Finding 540998 (2024-002)

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Requirement
L
Questioned Costs
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Year
2024
Accepted
2025-03-31
Audit: 350606
Organization: New York Law School (NY)
Auditor: Cbiz CPAS PC

AI Summary

  • Core Issue: Enrollment changes for graduates were not reported to NSLDS within the required 60-day window.
  • Impacted Requirements: Accurate reporting of student status is essential for eligibility in financial aid programs and affects repayment timelines.
  • Recommended Follow-Up: Establish a policy to review and report student status changes within 60 days to ensure compliance with reporting requirements.

Finding Text

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”). Condition Of the ten students selected for enrollment reporting testing who graduated, all ten students tested were not reported to NSLDS within the maximum 60-day window. This was not a statistically valid sample. Cause This was overlooked by the School while switching processing systems. There were no 'late transmission' notifications as the 'Graduates Only' report did not repeat in the Spring/Summer 2024 transmission schedule. 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. Context The auditor selected 40 students to test enrollment and examined if the student had a change of address and whether there was an indication of graduating or withdrawing from the School either voluntarily or for academic purposes. We examined all applicable documentation to determine the date of any such change in status to conclude whether the School was in compliance with the reporting requirements for the student changes in status. Identification as a Repeat Finding This is not a repeat finding. Recommendation We recommend the School implement a policy where the student roster is reviewed within the required 60 days and that all changes in student status be identified and reported timely with the Department of Education. This will ensure that the requirement to notify the NSLDS is done timely and in compliance with the requirement.

Corrective Action Plan

We concur with this finding. Last year the school implemented a significant upgrade to its student information system, Banner. The transition to Banner SaaS was difficult and resulted in significant breakdowns in operations that are slowly recovering, and efforts are underway to implement modifications to ensure smooth operations. This, along with omissions on our part resulted in noncompliance with the reporting requirements. We will going forward, institute timely submissions to meet the requirements, while we continue to work with our vendors in fixing the software issues that produce the required reports.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Eligibility Reporting

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $30.82M
84.033 Federal Work-Study Program $864,124
84.425 Education Stabilization Fund $310,441