FAC Explorer

Finding 1164706 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2025-12-12
Audit: 374416
Organization: New England Law / Boston (MA)
Auditor: CBIZ CPAS PC

AI Summary

  • Core Issue: Seven out of 16 students were reported late to NSLDS, missing the 60-day deadline for enrollment changes.
  • Impacted Requirements: Timely reporting of student status changes is crucial for eligibility in federal loan programs and affects grace periods and repayment schedules.
  • Recommended Follow-Up: The School must improve its reporting process to ensure all student changes are submitted within the required timeframe.

Finding Text

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2025 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 16 students selected for enrollment reporting testing, seven students within the sample were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Upon further inquiry, there were an additional 206 students included in the same batch reported to NSLDS that were not reported timely. Cause All these students graduated in May. The School uses a custom script to compile reporting for status changes. Such custom script was not run properly resulting in exclusion of certain students from the reporting submitted to NSLDS, which was not detected until the timing requirement had lapsed. 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 a repeat finding of an item reported previously as 2024-001. Recommendation The School should ensure that students are reported within the required 60-day window. Views of Responsible Officials See the School’s Corrective Action Plan.

Corrective Action Plan

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2025 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 16 students selected for enrollment reporting testing, seven students within the sample were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Upon further inquiry, there were an additional 206 students included in the same batch reported to NSLDS that were not reported timely. Views of Responsible Officials and Planned Corrective Actions NELB is revising the use of the customized report to more accurately reflect student records and will leverage the student information system, Jenzabar, to produce enrollment reports. The Office of the Registrar, the Office of the Controller, and Office of Financial Aid will review the file for NELB graduates in the month of May and ensure 100% compliance with graduating reporting after submission. As part of the NELB year-end closing procedures, there will be an additional review in the month of June every year to ensure that the file of NELB graduates provided to the National Student Loan Data System is consistent and accurate. This year-end closing procedure will be initiated by the NELB Chief Financial Officer and will coordinate with the Office of Financial Aid, Office of the Registrar and the Controller’s Office. Names of Contact Persons Responsible for Corrective Action: Office of Financial Aid (Jenny Aquiar), Office of the Registrar (Max Brodsky) and the Controller’s Office (Sean Bendall). The NELB Chief Financial Officer (James White) will work collaboratively to ensure that the corrective action plan is completed by each of these three NELB departments by June 30, 2026. Anticipated Completion Date: June 30, 2026

Categories

Student Financial Aid Special Tests & Provisions Eligibility Reporting

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $42.06M
84.033 FEDERAL WORK-STUDY PROGRAM $152,431
84.038 FEDERAL PERKINS LOANS $80,596