Criteria
When Direct Loans or TEACH funds are being credited to a student’s account, the institution must notify
the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or
parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds
returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure
and time by which the student or parent must notify the institution that he or she wishes to cancel the loan,
TEACH Grant, or TEACH Grant disbursement (a minimum of 14 or 30 days depending on the confirmation
process). Institutions that do not implement an affirmative confirmation process (as described in 34 CFR
668.165 (a)(6)(i)) must notify a student no earlier than 30 days before, but no later than seven days after,
crediting the student’s account and must give the student 30 days (instead of 14) to cancel all or part of the
loan.
Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must
establish and maintain effective internal control over the Federal award that provides reasonable assurance
that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations,
and the terms and conditions of the Federal award. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General
of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Condition
During our testing of student loan disbursement notifications, KPMG identified that four of forty students
selected for testwork received notifications beyond seven days after the students’ accounts had been
credited.
The exceptions described above did not result in changes to the amounts awarded or disbursed to students
by the College for the current fiscal year.
Cause
The condition resulted from the College’s internal control processes not operating consistently to ensure
that all disbursement notifications were made in a timely manner. Specifically, the College has
implemented an automated process to send disbursement notifications on a routine basis using student or parent contact information that is maintained in the system. However, in instances where these automated
disbursement notifications came back as undeliverable due to inaccuracies in contact information
(exceptions), the College did not implement effective internal control processes to ensure that these
exceptions were resolved within the requisite timeframe.
Possible Asserted Effect
Failure to notify students of the timing of disbursements, as well as timely notifying students of their rights
related to those disbursements and the procedures and timelines for cancellation, could have resulted in
students not being aware that a disbursement was made or receiving loans that they did not intend to keep.
Questioned Costs
None.
Statistical Sampling
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding was a Repeat Finding
This is not a repeat finding.
Recommendation
We recommend that the College review and enhance its processes related to disbursement notifications to
ensure that they are complying with federal requirements.
Views of Responsible Officials
Management concurs with the recommendations provided. To remediate this issue, there are new
personnel assigned to complete the process and ensure there are no gaps. The Director of Financial Aid
Operations will ensure that the process is run timely.
Berklee has changed the notification date to align with the disbursement date. This will ensure that notices
are sent on day zero. In addition, errors are reviewed and addressed within two business days.
Estimated Date of Completion: March 31, 2025
Criteria
Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan
programs via the NSLDS. The administration of the Title IV programs depends heavily on the accuracy and
timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify
student enrollment statuses, program information, and effective dates that appear on the Enrollment
Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access
(NSDLSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program
Level,” both of which need to be reported accurately and have separate record types.
Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must
establish and maintain effective internal control over the Federal award that provides reasonable assurance
that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations,
and the terms and conditions of the Federal award. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General
of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Condition
In testing the Program-Level enrollment reporting data elements, key items to test, if applicable, are:
OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement,
Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment
Effective Date.
Of the 40 students with enrollment changes that we selected for testwork, KPMG identified 2 students
whose program level enrollment data elements were not accurately transmitted to NSLDS. Specifically,
KPMG identified that 2 students’ Published Program Lengths, as reported to NSLDS, did not agree to the
College’s records.
The exceptions described above did not result in changes to the amounts awarded or disbursed to students
by the College for the current fiscal year.
Cause
The condition resulted from the College’s internal control processes not operating consistently to ensure
that all changes in enrollment information at both a campus level and program level were accurately
reported to NSLDS. Specifically, the College’s control of reviewing the key enrollment reporting data
elements for accuracy was not operating at a level of precision that would cover all key data elements.
Possible Asserted Effect
Inaccurate submission of student enrollment status information and related program information affects the
determinations that lenders and servicers of students’ loans make related to in-school status, deferments,
grace periods, and repayment schedules, as well as the federal government’s payment of interest
subsidies. Questioned Costs
None.
Statistical Sampling
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding was a Repeat Finding
This is not a repeat finding.
Recommendation
We recommend the College review and enhance its process related to enrollment reporting to ensure that
all status change key data elements that are reported to NSLDS agree to the College’s records.
Views of Responsible Officials
Management concurs with the recommendations provided. The Registrar’s Office will implement a
reconciliation of the Student Enrollment Information system and data provided to NSC (the National
Student Clearinghouse). The reconciliations will be reviewed by the Associate Registrar and confirmed by
the Registrar before submission to ensure that it’s performed timely and accurately. Notifications or any
discrepancies will be sent to NSC immediately informing them of any necessary corrections.
