Latest Release of NSLDS Enrollment Reporting Guide Addresses Retroactive Enrollment Status Changes
By Jill Desjean, Policy and Federal Relations Staff
On November 16, Federal Student Aid (FSA) released its revised Enrollment Reporting Guide, which includes new language defining the different dates involved when processing retroactive enrollment status changes and explaining National Student Loan Data System (NSLDS) reporting timeframes in the context of those dates. This change does not represent new guidance but, rather, updates existing guidance to more accurately reflect existing regulations.
Federal regulations 685.309(b)(2) and 682.610(c)(2) require institutions to report to NSLDS changes to a student’s enrollment status to less than half-time within 60 days of the date the school discovers that a student has ceased to be enrolled, or has failed to enroll, at least half-time. This date is also commonly referred to as the “date of determination.” This date may be the same as the status effective date, which is the date the enrollment status became effective. As an example, if a student decides on March 1 to stop attending classes and begins the official withdrawal process on the same day, the institution has 60 days from March 1 to report the enrollment status change to NSLDS.
However, in scenarios such as retroactive withdrawal or retroactive determination of a student having met all requirements for graduation, some time may pass between the status effective date and the institution’s date of determination of the enrollment status change. For instance, a student may have ceased attending classes on April 15, but the institution may not have been aware of that fact until May 10. In that case, May 10 is the date of determination, and the institution has 60 days from that date to report the change to NSLDS.
While the regulatory language has always been clear, the NSLDS Enrollment Reporting Guide in the past has not addressed the date of determination. Because of this omission, auditors may have incorrectly cited institutions for noncompliance with enrollment reporting requirements if the auditor incorrectly used the status effective date as the first day of the 60-day reporting window, even if the institution did correctly report to NSLDS within 60 days of the date of determination.
With this latest release of the Enrollment Reporting Guide, auditors will see consistent enrollment reporting requirements in both regulation and guidance, which should eliminate confusion and limit erroneous audit findings. The updated guide clearly distinguishes between status effective date and the date of determination, and provides examples to demonstrate scenarios where such dates would differ.
The National Student Clearinghouse will offer a webinar on Dec. 6, 2017 on this topic.
Publication Date: 11/27/2017
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