Enrollment reporting criteria and guidelines for compliance

A recent report published by the Consumer Financial Protection Bureau (CFPB) found that inaccurate enrollment reporting by Higher Education Institutions is harming student borrowers in more ways than one. As required by the Higher Education Act, Colleges and Universities are required to report complete and accurate enrollment information in a timely manner. This information is used by Higher Education Institutions, Lenders and Loan Servicers to make determinations on various matters such as repayment dates, interest charges, eligibility for current or future aid and credit reporting. As reported by the CFPB, “we have received complaints from student loan borrowers who report encountering a range of problems that may be driven by incomplete or inaccurate reporting of enrollment status information.”

The responsibility for reporting remains with the College or University, regardless of contracting with a third-party to assist with the submission of its enrollment data to the Department of Education. When this reporting is not complete or accurate, the ramifications to the student can include the following:

• Loss of eligibility for future financial aid funding due to inaccurate reporting of the student’s period of continuous enrollment
• Incorrect accrued interest calculations
• Unexpected student loan bills
• Loans unexpectedly entering repayment prematurely or during an eligible enrollment period
• Penalties and late fees
• Errors reported on the borrower’s personal credit reports

This is an area where we see a significant number of findings when performing compliance audits. These findings are often caused by a variety of factors, but most commonly:

• Incorrect treatment of end-of-term drops
• Incorrect reporting for graduate (or undergraduate) students who are undergoing a degree audit or other administrative requirement before conferral of degree
• Incorrect reporting for modular and borrower based academic years
• Incorrect determination of withdrawal or graduation date when attendance is not taken
• Incorrect reporting by the third-party servicer with minimal oversight by the College or University

Listed below are steps you can take to ensure compliance with this complex and ever evolving process:

• Clearly define roles and responsibilities regarding the origination and reporting of enrollment information among the academic, registrar and financial aid personnel
• Ensure that there is timely and frequent communication with the third-party servicer
• Review internal procedures to ensure there are controls in place to detect any late or inaccurate submissions
• Review procedures for ad-hoc reporting for non-standard or non-mandatory terms
• Review relevant guidance from the Department of Education (see resources below)

Resources:

• NSLDS Enrollment Reporting Guide
• Department of Education Regulations for Enrollment Reporting
• Dear Colleague Letter Library

For more information on this topic, or to learn how Baker Tilly higher education specialists can help, contact our team.