Making federal enrollment reporting palatable

John Humphrey & Christopher Barrett

2017 Annual Conference

The University of Rhode Island

• Founded in 1892 • Main campus in coastal

Rhode Island • ~16,000 students • ~3,000 faculty/staff • SIS: PeopleSoft 9.0 • Federal Reporting: NSC

The Regulatory Environment

Federal Enrollment 101 • Institutions must certify enrollment of students

receiving federal financial aid (F, Q, H, L, A, W, G, D, X, and Z)

• Institutions send campus and program level info (CIP code) to federal government

• Reporting allows student loan deferment • Reporting keeps institutions FA eligible • Anticipated Completion Date (ACD) drives

servicer notices to students

Federal Enrollment: The Players Department of Education – federal agency

– Federal Student Aid (FSA) – division of DOE managing grant/loan funds governed by Title IV

• National Student Loan Database (NSLDS) – federal aid servicing

• Common Origination & Disbursement (COD) system (awarded federal funds submitted via this system)

• Lenders & servicers of federal loan programs (Navient, AES)

National Student Clearinghouse – non-profit, non-government entity serving higher ed

National Student Loan Database (NSLDS)

• Centralized repository for student info on Title IV aid recipients (i.e. Direct Loans, Perkins, Pell, FFELP)

• Only for students with federal loans & grants (at any institution)

• Transmits data to and from lender/servicers of loans (to track loan deferments, repayment schedules, etc.)

• Expect you to report status changes within two months • Regulations 34 CFR 685.309(b), 682.610(c), 674.33(g)

“X” enrollment status required for resolving incorrectly reported

program

2016 1996 2011 2014 2013 2015 2012 1997-2010

NSLDS Enrollment

Roster at least twice a year

Extended GE reporting deadline

Initial GE reporting deadline

2011-12 GE reporting due

NSLDS requires new data submission format for SSCR roster

New less-than-half-time status

AGD requirement

NSLDS Enrollment Roster response spacing

adjustment

Program-level and Q status (for 3/4 time)

requirements

Reporting frequency changed to every 60

days

NSLDS requires response

within 15 days of roster receipt

NSLDS institutes new certification date logic for

summer and non-compulsory term reporting

NSLDS Enrollment Reporting Statistics Page released

New instruction to report unknown or unavailable student addresses as (“UK”) in address

fields

2008-09 thru 2013-14 GE reporting due

2014-15 GE reporting due

Reporting X or Z records without program-level data no longer negatively impacts Enrollment Reporting

Statistics • No changes for 15 years • 15 changes in 5 years (2011-2015),

including 8 changes between 2014 and 2015

• Changes growing in frequency and complexity

Gainful Employment (GE) disclosure

requirements take effect

Roster errors must be corrected within 10 days

Slide Courtesy of NSC

The Big New Rule: 150% Time • Effective July 1, 2013 • Applies to 1st time borrowers of fed subsidized loans • Students who exceed 150% of a program’s published

length will lose subsidized loan eligibility (so interest accrues like an unsubsidized loan)

• This means institutions must now report program information on students

• Put another way when a student starts and stops a different CIP code, you need to report that

• Stops reported as a program withdrawal (W)

150% Time: Technical Implications • Report for all students w/FA pursuing credentials

(certificates to doctorates) • Institutions must send credential level/program length

(based on full-time enrollment; time in years) • Program length consistent for all students in program • Length must follow NSLDS guidelines on definition of

year and min and max time for credentials • See NSLDS 150% Direct Subsidized Loan Limit:

Electronic Announcement #22

150% Time: Complicated Example New student enters school on 9/1/17 pursuing journalism and political science full time. On 9/15/17, student drops journalism and adds math.

Campus Info: Status F Status Date: 9/1/17

Program Info Journalism: Status W Status Date: 9/15/17 Political Science: Status F Status Date: 9/1/17 Math: Status F Status Date: 9/15/17

150% Time: Overly Complicated Example Whoops. Actually, we mixed up records. The student dropped journalism but never added math. Enter the X status • For students who never attended a program • Good for students admitted & never attended or

retroactively withdrawn • No program status date required

(NSLDS sets it to certification date)

150% Time: Overly Complicated Example For our example, we’d switch math to Never Enrolled “X” with a status date matching the certification date.

