Publication Date: April 14, 2014
Subject: Changes to NSLDS Enrollment Reporting: Program-Level Reporting and More Frequent Reporting
Summary: This letter provides important information regarding changes to the requirements for institutional reporting of enrollment information to the National Student Loan Data System. These changes include reporting of additional data, reporting at the academic program level, and more frequent reporting.
Over the next several weeks, we will be implementing some significant changes to the National Student Loan Data System (NSLDS) enrollment reporting process. While some changes relate only to the timing and process of reporting, others require schools to report additional data items and to report a student’s enrollment in an academic program. Most of these changes are required by amendments made to the Higher Education Act (HEA) and to the implementing regulations. These changes also support the Administration’s efforts to provide students, families, policy makers, and others with important enrollment and completion information at the program level.
Schools using a third-party servicer must remember that accurate and timely reporting to NSLDS is the school’s responsibility. If a school’s servicer NSLDS enrollment reporting is noncompliant the school would be held responsible and subject to any appropriate sanctions.
Statutory and Regulatory Provisions
As noted, the changes to NSLDS enrollment reporting discussed in this letter are partially required by statutory and regulatory changes, as follows:
On July 6, 2012, the Moving Ahead for Progress in the 21st Century Act (Pub. L. No. 112-141) was enacted. This law included a limit on the period of time certain borrowers can receive Direct Subsidized Loans (150% Direct Subsidized Loan Limit). Implementing regulations were published on May 16, 2013 and January 17, 2014.
Final regulations, published on November 1, 2013, changed the frequency and manner of enrollment reporting by schools that participate in the Title IV, student financial aid programs.
On January 17, 2014, the Consolidated Appropriations Act of 2014 (Pub. L. No. 113-76) was enacted. Among the new law’s provisions was a directive that the Department submit to Congress a report of enrollment and graduation information of Federal Pell Grant recipients.
Timing of Changes
NSLDS will begin accepting enrollment information that conforms to the changes discussed in this letter as follows:
NSLDS Professional Access Website Submissions – As of April 14, 2014, schools submitting enrollment information online using the NSLDS Professional Access Website may begin reporting the enhanced enrollment data using the new formats and processes. Special instructions are provided to the school when logging in to the online enrollment reporting process. While schools may continue, until October 1, 2014, to submit enrollment information under the current reporting formats and process, that process will end as of October 1, 2014.
Batch Reporting and Spreadsheet Uploading – Beginning July 1, 2014, schools using the batch enrollment reporting or the spreadsheet upload process may convert to the new enrollment roster file layouts with program data by first indicating their preference on their enrollment profile on the NSLDS Professional Access Website. Upon processing of a preference for the new reporting formats, NSLDS will produce and forward to schools (or to their third-party servicers) enrollment reporting rosters in the new format.
All Enrollment Reporting Processes – No later than October 1, 2014, all schools must report enrollment records under the new reporting file layouts regardless of their method of reporting. To emphasize, beginning October 1, 2014, all NSLDS enrollment reporting rosters sent to schools and servicers will be in the new format, regardless of any choices made by the school.
While we encourage schools to implement the necessary changes as soon as possible, all schools must have implemented the necessary changes by October 1, 2014. This October date represents a three-month extension from our previously announced deadline of July 1, 2014. Schools that choose to wait to report using the new enrollment reporting file layouts until after July 1, 2014 must, when they do begin reporting using the new enrollment reporting file layouts, report program-level enrollment information retroactive to July 1, 2014.
For example, if a student withdrew from or completed a program during the period between July 1, 2014 and when the school first reports using the new program level record type, the school would report that withdrawal or completion with their first post-July 1 reporting that uses the new file layouts. And, if this same student then enrolled in a different program, the school would submit two program-level records – one showing the withdrawal or completion from the first program and the second showing the enrollment in the new program with the appropriate status begin date.
Failure to begin reporting under the new enrollment reporting file layouts by October 1, 2014 will likely result in the school’s enrollment records being rejected by NSLDS and the school being out of compliance with the regulatory requirements and possibly subject to sanctions.
More Frequent Reporting
The final regulations, published on November 1, 2013 and effective on July 1, 2014, change the nature and frequency of enrollment reporting to NSLDS. Specifically, the regulations provide that schools must respond to the Secretary’s request for enrollment information (1) within a timeframe specified by the Secretary, (2) in a manner specified by the Secretary, and (3) in a format specified by the Secretary. Under the authority of those regulations, beginning July 1, 2014, we will request enrollment information from schools every 60 days and schools will be required to respond to those requests within 15 days of the date that we send the electronic enrollment reporting roster to the school or to its designated third-party servicer. Note that we are not changing the July 1, 2014 implementation of this 60-day reporting frequency even though we have extended the date when schools must begin using the new enrollment reporting file layouts to October 1, 2014.
