Understanding NSLDS Enrollment Reporting

Autumn and Winter holiday breaks present unique challenges for institutions when students withdraw from school. Once a student’s withdrawal date is determined, a school needs to calculate the percentage of the payment period or period of enrollment the student completed to determine the percentage of Title IV Federal Student Aid funds the student earned. It’s common for schools to schedule holiday breaks lasting five or more days during Thanksgiving under most academic calendars and Winter Breaks in non-term and nonstandard term calendars. Institutionally scheduled breaks of five or more consecutive days are excluded from the Return to Title IV (R2T4) calculation as periods of nonattendance. Errors made when determining the length of a scheduled break lead to errors in the amount of aid students are eligible for.

Determining the length of a scheduled break

Step 1 – First determine the last day that class is held before the scheduled break. The scheduled break begins on the next day.

Step 2 – Next determine the last day of the scheduled break. The scheduled break ends on the day before classes resume.

Step 3 – Count the days.

REMEMBER – If your institution’s academic calendar schedules classes that end on a Friday, but don’t resume until the Monday after the break your break may be up to nine days long. Once you’ve properly determined the length of your scheduled break, you can subtract it from the numerator and denominator of the R2T4 calculation, ensuring that your calculations yield the proper amount of aid for withdrawn students.

Knowing what to watch out for can help you avoid compliance problems.
R2T4 errors are one of the top three audit and program review findings at institutions each year. R2T4 errors related to academic calendars and scheduled breaks are often systemic because the schedule itself affects all students.

Institutions with questions about Title IV and compliance with Federal Regulations related to Federal Student AId Programs are welcome to contact our office for assistance.


The United States Department of Education published final accreditation and state authorization regulations in October. The rules which will govern accrediting agencies and how they accredit institutions, as well as state authorization rules for distance education providers will have two different effective dates. Most of the published regulations will take effect on July 1, 2020, however some of the provisions were scheduled for early implementation beginning on November 1, 2019.

600.2 – Institutional Eligibility

600.9 – State Auth – Religious Institutions

668.43 – State Complaint Process

668.50 – Institutional Disclosure for Distance Programs

The remaining regulations pertaining to the Department’s recognition of accrediting agencies, will take effect on July 1, 2021.


  • Eliminate geography to determine an accreditor’s scope of recognition and clarify that institutional mission, rather than geographic location, should guide the quality assessment of an institution and its programs.
  • Affirm that accreditors must respect the mission of an institution of higher education that relies upon religious tenets, beliefs, or teachings.
  • Encourage institutions to evaluate the merit of transfer credits and prior learning assessment more fairly to reduce the need for students to take – and pay for – the same classes twice.
  • Allow accreditors to establish different methods of monitoring institutional success, based on the mission of the institution and the goals of its students.
  • Provide flexibility for accreditors to support innovation in higher education, recognizing that innovation has inherent risk, and monitoring the innovation carefully to intervene when student success is at risk.
  • Engage employers more directly in the evaluation of program quality and allow for institutional decision-making models that give employers a more prominent role in recommending program or curriculum updates.
  • Provide opportunities for accreditors to increase standards for accountability, while also providing an appropriate amount of time for institutions to make the changes needed to meet those standards.
  • Allow accreditors to take earlier action when institutions are struggling to require teach-out plans and permitting accreditors to permit teach-out agreements before a school announces its closure.
  • Reduce credential inflation, especially in programs that lead to a State license, to allow low income students the opportunity to pursue those occupations and to ensure that the cost of qualifying for work does not exceed a graduate’s likely earnings.
  • Reduce the time and complexity associated with approving an accreditor’s application for initial or renewal of recognition.


  • Make clear that an institution must identify the State in which a student is “located” and, therefore, the State in which the institution must have authorization.
  • More clearly define State authorization reciprocity agreements and reaffirm that they meet the requirements of the State authorization regulations for States that elect to participate in them.
  • Expand consumer protections for students who are enrolled in programs that lead to occupational licensure, including those enrolled in ground-based courses or programs.
  • Reduce the disclosures that institutions must provide students to reduce the cost and burden of distributing them and increasing the chances that students will consider them.
  • Eliminate requirements for States to establish new or separate consumer complaint processes for students enrolled in distance learning programs, while providing other options to ensure consumer protection.
  • Enable institutions to determine the States for which it will determine occupational licensing requirements, while requiring institutions to report that information accurately to students.
  • Enable students to continue their education, even if work or military service requires them to move to a new State, and to allow students to complete internships with potential future employers, without adding new State licensing fees to their institutions.

Institutions with questions pertaining to this or other matters of compliance with Accreditation, Federal Student Aid standards are welcome to contact our offices for additional assistance.


