NEW ENGLAND LAW / BOSTON

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.

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

2024-001

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.

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. Views of Responsible Officials and Planned Corrective Actions The School concurs with the finding. The School intends to report student status changes at year end. Names of Contact Person Responsible for Corrective Action: Andy Vidal, Chief Financial Officer, and Daniel Miller, Director on Financial Aid Anticipated Completion Date: December 31, 2024 Summary Schedule of Prior Audit Findings None

Finding ? Special Tests and Provisions: Enrollment Reporting ? Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2022 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 September 2021, and 34 CFR 685.309(b)) Condition Of the 40 students selected for enrollment reporting testing, two students within the sample were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Cause The School only reports status changes during the summer if a Title IV borrower is enrolled during the School's summer term. In both instances identified, both students withdrew after the completion of the Spring 2022 semester and such withdrawn statuses were not communicated to NSLDS until commencement of the Fall 2022 semester. 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. Identification as a Repeat Finding This is not a repeat finding. Recommendation Status changes relating to all Title IV borrowers should be reported year-round. Views of Responsible Officials and Corrective Actions See corrective action plan.

Finding ? Special Tests and Provisions: Enrollment Reporting ? Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2022 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 September 2021, and 34 CFR 685.309(b)) Condition Of the 40 students selected for enrollment reporting testing, two students within the sample were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The School concurs with the finding. The School intends to report student status changes at year end. Names of Contact Person Responsible for Corrective Action: Anne Marie Martorana, Chief Financial Officer Anticipated Completion Date: December 14, 2022

Finding 2021-001: Enrollment Reporting Federal agency: U.S. Department of Education Program: Student Financial Aid Cluster Assistance Listing Number: 84.268, 84.033, 84.038 Criteria: 34 CFR 685.309 notes in part, ?unless an institution expects to submit its next updated enrollment report to the Department within the next 60 days, an institution must notify NSLDS within 30 days after the date that the institution discovers that (1) a Direct loan was made to or on behalf of a student,?, and the student ceased or failed to be enrolled on at least half-time basis?, or (2) a student who is enrolled at the institution and who received a loan?has changed his or her permanent address?. Condition: Student enrollment reporting is done every month. There were two students that were readmitted to School during the year ended June 30, 2021, but were never reported again as enrolled and subsequently, not reported as withdrawn again for one student or graduated for the other student. In addition, there were two students who were not reported within required time frame for changes in enrollment status. Cause: The enrollment status changes were missed in the case of two readmitted students due to an internal error in the School?s reporting system. The other two students? enrollment changes were reported a few days late because the School was waiting for responses from other departments regarding the facts and circumstances pertaining to their withdrawals. By the time all parties replied, their enrollment status was reported beyond the required time frame for changes in enrollment status. Effect: The School was not in compliance with 34 CFR section 685.309 for timely enrollment reporting of students who received Federal loans. Questioned Costs: No questioned costs noted. Perspective Information: We tested twenty-five students for the enrollment reporting requirement and four were considered late. We view this late reporting as an isolated instance due to the unusual circumstances as well as the Covid-19 pandemic. Identification as a Repeat Finding: See finding 2020-002 included in the summary schedule of prior year findings. Recommendation: We recommend that the School adjust its procedures to provide enrollment status change within a time period shorter than the required 30 days. We also recommend that the School should have a procedure in place to verify that enrollment status change is provided on a timely basis. Views of Responsible Officials: In cases of re-admission, the School?s reporting system requires completion of a particular field. Because of a transition in Registrars, and infrequent re-admissions, the new official was not aware of the ?re-entry? field. The Registrar has now revised the office procedures to include information about the re-entry field for the future. With regard to the late reporting of withdrawals, the School acknowledges a repeat problem. However, by the time the issue was identified and corrected last year, the School was well into the next academic year. Unfortunately, the withdrawals cited in the current audit occurred prior to the implementation of the new process. The Registrar has reviewed withdrawals since that time, and the corrective action has indeed been effective. Most withdrawals are now reported within one month

In cases of re-admission, the School?s reporting system requires completion of a particular field. Because of a transition in Registrars, and infrequent re-admissions, the new official was not aware of the ?re-entry? field. The Registrar has now revised the office procedures to include information about the re-entry field for the future. With regard to the late reporting of withdrawals, the School acknowledges a repeat problem. However, by the time the issue was identified and corrected last year, the School was well into the next academic year. Unfortunately, the withdrawals cited in the current audit occurred prior to the implementation of the new process. The Registrar has reviewed withdrawals since that time, and the corrective action has indeed been effective. Most withdrawals are now reported within one month.