Program-Level Enrollment Reporting Required
Because the 150% Subsidized Loan Limitation provisions, including the possible loss of interest subsidy, are based on the borrower’s enrollment in a specific program and not on whether the borrower applied for or received aid for enrollment in that program, schools must report enrollment at the program-level and not just at the school-level. If the student is or was enrolled in more than one program, the student’s enrollment information must be reported for each of the programs. The NSLDS enrollment reporting rosters include recipients of all Title IV loans and Federal Pell Grants. Including Pell Grant recipients will allow the Department to meet the Congressional reporting requirements noted earlier. Note that a student will only be included on the roster once, regardless of the number of different Title IV programs from which the student received funding.
As noted in 150% Direct Subsidized Loan Limit Electronic Announcement # 9, posted to IFAP on February 27, 2014, for the purpose of the 150% Direct Subsidized Loan Limit requirements, NSLDS will use the following information, as reported and certified by schools:
Student’s Enrollment Status – full-time (‘F’), three-quarter-time (‘Q’), half-time (‘H’)
Program Credential Level
Program’s Classification of Instructional Program Code (CIP Code)
Published Program Length (reported in years, months, or weeks)
Number of Weeks in the Program’s Title IV Academic Year
Date Student Began Enrollment in the Program
Special Program Indicator
In addition to meeting the requirements of the 150% Direct Subsidized Loan Limit provisions, program enrollment information will be used by the Department to develop important budget and policy analysis information.
Enrollment Record Types
As noted in 150% Direct Subsidized Loan Limit Electronic Announcement # 9, NSLDS enrollment reporting file layouts will have multiple record types to accommodate enrollment reporting at the institutional and at the program level. The record types are:
Record Type ‘001’: Campus-Level Record – This required record type includes the eight digit OPEID code of the student’s primary enrollment campus location and the student’s institutional enrollment status (enrollment at all locations). It also includes information such as the student’s name, social security number, date of birth, address, and phone number.
Record Type ‘002’: Program-Level Record – Schools must report one or more of this record type that provides program-level enrollment information for the program the student is or was enrolled in. The record includes the program’s CIP Code and Credential Level, the program’s published length and Title IV academic year, the student’s enrollment status in the program, and other information related to the academic program.
Record Type ‘003’: Student’s Email Address Record – This optional record provides the Department with a way to communicate directly with the Title IV aid recipient.
Separate Program-Level Records must be completed for each academic program the student is or was enrolled at the school.
The new NSLDS enrollment reporting file layouts with details on the new record types can be found in the NSLDS Reference Materials section of the Information for Financial Aid Professionals (IFAP) Web site.
New Enrollment Status Code “Q”
As noted above, there will be a new Enrollment Status Code of “Q” for three-quarter-time enrollment. The complete list of enrollment status codes are:
‘F’ - Full-time;
‘Q’ - At least three-quarter time but less than full-time;
‘H’ - At least half-time but less than three-quarter time;
‘L’ - Less than half-time;
‘G’ - Graduated (See special note below about the effective date for statuses of ‘G’);
‘W’ - Withdrawn;
‘A’ - Leave of absence;
‘D’ - Deceased;
‘X’ - Never attended; and
‘Z’ - Record not found.
The enrollment status codes must be reported both in the Campus-Level Record, representing the student’s overall enrollment at the school and in the Program-Level Record, for each of the academic programs the student attended.
Protecting Interest Subsidy
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 Department 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.
Effective date for statuses of ‘G’ – We appreciate that 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, for reasons related to the possible loss of interest subsidy under the 150% Direct Subsidized Loan Limit provisions, 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 a Student’s Enrollment at the Eight-Digit OPEID-Level
NSLDS requires enrollment to be reported for a specific location (campus) eight-digit OPEID. If the student changes his or her primary location to one of the institution’s other campuses, the school will use the NSLDS enrollment reporting process to provide the “move to” location of the campus to which the student transferred. Enrollment should not be certified at more than one campus location (multiple eight-digit OPEIDs), even if that student has no primary location and is attending multiple locations of the institution. In such instances, the school must choose a primary location (campus) and report one enrollment status that includes the student’s enrollment at all of the school’s campuses.
NSLDS finds that many schools using an enrollment reporting servicer are not complying with this reporting requirement. Servicers (and some schools) are reporting the same enrollment status for a student at multiple locations of an institution rather than only at the current location, as required. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely, including reporting the proper location. Remember, enrollment information may be submitted on the NSLDS Professional Access Website in addition to using the enrollment roster file exchange process.
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 Department but who received Title IV aid at another school.
We believe 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 provided by the Department, because the servicer cannot identify which of the school’s enrolled students are Title IV aid recipients and which are not.
We thank you in advance for your cooperation in the implementation of these important enrollment reporting requirements. As noted, they are needed to ensure that together, we comply with all requirements of the Title IV student assistance programs.
Questions about the information in this letter can be submitted by phone to 1-800-999-8219 or by email to NSLDS@ed.gov.
Pamela Eliadis, Service Director, System Operations & Aid Delivery Management, Federal Student Aid