Higher Ed Executives Financial Aid Consultants


One of the functions of the U.S. Department of Education is to oversee the Federal Student Aid programs to ensure they are administered correctly and that institutions are meeting the FSA requirements for institutional eligibility, financial responsibility, and administrative capability.

School Participation Divisions review information about each title iv approved school from a variety of sources including accrediting agencies, state licensing boards and agencies, student complaints and of course, financial and compliance audits.

This information is evaluated by ED and FSA to assess potential risk to the FSA programs and if necessary, act to investigate a school. One of the ways ED does this is by conducting program reviews at schools that exhibit certain indications of problems or pose a potentially significant risk of failing to comply with the rules and regulations governing title iv participation.

Knowing what to watch out for can help you avoid compliance problems.

These findings represent data ED reported based on findings from Program Review audits and compliance examinations reports conducted by FSA and published in the last twelve months for fiscal year 2018.

  1. NSLDS Roster Reporting – Inaccurate/Untimely Reporting
  2. Crime Awareness Requirements Not Met
  3. Return of Title IV (R2T4) Calculation Errors
  4. Drug Abuse Prevention Requirements Not Met
  5. Student Credit Balance Deficiencies
  6. Consumer Information Requirements Not Met
  7. Verification Violations
  8. Entrance/Exit Counseling Deficiencies
  9. Inaccurate Recordkeeping
  10. Satisfactory Academic Progress Policy Not Adequately Developed/Monitored

Findings like these are preventable.

Higher Ed Executives provides colleges and universities with objective and confidential assessments that can help you uncover unknown compliance problems and improve title iv administrative and operational procedures and processes.

Our comprehensive assessments cover the full spectrum of FSA requirements for institutional eligibility, financial responsibility, and administrative capability.

Call us today for a free no obligation consultation and to find out how our assessments can work for you.

Call 203-836-4806


Higher Ed Executives Financial Aid Consultants Can help you gain compliance with title iv cash management regulations

FSA recently released an electronic announcement reminding institutions of the requirements for proper cash management compliance. Disbursing aid timely, resolving excess cash and reconciliation are necessary procedures and controls to ensure compliance with the federal regulations. Noncompliance in these areas often results in institutions being placed on the Heightened Cash Monitoring disbursement method and often with a requirement that the school post an irrevocable Letter of Credit equal to a percentage of title iv funds that have been drawn down in prior years. It’s not pretty. The simplest thing to do to avoid this is to have a handle on some cash management basics.

Three Steps to Cash Management Compliance:

1. Submit disbursement records timely.

All disbursement records should be sent to COD within 15 days after making the disbursement or becoming aware of the need to adjust a student’s previously reported disbursement.

2. Keep an eye out for excess cash and if necessary, return any undisbursed funds to the Department.

Excess Cash is any amount of title iv funds (excluding Perkins) that the school does not disburse to students or parents by the end of the third business day after the date the school received funds from the department. Excess cash can also occur when a school deposits previously disbursed funds into their federal bank account and lets it sit for more than three days before disbursing it to another student or returning it to the Department.

3. Reconcile regularly.

If you are reconciling all title iv disbursements on at least a monthly basis, you’ll be in a good position to ensure that you are meeting the disbursement reporting and excess cash deadlines. Regularly reconciling both internally between business office and financial aid office data as well as externally between financial aid office data and the Department’s COD and G5 systems will make final reconciliation and program year closeouts a snap. Plus, your auditors will be very happy to see the proof of your regular efforts.


On October 15, 2018, the Department published a notice in the Federal Register announcing that it will be establishing a negotiated rulemaking committee to prepare proposed regulations to address accreditation and innovation in higher ed. The Federal Register notice also requested nominations for individual negotiators who represent key stakeholder constituencies for the issues to be negotiated to serve on the committee and announced a schedule for committee meetings.
In addition, the notice requested nominations for individuals with pertinent expertise to participate in one of three topic-based subcommittees: Distance Learning and Educational Innovation; Faith-Based Entities; and, TEACH Grants.
The Accreditation and Innovation Committee will meet for three sessions on the following dates: Session 1: January 14–16, 2019 Session 2: February 19–22, 2019 Session 3: March 25–28, 2019. Meanwhile, each of the subcommittees will meet for three sessions on the following dates: Meeting 1: January 17–18, 2019 Meeting 2: February 12–13, 2019 Meeting 3: March 11–12, 2019.
Locations for the committee and subcommittee meetings will be announced in a subsequent Federal Register Notice. As provided in the Federal Register notice, the deadline for submitting nominations is Thursday, November 15, 2018.


