Audit 54378

FY End
2022-06-30
Total Expended
$30.47M
Findings
2
Programs
7
Organization: New England Law / Boston (MA)
Year: 2022 Accepted: 2023-01-13

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
61595 2022-001 Significant Deficiency - N
638037 2022-001 Significant Deficiency - N

Contacts

Name Title Type
LKD3R6DLJKY8 Anne Marie Martorana Auditee
6173681418 Michelle E. Spriggs Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The School has elected not to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. No amounts were passed through to subrecipients. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal award activity of New England Law / Boston (the School) under programs of the federal government for the year ended June 30, 2022. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Because the Schedule presents only a selected portion of the operations of the School, it is not intended to and does not present the financial position, changes in net assets, or cash flows of the School. The School includes loans granted under the Federal Direct Student Loan Program as expenditures of federal awards.
Title: Federal Student Loan Program Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The School has elected not to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. No amounts were passed through to subrecipients. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The federal student loan program listed subsequently is administered directly by the School and balances and transactions relating to this program are included in the Schools financial statements. Loans outstanding at the beginning of the year are included in the federal expenditures presented in the Schedule. The program has been terminated by DOE and therefore no new loans were made during the year ended June 30, 2022. The balance of loans outstanding at June 30, 2022 consists of: FEDERAL PERKINS LOANS (Assistance Listing Number: 84.038) - Balances outstanding at the end of the audit period were $339,474.
Title: Higher Education Emergency Relief Fund Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The School has elected not to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. No amounts were passed through to subrecipients. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The School was awarded funds for student and institutional purposes under the Higher Education Emergency Relief Fund program (HEERF). These funds are administered directly by the School. Amounts expended as of June 30, 2022 for both the student and institutional portion of the program are included in Federal expenditures presented in the Schedule. HEERF activity for the year ended June 30, 2022 and prior is as follows: SEE FINANCIAL STATEMENTS FOR TABLE.

Finding Details

Finding ? Special Tests and Provisions: Enrollment Reporting ? Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2022 Award Year; U.S. Department of Education Criteria or Specific Requirement Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves-of absence. It is the institution?s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (?NSLDS?). (NSLDS Enrollment Reporting Guide September 2021, and 34 CFR 685.309(b)) Condition Of the 40 students selected for enrollment reporting testing, two students within the sample were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Cause The School only reports status changes during the summer if a Title IV borrower is enrolled during the School's summer term. In both instances identified, both students withdrew after the completion of the Spring 2022 semester and such withdrawn statuses were not communicated to NSLDS until commencement of the Fall 2022 semester. Effect A student?s enrollment status determines eligibility for in-school status, deferment, grace periods, and repayments, as well as the government?s payment of interest subsidies. The notification of student status changes to NSLDS will cause a student to enter into a grace period and determine a repayment date and, therefore, accurate and timely notification of student status to NSLDS is important. Questioned Costs None noted. Identification as a Repeat Finding This is not a repeat finding. Recommendation Status changes relating to all Title IV borrowers should be reported year-round. Views of Responsible Officials and Corrective Actions See corrective action plan.
Finding ? Special Tests and Provisions: Enrollment Reporting ? Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2022 Award Year; U.S. Department of Education Criteria or Specific Requirement Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves-of absence. It is the institution?s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (?NSLDS?). (NSLDS Enrollment Reporting Guide September 2021, and 34 CFR 685.309(b)) Condition Of the 40 students selected for enrollment reporting testing, two students within the sample were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Cause The School only reports status changes during the summer if a Title IV borrower is enrolled during the School's summer term. In both instances identified, both students withdrew after the completion of the Spring 2022 semester and such withdrawn statuses were not communicated to NSLDS until commencement of the Fall 2022 semester. Effect A student?s enrollment status determines eligibility for in-school status, deferment, grace periods, and repayments, as well as the government?s payment of interest subsidies. The notification of student status changes to NSLDS will cause a student to enter into a grace period and determine a repayment date and, therefore, accurate and timely notification of student status to NSLDS is important. Questioned Costs None noted. Identification as a Repeat Finding This is not a repeat finding. Recommendation Status changes relating to all Title IV borrowers should be reported year-round. Views of Responsible Officials and Corrective Actions See corrective action plan.