Estimated Date of Completion: March 31, 2025
Criteria
Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan
programs via the NSLDS. The administration of the Title IV programs depends heavily on the accuracy and
timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify
student enrollment statuses, program information, and effective dates that appear on the Enrollment
Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access
(NSDLSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program
Level,” both of which need to be reported accurately and have separate record types.
Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must
establish and maintain effective internal control over the Federal award that provides reasonable assurance
that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations,
and the terms and conditions of the Federal award. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General
of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Condition
In testing the Program-Level enrollment reporting data elements, key items to test, if applicable, are:
OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement,
Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment
Effective Date.
Of the 40 students with enrollment changes that we selected for testwork, KPMG identified 2 students
whose program level enrollment data elements were not accurately transmitted to NSLDS. Specifically,
KPMG identified that 2 students’ Published Program Lengths, as reported to NSLDS, did not agree to the
College’s records.
The exceptions described above did not result in changes to the amounts awarded or disbursed to students
by the College for the current fiscal year.
Cause
The condition resulted from the College’s internal control processes not operating consistently to ensure
that all changes in enrollment information at both a campus level and program level were accurately
reported to NSLDS. Specifically, the College’s control of reviewing the key enrollment reporting data
elements for accuracy was not operating at a level of precision that would cover all key data elements.
Possible Asserted Effect
Inaccurate submission of student enrollment status information and related program information affects the
determinations that lenders and servicers of students’ loans make related to in-school status, deferments,
grace periods, and repayment schedules, as well as the federal government’s payment of interest
subsidies. Questioned Costs
None.
Statistical Sampling
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding was a Repeat Finding
This is not a repeat finding.
Recommendation
We recommend the College review and enhance its process related to enrollment reporting to ensure that
all status change key data elements that are reported to NSLDS agree to the College’s records.
Views of Responsible Officials
Management concurs with the recommendations provided. The Registrar’s Office will implement a
reconciliation of the Student Enrollment Information system and data provided to NSC (the National
Student Clearinghouse). The reconciliations will be reviewed by the Associate Registrar and confirmed by
the Registrar before submission to ensure that it’s performed timely and accurately. Notifications or any
discrepancies will be sent to NSC immediately informing them of any necessary corrections.
Estimated Date of Completion: March 31, 2025
Criteria
When Direct Loans or TEACH funds are being credited to a student’s account, the institution must notify
the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or
parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds
returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure
and time by which the student or parent must notify the institution that he or she wishes to cancel the loan,
TEACH Grant, or TEACH Grant disbursement (a minimum of 14 or 30 days depending on the confirmation
process). Institutions that do not implement an affirmative confirmation process (as described in 34 CFR
668.165 (a)(6)(i)) must notify a student no earlier than 30 days before, but no later than seven days after,
crediting the student’s account and must give the student 30 days (instead of 14) to cancel all or part of the
loan.
Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must
establish and maintain effective internal control over the Federal award that provides reasonable assurance
that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations,
and the terms and conditions of the Federal award. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General
of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Condition
During our testing of student loan disbursement notifications, KPMG identified that four of forty students
selected for testwork received notifications beyond seven days after the students’ accounts had been
credited.
The exceptions described above did not result in changes to the amounts awarded or disbursed to students
by the College for the current fiscal year.
Cause
The condition resulted from the College’s internal control processes not operating consistently to ensure
that all disbursement notifications were made in a timely manner. Specifically, the College has
implemented an automated process to send disbursement notifications on a routine basis using student or parent contact information that is maintained in the system. However, in instances where these automated
disbursement notifications came back as undeliverable due to inaccuracies in contact information
(exceptions), the College did not implement effective internal control processes to ensure that these
exceptions were resolved within the requisite timeframe.
Possible Asserted Effect
Failure to notify students of the timing of disbursements, as well as timely notifying students of their rights
related to those disbursements and the procedures and timelines for cancellation, could have resulted in
students not being aware that a disbursement was made or receiving loans that they did not intend to keep.
Questioned Costs
None.
Statistical Sampling
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding was a Repeat Finding
This is not a repeat finding.
Recommendation
We recommend that the College review and enhance its processes related to disbursement notifications to
ensure that they are complying with federal requirements.
Views of Responsible Officials
Management concurs with the recommendations provided. To remediate this issue, there are new
personnel assigned to complete the process and ensure there are no gaps. The Director of Financial Aid
Operations will ensure that the process is run timely.
Berklee has changed the notification date to align with the disbursement date. This will ensure that notices
are sent on day zero. In addition, errors are reviewed and addressed within two business days.
