Did you know that under the 150% requirement, NSLDS¹ can use Graduated enrollment status to help determine a borrower’s maximum interest subsidy and remaining eligibility? It’s true!
It’s important you understand how to meet the Department of Education’s (ED) expectation for reporting Program Level graduation, used by NSLDS for Title IV recipients who are subject to the 150% Limit. Although NSLDS continues to allow only one Campus Level record to be reported via the SSCR process, up to six programs per student can now be reported at the program level. In order to fulfill the 150% requirement, Program Level graduation status must be reported to NSLDS.
To address potential Graduated enrollment status reporting challenges, your school may need to consider adjusting your reporting practices to the Clearinghouse. Under the 150% reporting requirement, you will encounter instances where you should report Graduated enrollment status to the Clearinghouse via Enrollment Reporting, in addition to reporting degree files to us.
The following are reporting adjustments you should consider implementing to your enrollment to the Clearinghouse:
- Report the corresponding CIP Codes for all degrees earned on your degree files, where applicable. This prevents reporting challenges that can occur when the Clearinghouse generates Graduated enrollment statuses from your degree files, during which we append the Graduated enrollment status at both the campus and program levels.
- Report Graduated enrollment status via Enrollment Reporting for the corresponding CIP Code, Credential Level, and Program Length for the degree earned, in the event the student continues enrollment at the school after the degree is awarded. You should include an additional program in your Enrollment Reporting file showing the student’s active Campus Level enrollment status AND that he or she has also completed a program. For example, you would report Campus Level Full Time status during the current term with program details as:
- Program 1: Full time for the current term
- Program 2: Graduated and include the status effective date and program completion details for the prior term
- Report Graduated enrollment status at both the campus- and Program Level, in the event the student is awarded a degree more than four months after his or her last date of attendance. You can submit the respective CIP Code, Credential Level, and Program Length via Enrollment Reporting’s batch exchange as a “Graduates Only” file. If you need to report the information for just one or a small number of students, you can use the “Update Student Record” option on our school secure site’s “Student Look-Up” tab.
¹The Department of Education’s 150% Limit reporting expectation for reporting the Graduated enrollment status is specific to program level, as noted in the following NSLDS Enrollment Reporting Guide excerpts:
2.3.1 Program-Level Reporting, p 5: “In the past, schools were only required to report a student’s enrollment at the Campus Level. This information was used for, among other things, the determination of when a student’s grace period would begin or when an in-school deferment would end. Now, because the 150% Limit is based on the borrower’s enrollment in a program, schools are required to report all Title IV aid recipients’ enrollment at the Program Level in addition to the Campus Level.”
2.3.2 Loss of Subsidy, p 6: “NSLDS will perform this analysis by calculating a borrower’s maximum and remaining eligibility period based on the Program Level information that schools report to NSLDS and the subsidized usage period data calculated by the Common Origination and Disbursement (COD) System.”
2.3.3 Protection of Subsidy, p 6: “If a student who is subject to the 150% Limit regulations completes a program before losing interest subsidy (exceeding the 150% Limit), the reporting of the graduation will protect the interest subsidy on any outstanding Direct Subsidized Loan(s) that have not lost interest subsidy because of the 150% Limit.”
4.4.3 Reporting Graduation and Anticipated Completion, p. 17: “Because schools will report enrollment status, including ‘W’ and ‘G’ at both the Campus Level and Program Level, it is important to understand when each status is appropriate at each level. At the Campus Level, a student should only be reported as withdrawn or graduated if the student has either withdrawn or graduated from the school entirely.”