Reporting Compliance Issue May Generate Letters to School Presidents

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

Erin T | 6/19/2016 7:51:51 PM


We’re not sure that ED has determined exactly how they will calculate who gets a letter and who doesn’t. We’re also not sure they will disclose publicly what that threshold is. We believe the letters are still in the planning stages, so are not yet imminent. Our best advice is to examine the level at which your school has complied with the requirement to report program-level information for all students who appear on the roster file that is sent to the school from NSLDS.

Please note: the reporting requirements apply to ALL institutions, even those that enroll only graduate students.


Russell J | 6/17/2016 11:33:46 AM

Thank you, NASFAA, for this heads up ... as Amy N asked, what % would be low? Also, is the percent certified with program enrollment" the column that I focus on? Thank you, David H, for the specific direction on viewing this data ...

Sara D | 6/17/2016 11:24:30 AM

Would this also apply to a school that only offers Masters programs, since we are unable to offer subsidized funds, or is this aimed at undergraduate institutions?

Amy N | 6/17/2016 10:42:17 AM

What percentage would "seem low"?

David H | 6/17/2016 10:38:08 AM

To find the NSLDS “Enrollment Reporting Statistics” Report, go to Main Menu, choose the “Enroll" tab, choose "Enrollment Reporting Profile" in green bar, in main section choose the gray "Enrollment Reporting Statistics" box.

Francisco V | 6/17/2016 9:36:20 AM

Any guesses on a timeline that ED is on to send letters to Presidents?

Lori V | 6/17/2016 8:33:55 AM

GREATLY appreciate the heads up on this NASFAA, thank you!

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