2023-002 Enrollment Reporting – Significant Deficiency
United States Department of Education—
ALN 84.268 Federal Direct Student Loans Program
Criteria: Per CFR §658.309, unless it expects to submit its next updated enrollment report to the Secretary
within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers
that: (i) a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for
enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to
enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is
enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent
address.
Condition: For one out of 25 students sampled, the effective date reported in NSLDS was incorrect. For four
out of 25 students sampled, the status change was not reported in NSLDS in the next enrollment report or
within 30 days of the date of determination.
Cause: The Law School does not have a formalized policy to address enrollment reporting for summer terms.
Effect: Enrollment reporting was inaccurate. Federal loan servicers utilize this information to determine the
appropriate status for repayment terms and as such, had incorrect information. Enrollment reporting was not
submitted within the required time frame.
Questioned Costs: None.
Context: See condition above.
Recommendation: We recommend the Law School enhance their procedures and formalize a written
policy for all terms of enrollment reporting.
Corrective Actions Taken: Julie Brown, the Registrar will be given access to the NSLDS database to verify
the information submitted through the National Student Clearinghouse is reported completely and accurately,
particularly in relation to enrollment statuses that change during the non-required summer terms. This is part of an
ongoing process as this information is updated multiple times per year. The Registrars Office will also draft a
policy including timelines for uploading information to the National Student Clearinghouse and dates for
verification of information in NSLDS.
Responsible party: Julie Brown, Registrar. 718-780-7918 julie.brown@brooklaw.edu