Finding 388460 (2023-001)

Significant Deficiency
Requirement
N
Questioned Costs
$1
Year
2023
Accepted
2024-03-28
Audit: 300177
Organization: Brooklyn Law School (NY)
Auditor: Rsm US LLP

AI Summary

  • Core Issue: The Law School disbursed federal aid to 63 students in an ineligible Masters of Law (LL.M) program, totaling about $2.1 million.
  • Impacted Requirements: Federal aid can only be given to students in programs that are accredited and authorized by the State and the U.S. Department of Education.
  • Recommended Follow-Up: The Law School should thoroughly review all new or modified programs to ensure they meet eligibility requirements before disbursing federal aid.

Finding Text

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.

Corrective Action Plan

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 US 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 LL.M. program. Context: The impact was to 63 students over a four-year period. Cause: The Master of Laws (LL.M) Program was included in the Law School’s ECAR which was 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 therefore not an eligible program. The ECAR was subsequently amended to remove this program. Effect: Federal student aid funds were inappropriately disbursed to students in an ineligible program which resulted in the Law School entering into a settlement agreement with the U.S. Department of Education pursuant to which the Law School reimbursed and paid a fine to the US Department of Education. Questioned Costs: $2,115,747 Recommendation: We recommend the Law School review new or modified programs to ensure program eligibility requirements are met. Corrective Actions Taken: Upon notification from Department of Education regarding this concern, the Law School discontinued disbursement of Title IV funds to students of the LL.M. program and will not disburse those funds to students of that program until it receives additional accreditation. The Law School is currently working on obtaining accreditation from the Middle States Commission on Higher Education for its existing LL.M. and future Master’s degree programs. Responsible Person: David D. Meyer, President and Dean, (718) 780-7901, david.meyer@brooklaw.edu

Categories

Questioned Costs Eligibility Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 388461 2023-002
    Significant Deficiency
  • 964902 2023-001
    Significant Deficiency
  • 964903 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $35.61M
84.033 Federal Work-Study Program $456,885
84.425 Education Stabilization Fund $336,942