Program-Level Enrollment Reporting Requirement
Institutions are required to report students’ enrollment to NSLDS at the academic program level, as well as at the institutional (campus) level, using the new enrollment reporting format no later than with the institution’s first submission to NSLDS on or after October 1, 2014.
Program-level enrollment data is required to be reported retroactively for all students enrolled as of July 1, 2014. That is, institutions must report a student’s current enrollment status for any program in which the student is or was enrolled between July 1, 2014 and when the institution begins reporting under the new format. This includes students who may have withdrawn or graduated during that time period. Institutions must report the student’s current enrollment status and do not have to report every change that happened between July 1, 2014 and when the institution begins reporting under the new format.
Enrollment reporting rosters generated beginning October 1, 2014 will be in the new format that includes program-level information.
- Failure to begin reporting under the new enrollment reporting requirements by October 1, 2014 will likely result in:
- Enrollment records being rejected by NSLDS
- School being out of compliance
- Potential sanctions
- Impact to Borrowers
- Potential over-award of Subsidized loans
- Loss of interest subsidy
- Improper loan servicing
IMPORTANT: USDE will monitor institutions’ compliance with the requirement to transition to the new file layouts.
Importance of Accurate and Timely Reporting
Under the 150% Direct Subsidized Loan Limit provisions, if a borrower completes an undergraduate program of study before losing interest subsidy, all outstanding Direct Subsidized Loans that still have interest subsidy under the 150% limit will be permanently protected from ever losing interest subsidy.
While the USDE will correct erroneous subsidy loss determinations that were based on incorrect or untimely reporting on the part of schools, a lack of timeliness in the reporting of completions will cause unnecessary confusion to borrowers.
Failing to report completions at all may cause borrowers to lose interest subsidy when they should not. And, because such determinations are based on the student’s enrollment (and completion) at the program level, it is critically important that schools correctly and promptly report a student’s completion at the program level.
Some schools have reported, and will continue to report, a student as withdrawn (Enrollment Status of ‘W’) while the student’s academic record is being reviewed to see if all graduation requirements have been met. However, once graduation is confirmed the school must submit a change of the enrollment status from ‘W’ to ‘G’. And, the school must set the effective date of the ‘G’ status to the same date that was reported for the initial ‘W’ status. Doing so will avoid a gap that could otherwise result in a student losing interest subsidy.
Reporting Transfer Students on Enrollment Rosters
It is important that enrollment information of Title IV aid recipients who transfer to another institution but who do not receive aid at the new institution be reported to NSLDS like any other aid Title IV aid recipient. Failure to report the enrollment of these students could, among other things, result in the student
(1) Entering repayment on their loans when they should not,
(2) Not being subject to loss of interest subsidy under the 150% limit when they should because of continued enrollment, and
(3) Losing interest subsidy under the 150% limit when they should not because the student completed the program
Therefore, schools should make every effort to add to their enrollment reporting any of their enrolled students who were not included on the NSLDS enrollment roster provided by the USDE but who received Title IV aid at another school.
USDE believes that many schools using a third-party servicer for enrollment reporting believe that adding new students is automatically being done by their servicer if schools provide their servicers with a “full enrollment file”. This is not the case. Most servicers do not add students to the NSLDS enrollment roster because the servicer cannot identify which of the school’s enrolled students are Title IV aid recipients and which are not.
Change to Required Frequency for NSLDS Enrollment Reporting
NSLDS will generate and send roster files to institutions (or to their third-party servicers) on a schedule established by the institution but no less frequent than once every two months. Institutions that currently receive rosters less often than every two months will have their schedules adjusted if the institution has not already made the required change on the Enrollment Reporting Profile Page on the NSLDS Professional Access Web site.
Institutions must, within 15 calendar days of the date that we send the electronic enrollment reporting roster, respond to the roster.
NSLDS Enrollment Reporting Resources
For more information about NSLDS enrollment reporting requirements, refer to the July 2014 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. You can find the New NSLDS Enrollment Spreadsheet Submittal at the following link: https://www.fsadownload.ed.gov/software.htm
Please also refer to Dear Colleague Letter GEN-14-17 for important information regarding changes to institutional enrollment reporting requirements.