Estimated Date of Completion: March 31, 2025
Criteria
Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan
programs via the NSLDS. The administration of the Title IV programs depends heavily on the accuracy and
timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify
student enrollment statuses, program information, and effective dates that appear on the Enrollment
Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access
(NSDLSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program
Level,” both of which need to be reported accurately and have separate record types.
Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must
establish and maintain effective internal control over the Federal award that provides reasonable assurance
that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations,
and the terms and conditions of the Federal award. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General
of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Condition
In testing the Program-Level enrollment reporting data elements, key items to test, if applicable, are:
OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement,
Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment
Effective Date.
Of the 40 students with enrollment changes that we selected for testwork, KPMG identified 2 students
whose program level enrollment data elements were not accurately transmitted to NSLDS. Specifically,
KPMG identified that 2 students’ Published Program Lengths, as reported to NSLDS, did not agree to the
College’s records.
The exceptions described above did not result in changes to the amounts awarded or disbursed to students
by the College for the current fiscal year.
Cause
The condition resulted from the College’s internal control processes not operating consistently to ensure
that all changes in enrollment information at both a campus level and program level were accurately
reported to NSLDS. Specifically, the College’s control of reviewing the key enrollment reporting data
elements for accuracy was not operating at a level of precision that would cover all key data elements.
Possible Asserted Effect
Inaccurate submission of student enrollment status information and related program information affects the
determinations that lenders and servicers of students’ loans make related to in-school status, deferments,
grace periods, and repayment schedules, as well as the federal government’s payment of interest
subsidies. Questioned Costs
None.
Statistical Sampling
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding was a Repeat Finding
This is not a repeat finding.
Recommendation
We recommend the College review and enhance its process related to enrollment reporting to ensure that
all status change key data elements that are reported to NSLDS agree to the College’s records.
Views of Responsible Officials
Management concurs with the recommendations provided. The Registrar’s Office will implement a
reconciliation of the Student Enrollment Information system and data provided to NSC (the National
Student Clearinghouse). The reconciliations will be reviewed by the Associate Registrar and confirmed by
the Registrar before submission to ensure that it’s performed timely and accurately. Notifications or any
discrepancies will be sent to NSC immediately informing them of any necessary corrections.
Estimated Date of Completion: March 31, 2025
Criteria
Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan
programs via the NSLDS. The administration of the Title IV programs depends heavily on the accuracy and
timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify
student enrollment statuses, program information, and effective dates that appear on the Enrollment
Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access
(NSDLSFAP) website. There are two categories of enrollment information, “Campus Level” and “Program
Level,” both of which need to be reported accurately and have separate record types.
Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must
establish and maintain effective internal control over the Federal award that provides reasonable assurance
that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations,
and the terms and conditions of the Federal award. These internal controls should be in compliance with
guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General
of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
Condition
In testing the Program-Level enrollment reporting data elements, key items to test, if applicable, are:
OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement,
Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment
Effective Date.
Of the 40 students with enrollment changes that we selected for testwork, KPMG identified 2 students
whose program level enrollment data elements were not accurately transmitted to NSLDS. Specifically,
KPMG identified that 2 students’ Published Program Lengths, as reported to NSLDS, did not agree to the
College’s records.
The exceptions described above did not result in changes to the amounts awarded or disbursed to students
by the College for the current fiscal year.
Cause
The condition resulted from the College’s internal control processes not operating consistently to ensure
that all changes in enrollment information at both a campus level and program level were accurately
reported to NSLDS. Specifically, the College’s control of reviewing the key enrollment reporting data
elements for accuracy was not operating at a level of precision that would cover all key data elements.
Possible Asserted Effect
Inaccurate submission of student enrollment status information and related program information affects the
determinations that lenders and servicers of students’ loans make related to in-school status, deferments,
grace periods, and repayment schedules, as well as the federal government’s payment of interest
subsidies. Questioned Costs
None.
Statistical Sampling
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding was a Repeat Finding
This is not a repeat finding.
Recommendation
We recommend the College review and enhance its process related to enrollment reporting to ensure that
all status change key data elements that are reported to NSLDS agree to the College’s records.
Views of Responsible Officials
Management concurs with the recommendations provided. The Registrar’s Office will implement a
reconciliation of the Student Enrollment Information system and data provided to NSC (the National
Student Clearinghouse). The reconciliations will be reviewed by the Associate Registrar and confirmed by
the Registrar before submission to ensure that it’s performed timely and accurately. Notifications or any
discrepancies will be sent to NSC immediately informing them of any necessary corrections.
Estimated Date of Completion: March 31, 2025