Executive Director Update - November 12, 2015

Last year, the U.S. Department of Education released new NSLDS reporting guidelines related to the 150% subsidized Direct Loan eligibility. After lengthy discussions with the Department and several webinars conducted jointly by the Department, AACRAO, and NASFAA, those new reporting regulations went fully into effect October 1 of 2014. While most institutions are now reporting these new program-level enrollments, we continue to hear from our members of a number of challenges that have resulted from the new NSLDS reporting requirements or from decisions made by the Department regarding enrollment verification for student loans.

I want to thank our colleagues from Colorado who took time to meet with me on a conference call and provide detailed examples of some of the ongoing issues. These include dramatic increases in last-minute enrollment verifications for loan deferrals, increases in errors in enrollment reporting to the NSLDS, and problems with the new Enrollment Reporting Statistics functionality in NSLDS that have suggested, for example, that institutions are out of compliance for the Percent Certified with Program Enrollment when in fact they are not.

There appear to be several issues at play. At our Annual Meeting in Denver last year, the National Student Clearinghouse (NSC) informed us that their contract with the Department for automated enrollment verification for loan deferrals was being cancelled. The repercussions of that decision by the Department are rippling through our campuses, compromising customer service to students, and creating increased workloads for staff. The Department has indicated that they will not be renewing the NSC contract but has offered no alternative. A letter from NASFAA and communications from AACRAO have not received a response from the Department.

Errors in NSLDS reporting have risen dramatically as campuses moved to the new program-level reporting requirements. Since many of our institutions use the NSC to submit NSLDS reporting data, our members have asked the NSC to review its procedures for informing institutions about reporting errors. We have had a number of conversations with the NSC and anticipate improvements in this area. They have also announced a change effective December 31 of this year that will automatically add students to your SCCR Roster who may have received aid at previous institutions but are not receiving aid at your institution. It is our understanding that these students often seek manual verifications of their enrollment. I encourage you to monitor the NSC communications on NSDLS enrollment reporting and evaluate these changes over the coming months to help ensure that the solutions are effective.

What the Department of Education will do to help address some of our concerns remains another matter. AACRAO and NASFAA will continue to partner to engage the Department but, as some of you have heard me say, writing a letter to the Department can sometimes feel like writing a letter to Santa Claus. Since we are approaching the holiday season, let us hope that the concerns surrounding NSLDS reporting will be heard. We will try to arrange opportunities to discuss these issues with the Department either via a webinar or at our Annual Meeting in Phoenix. We will keep you posted as we learn more and please let us know what you are hearing as well.