please view NASFAA’s complete Comments Policy.