Audit 300177

2023-001 Program Eligibility—Significant Deficiency United States Department of Education— ALN 84.268 Federal Direct Student Loans Program Criteria: Students who receive federal student aid are required to be enrolled in an eligible program. Eligible programs must be included in an institution’s accreditation and authorized by the State and the U.S. Department of Education. Condition: The Law School disbursed federal student aid to 63 students, totaling approximately $2,115,747, enrolled in an ineligible program, the Masters of Law (LL.M) program. Cause: The LL.M program was included in the Law School’s ECAR which is approved by the Department of Education. The Law School’s accreditation by the American Bar Association does not cover Programs outside of the Juris Doctorate program. As such, the LL.M program was not properly accredited and as such was not an eligible program. The ECAR was subsequently amended to remove this program. Effect: Federal student aid funds were inappropriately disbursed to students in ineligible programs which resulted in the Law School reimbursing and paying a fine to the U.S. Department of Education. Questioned Costs: $2,115,747 Context: The impact was to 63 students over a four-year period. Recommendation: We recommend the Law School review new or modified programs to ensure program eligibility requirements are met. View of Responsible Officials: The Law School agrees with the findings and disbursements have been discontinued. The Law School is working to obtain the appropriate accreditation.

2023-002 Enrollment Reporting – Significant Deficiency United States Department of Education— ALN 84.268 Federal Direct Student Loans Program Criteria: Per CFR §658.309, unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition: For one out of 25 students sampled, the effective date reported in NSLDS was incorrect. For four out of 25 students sampled, the status change was not reported in NSLDS in the next enrollment report or within 30 days of the date of determination. Cause: The Law School does not have a formalized policy to address enrollment reporting for summer terms. Effect: Enrollment reporting was inaccurate. Federal loan servicers utilize this information to determine the appropriate status for repayment terms and as such, had incorrect information. Enrollment reporting was not submitted within the required time frame. Questioned Costs: None. Context: See condition above. Recommendation: We recommend the Law School enhance their procedures and formalize a written policy for all terms of enrollment reporting. View of Responsible Officials: The Law School agrees with the finding and will ensure that enrollment reporting is accurate and timely.

2023-001 Program Eligibility—Significant Deficiency United States Department of Education— ALN 84.268 Federal Direct Student Loans Program Criteria: Students who receive federal student aid are required to be enrolled in an eligible program. Eligible programs must be included in an institution’s accreditation and authorized by the State and the U.S. Department of Education. Condition: The Law School disbursed federal student aid to 63 students, totaling approximately $2,115,747, enrolled in an ineligible program, the Masters of Law (LL.M) program. Cause: The LL.M program was included in the Law School’s ECAR which is approved by the Department of Education. The Law School’s accreditation by the American Bar Association does not cover Programs outside of the Juris Doctorate program. As such, the LL.M program was not properly accredited and as such was not an eligible program. The ECAR was subsequently amended to remove this program. Effect: Federal student aid funds were inappropriately disbursed to students in ineligible programs which resulted in the Law School reimbursing and paying a fine to the U.S. Department of Education. Questioned Costs: $2,115,747 Context: The impact was to 63 students over a four-year period. Recommendation: We recommend the Law School review new or modified programs to ensure program eligibility requirements are met. View of Responsible Officials: The Law School agrees with the findings and disbursements have been discontinued. The Law School is working to obtain the appropriate accreditation.

2023-002 Enrollment Reporting – Significant Deficiency United States Department of Education— ALN 84.268 Federal Direct Student Loans Program Criteria: Per CFR §658.309, unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition: For one out of 25 students sampled, the effective date reported in NSLDS was incorrect. For four out of 25 students sampled, the status change was not reported in NSLDS in the next enrollment report or within 30 days of the date of determination. Cause: The Law School does not have a formalized policy to address enrollment reporting for summer terms. Effect: Enrollment reporting was inaccurate. Federal loan servicers utilize this information to determine the appropriate status for repayment terms and as such, had incorrect information. Enrollment reporting was not submitted within the required time frame. Questioned Costs: None. Context: See condition above. Recommendation: We recommend the Law School enhance their procedures and formalize a written policy for all terms of enrollment reporting. View of Responsible Officials: The Law School agrees with the finding and will ensure that enrollment reporting is accurate and timely.