Revised Guidance on NSLDS Enrollment Reporting

The U.S. Office of Federal Student Aid (FSA) recently released a revised National Student Loan Data System (NSLDS) Enrollment Reporting Guide. The update was prompted by an issue regarding enrollment status changes and dates of determination.  

Numerous institutions noted that when reporting retroactive enrollment status changes, auditors cited them for failing to report the change in a timely manner. While federal reporting regulations have referenced the "institution's discovery" (determination) of a change, previous guidance did not specifically address the issue.

The date of determination is the date an institution becomes aware of a student's enrollment status change. Per federal requirements, after a student ceases to be enrolled at least half-time, an institution has 60 days from the date of determination to report the student’s enrollment to NSLDS.

According to the latest FSA guidance, "the Effective Date is neither the 'date of determination' nor the date that the school becomes aware of a status change; rather, it is the date that the enrollment status first became effective. In other words, it is not required that the update be received by NSLDS within two months of the Enrollment Status Effective Date; rather, the school must report the retroactive status change in its next scheduled enrollment submission, or sooner if possible, although this might happen months after the actual effective date."

The new guide goes on to provide definitions and examples that help resolve the longstanding issue.

"[A] school may not be aware a student has withdrawn until sometime after the student stops attending. Or, a student may complete the coursework for a degree but it takes the school time to determine whether the student meets all graduation requirements, and then the school would use an Effective Date backdated to the date the school assigns for graduation," the guide proffers. "Even though a school may not be able to report a status change until more than 60 days after the actual Effective Date of that status change, this retroactive reporting does not violate the requirement to report every 60 days."

National Student Clearinghouse is hosting a webinar, "Date of Determination Solved!," on Wednesday, December 6 to delve deeper into the changes in the guide. Registration for the live webinar is currently full, but an archived version of the presentation will be available after that date. AACRAO will provide information on how to access the archived webinar in the coming weeks.


Related Links

National Student Loan Data System Enrollment Reporting Guide - November 2017