Recently, the Clearinghouse has heard from a number of schools about their challenges surrounding audit findings and the date of determination of a student’s status change. On November 16, 2017, Federal Student Aid (FSA) released the November 2017 NSLDS Enrollment Reporting Guide. In anticipation of the guide’s release, the Clearinghouse had been collaborating with FSA over the past several months with the hope that additional clarification regarding reporting retroactive enrollment status changes would be included. The new NSLDS Enrollment Reporting Guide reflects the latest guidance from FSA, which is consistent with the guidance that the Clearinghouse has been providing.

Section 4.4.2 of the new NSLDS Enrollment Reporting Guide provides detailed information on several key dates, starting at page 20, including:

“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 For example, a school may not be aware a student has withdrawn until sometime after the student stops attending.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.

Definitions for multiple dates with which a school and its auditors should be familiar with are also included:

  • Effective Date: “… neither thedate 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.”
  • Certification Date: “…is the date the school certified the enrollment information. The Certification Date, which changes with each reporting submission, is the date as of which the school is asserting that the data being reported is accurate; it roughly corresponds to the date the school (or its servicer) processes its NSLDS Enrollment Roster.”
  • Date of Determination: The date your institution became aware of a student’s enrollment status change. “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.” This is because that status change may not have been determined within 60 days of the actual status change effective date.

Things get more complicated when examining the retroactive effective date of a student’s withdrawal, which is where the FSA Handbook comes in handy. Volume 5, Chapter 1 provides additional details on the date of determination that a student withdrew:

  1. If a student begins the official withdrawal process or provides official notification to the school of his or her intent to withdraw, the date of the institution’s determination that the student withdrew would be the date the student began the official withdrawal process or the date of the student’s notification, whichever is later.
  2. If a student did not begin the official withdrawal process or provide notification of his or her intent to withdraw, the date of the institution’s determination that the student withdrew would be the date that the school becomes aware that the student ceased attendance.
  3. Institutions that are required to take attendance are expected to have a procedure in place for routinely monitoring attendance records to determine in a timely manner when a student withdraws.
    • Except in unusual instances, the date of the institution’s determination that the student withdrew should be no later than 14 days (less if the school has a policy requiring determination in fewer than 14 days) after the student’s last date of attendance as determined by the institution from its attendance records.

Retroactive enrollment status changes are one of the most challenging compliance situations a school can encounter. Understanding the difference between effective dates, certification dates, and dates of determination is fundamental in ensuring status changes are captured in an accurate and timely manner.

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.

And just remember, when in doubt, contact our Audit Resource Center by emailing auditresource@studentclearinghouse.org, or by calling 703.742.4200, option 7, option 2.

We also invite you to “Join the Journey” as the Clearinghouse gets a head start on our 25th anniversary as your trusted partner in 2018 with an academic year filled with new events, services, and more.

 

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