The New England Association of Schools and Colleges, Commission on Institutions of Higher Education (NEASC-CIHE) is now the New England Commission of Higher Education (NECHE). NECHE has taken on the functions formerly performed by the CIHE. The move follows concerns raised by officials last year that the NEASC’s Commission on Higher Education wasn’t a “separate and independent” organization as required by ED. Now NECHE will function as an independent organization, fulfilling the federal requirements.


Two years after the Obama administration’s top education officials Emma Vadehra, the Chief of Staff to, and, Education Secretary John B. King Jr. at the U.S. Department of Education decided to terminate the Department’s recognition of ACICS, the Accrediting Council For Independent Colleges and Schools, the Trump administration is attempting to revive them.

Diane Auer Jones, an aide to Education Secretary Betsy DeVos who has been carrying out the duties of the Undersecretary of Education and acting as “Senior Department Official” (SDO), found the Accrediting Council of Independent Colleges and Schools (ACICS) to be compliant with only 19 out of the 21 requirements for federal recognition, but still hasn’t demonstrated full compliance. She recommends ACICS be given another twelve months to come into or demonstrate compliance with federal accreditor recognition standards.

In a statement Michelle Edwards, President and CEO of ACICS commented on the SDO’s recommendation:

“It has been a long and winding road since we filed our 2016 petition for continued recognition. We have long believed that ACICS met accreditation criteria as established by the Department and had the ability to remedy any deficiencies noted by the Department. We understand the agency’s need to be extremely thorough in its evaluation of our compliance. We appreciate the SDO’s very thoughtful and detailed review of the voluminous supporting materials that the agency provided in response to the Secretary’s April 2018 Order.

In the past two years, ACICS has implemented significant reforms designed to address concerns, strengthen the accreditation process and, ultimately, enhance our ability to hold schools accountable for meaningful student outcomes.  These efforts will continue in force as we improve and evolve our processes to ensure we not only remain in compliance with current federal requirements, but also foster an environment of rigorous quality and continuous improvement, both at ACICS and our accredited schools.” 

The final decision whether to follow the SDO’s recommendation seems to rest with Betsy DeVos who must now review the SDO’s decision, and decide whether to grant the agency recognition or not. What remains unclear is the Secretary’s authority to grant another extension of accreditation to an agency that has not yet demonstrated full compliance with the recognition criteria or what the timeframe for her to decide is.



In July, U.S. Education Secretary Betsy DeVos granted the Senior Department Official an extension to review and respond to a trove of documents related to ACICS’ petition for continued recognition as U.S. Department of Education accreditor. Secretary DeVos granted the extension after the SDO requested it. The SDO has been given until September 4, 2018 to file the response. You can read the memo from ED on ACICS website here.



In a statement on the ACICS website, the agency announced it has regained recognition today as a federally recognized accreditor. Retroactive status has been granted going back to December 2016 while Education Secretary Betsy DeVos reviews the agency’s 2016 petition for recognition.

A press release from ED explains the details and next steps.

Meanwhile, ACICS has this statement posted on their website.

Secretary of Education Orders Restoration of ACICS as a Federally Recognized Accrediting Agency as of December 2016.

Secretary of Education Orders Restoration of ACICS as a Federally Recognized Accrediting Agency as of December 2016 and Outlines Next Steps in the Compliance Review Process

On Tuesday, April 3, 2018, the Secretary of Education issued an Order notifying ACICS that the U.S. Department of Education has restored ACICS’s status as a federally recognized agency as of December 12, 2016.  The Order comes in response to the recent ruling from U.S. District Judge Reggie B. Walton that the U.S. Department of Education violated the Administrative Procedures Act by failing to consider various categories of relevant evidence” in its decision to withdraw ACICS’ recognition as a nationally-recognized accreditor.  The case was remanded back to the Secretary of Education.

Michelle Edwards, ACICS President, issued the following statement regarding the Order:

“We were gratified by the court’s ruling requiring the Department to review evidence submitted by ACICS documenting many meaningful reforms implemented by the organization.  And we appreciate the timely response by the Department, reinstating our recognition as of December 2016 and outlining the next steps in the compliance review process. The Department’s decision ensures that students currently attending ACICS schools are not negatively impacted pending the Department’s ongoing review process. In the last two years, ACICS has implemented significant reforms designed to address concerns, strengthen the accreditation process and, ultimately, enhance our ability to hold schools accountable for meaningful student outcomes.  These efforts are comprehensive and ongoing, and we look forward to working with the Department to ensure we are not only in full compliance with current requirements, but also in a position to become, over time, a leader among accreditors.”