Many schools have made the National Student Clearinghouse aware that when they report retroactive enrollment status changes, their auditors cite them for failing to report the change in a timely manner. Although federal reporting regulations have referenced the “institution’s discovery” (determination) of a change, the NSLDS Enrollment Reporting Guide has not addressed the issue until now. For the past several months, the Clearinghouse has worked with the Federal Student Aid (FSA) to obtain clarification. We’re pleased to share with you that on November 16, FSA released their revised Enrollment Reporting Guide, which provides definitions and examples that we believe will finally resolve the longstanding issue regarding enrollment status change and date of determination. This latest guidance from FSA is consistent with the guidance that the Clearinghouse has been providing.
The Clearinghouse is reviewing other changes in the guide and will share them with you shortly. In the meantime, we wanted to get this critical information to you as soon as possible since we know audits are underway at many schools. In addition, we want to invite you to join us for a webinar the Clearinghouse is hosting on Wednesday, December 6, at 3 pm, ET, “Date of Determination Solved!“
BACKGROUND: The date of determination is the date your institution became 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.
The following is an excerpt from page 20 of the NSLDS Enrollment Reporting Guide (November 2017):
“Note that 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. For example, a school may not be aware a student has withdrawn until sometime after the student stops attending.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. 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.”
Register now for Date of Determination Solved!
Have you received questions from auditors related to date of determination or do you have questions yourself? If so, you don’t want to miss the webinar hosted by the Clearinghouse, “Date of Determination Solved!“ at 3 pm, ET, on Wednesday, December 6.
Watch for additional information regarding date of determination and other updates from the new NSLDS Enrollment Reporting Guide on our Compliance Central blog. You can also subscribe to our Compliance Central blog to get updates on date of determination and other compliance-related topics sent to you automatically.
If you have questions about date of determination or need assistance with an audit, please contact our Audit Resource Center at firstname.lastname@example.org or call us at 703.742.4200 (select options #7, #2).
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