Finding 1090372 (2024-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2024-12-12
Audit: 332140
Organization: New England Law / Boston (MA)
Auditor: Cbiz CPAS PC

AI Summary

  • Core Issue: One student was reported late to NSLDS, and seven others were also not reported on time due to graduation timing confusion.
  • Impacted Requirements: Enrollment changes must be reported within 30 days or, if a roster is submitted, within 60 days to maintain compliance with federal regulations.
  • Recommended Follow-Up: Implement a process to ensure timely reporting for students graduating outside the traditional Spring schedule.

Finding Text

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2024 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 November 2022 and 34 CFR 682.610) Condition Found Of the 15 students selected for enrollment reporting testing, one student within the sample was reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Upon further inquiry, there were an additional 7 students included in the same batch reported to NSLDS that were not reported timely. Cause All these students graduated in December. The School’s traditional graduation timing is in the Spring. Due to turnover in the Office of the Registrar, the students who graduated in December were included in the reporting to NSLDS with the other students who graduated in the Spring and, therefore, were reported after the required timing. 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 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 The School should ensure that students who graduate outside the traditional timing in the Spring are reported within the required 60-day window. Views of Responsible Officials See the School’s Corrective Action Plan.

Categories

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking Eligibility Reporting

Other Findings in this Audit

  • 513930 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $35.47M
84.038 Federal Perkins Loans $130,596
84.033 Federal Work-Study Program $127,419