Campus Info: Status F Status Date: 9/1/17

Program Info Journalism: Status W Status Date: 9/15/17 Political Science: Status F Status Date: 9/1/17 Math: Status X Status Date: Cert Date

Checking Your NSLDS Grade

NSLDS Enrollment Reporting Profile Enrollment Reporting Statistics

Must keep >90%

Non-required Summer Guidance • NSLDS considers students in school during

summer/vacation periods if non-required terms • NSLDS keeps asking in summer for enrollment info;

consensus is to report spring enrollment status* • If known a student will not return, report W immediately • If student unexpectedly fails to return, W must be the

last day of attendance

(*sort of; NSC suppresses less than H enrollment to keep students in deferment)

Leaves/Withdrawals Guidance • NSLDS stops asking about students after two

campus W certifications • Hence, backdated institutional withdrawal/leaves

after final term transmission must be manually reported (unless you send a post-term W file)

• Leaves exceeding 180 days must be converted to W in NSLDS (regardless of SIS status)

Graduation Guidance • G locks in time and may protect subsidy • G reported by program (so possible G and W) • If you hold conferral until balance settled and date

retroactively, you may miss timely reporting period • Remember, NSLDS stops asking after two Ws.

Hence, students who graduate without enrollment need manual update.

Lessons Learned

Prevent Errors • Avoid SIS customizations if possible

– Understand all consequences of customizations – Keep customizations current with regulations

• Run data checks before file transmission – Complete address, including zip code – Birthdays – Students with concurrent matriculating/non-matriculating

status – Missing CIP codes – Students with prior anticipated completion dates (ACDs)

Read Error Reports

• PeopleSoft returns an error report for NSC files (aligns with NSC errors, fix them first and rerun file!)

• If use NSC, resolve red and black errors (black errors kick out at NSLDS)

• Resolve NSLDS roster errors (required within 10 days by regs)

Use Errors to Inform Policy and Procedure Change

• Knowing where your errors come from allows you to work to prevent them

• Recognize most errors are not an IT problem • Continuously educate and inform academic units of

errors and their role in creating them and therefore fixing them

Examples of Error-Driven Changes

• Discontinued custom processes for NSC reporting and moved to SIS-delivered process

• Required consistent dating rules for changes in programs (Moved from past/future dating to transaction date)

• Systematically identified and updated students with past anticipation completion dates (ACDs)

• Proactive outreach to students that have not enrolled for future term as expected (Prevents retroactive enrollment and identifies withdrawn students.)

Examples Continued • Educated faculty on the need to report no shows

during add period (first 2 weeks at URI) – Allows us to withdraw students who never show before first

file transmission

• Worked with Admission to revoke admission for first-time student no-shows, so student is not reported.

• Re-defined institutional policy to calculate date of determination for graduation – Informed auditors – Communicated the deadlines to academic units and

enforced the deadlines

Examples Continued • Systematically identified students with concurrent

matriculating/non matriculating status • Re-assigned processing of leaves and withdrawals to

one primary and one back-up staff to ensure consistency and timeliness in processing

• Ensure that approved petitions resulting in a backdated withdrawal/leave are manually reported in NSC/NSLDS

Examples Continued

• Worked with Financial Aid to provide access to NSLDS for Registrar person responsible for reporting

• Follow-up on students with SSN errors. – Stop future FA for students until resolved. – Block registration for future terms for students who do not

comply. We now view this similar to bad check or credit card payment issues.

Why use NSC? • NSC creates report format for NSLDS • NSC modifies report when regulations change • NSC checks for ~173 errors • NSC calculates withdrawals • NSC checks SSN against millions of others to spot

conflicts • NSC provides enrollment verification, deferment form

completion and transcript services

Helpful Resources • NSLDS Reporting Guide • FSA Dear Colleague Letters • NSC Audit Resource Center (for NSC members) • NSC Clearinghouse Academy • SIS Higher Education Users Group (e.g. HEUG, BUG)

• Chris is happy to share his HEUG presentations or download them from the HEUG website

Questions?

Please be sure to fill out the session evaluation at:

neacrao.org/feedback Thank you!