2020-002

Section 3 Federal Award Findings and Questioned Costs Finding 2020-001: Notifications to Students of Federal Loans CFDA: Student Financial Aid Cluster 84.268 84.033 84.038 Criteria: 34 CFR 668.165(a)(2) notes in part, ?The institution must notify the student or parent of ? (i) The anticipated date and amount of the disbursement; (ii) the student?s or parent?s right to cancel all or a portion of that loan?? 34 CFR 668.165 (a)(3) states ?The institution must provide the notice? in writing (i) no earlier than 30 days before, and no later than 30 days after,?? Condition: Notices were provided to students or parents. In all cases the notices were provided after the loan was credited to the student?s account. However, 1 of the notices tested was not provided within the required 30 days. Cause: The employee who normally sends the notifications inadvertently missed this disbursement amid the disruption and transition to remote work related to working from home during the Covid-19 pandemic. This caused the notification to be 12 days late. Effect: The school was not in compliance with 34 CFR section 668.165 (a) (3) for timely notice to students of Federal loans. NEW ENGLAND LAW BOSTON Schedule of Findings and Questioned Costs - Continued June 30, 2020 _____________________________________________________________________________ Questioned Costs: No questioned costs noted. Perspective Information: We tested sixty students for the loan notification requirement and one was considered twelve days late. We view this late notification as an isolated instance due to Covid-19 pandemic. Recommendation: We recommend that the School adjust its procedures to provide notification within a time period shorter than the required 30 days (such as 20 days). We also recommend that the School should have a procedure in place to verify notices are sent on a timely basis. Views of Responsible Officials: The School already improved its procedures for timely notifications by running the report of all disbursements weekly in order to capture all disbursements and notify the students well within the required 30-day period. Furthermore, the supervisor of the responsible employee monitors this closely to ensure the weekly report is done.

The School already improved its procedures for timely notifications by running the report of all disbursements weekly in order to capture all disbursements and notify the students well within the required 30-day period. Furthermore, the supervisor of the responsible employee monitors this closely to ensure the weekly report is done and timely notifications are made.

Finding 2020-002: Enrollment Reporting CFDA: Student Financial Aid Cluster 84.268 84.033 84.038 Criteria: 34 CFR 685.309 notes in part, ?unless an institution expects to submit its next updated enrollment report to the Department within the next 60 days, an institution must notify NSLDS within 30 days after the date that the institution discovers that (1) a Direct loan was made to or on behalf of a student,?, and the student ceased or failed to be enrolled on at least half-time basis?, or (2) a student who is enrolled at the institution and who received a loan?has changed his or her permanent address?. NEW ENGLAND LAW BOSTON Schedule of Findings and Questioned Costs - Continued June 30, 2020 _____________________________________________________________________________ Condition: Student enrollment reporting is done every month. In one case, a student was suspended for disciplinary reasons, pending a hearing with the School?s Discipline Committee. The student?s enrollment status changed from active to ?suspended? in the School?s registration system, but that status code was not recognized by the clearinghouse. When the school?s Financial Aid staff noticed that the Department of Education?s enrollment status did not reflect the change, they notified the Registrar who amended the status from ?suspended? to ?withdrawn,? and used the date of last class attendance as the effective date. The amended status was then reported to the Department of Education. Cause: The dismissal of the student was a complex situation, due to a disciplinary issue. The student was placed on suspension pending the outcome of a hearing. The School attempted contact with the student numerous times to schedule the hearing, but the student never responded. The situation was likely exacerbated by the coronavirus emergency and the many issues that the School and students were managing last spring. Eventually the School concluded that its only recourse wasto withdraw the student. By that time, it was reported beyond the required time frame for changes in enrollment status. Effect: The School was not in compliance with 34 CFR section 685.309 for timely enrollment reporting of students who received Federal loans. Questioned Costs: No questioned costs noted. Perspective Information: We tested twenty-five students for the enrollment reporting requirement and one was considered thirteen days late. We view this late reporting as an isolated instance due to the unusual circumstances as well as the Covid-19 pandemic. Recommendation: We recommend that the School adjust its procedures to provide enrollment status change within a time period shorter than the required 30 days. We also recommend that the School should have a procedure in place to verify that enrollment status change is provided on a timely basis. Views of Responsible Officials: The School acknowledges that the reporting exceeded the required time limit, but would like to emphasize the unusual nature of the situation, in which it took time to attempt a fair and proper resolution with the student. The School, moreover, is pleased that it was the careful review of the enrollment status by the Financial Aid staff that identified the issue so that it could be corrected. The School is considering whether having a shorter suspension period would provide enough time for due process and fairness for the student. Otherwise, the School will continue with the reporting and reviewing procedures that are working effectively as designed.

The School acknowledges that the reporting exceeded the required time limit, but would like to emphasize the unusual nature of the situation, in which it took time to attempt a fair and proper resolution with the student. The School, moreover, is pleased that it was the careful review of the enrollment status by the Financial Aid staff that identified the issue so that it could be corrected. The School is considering whether having a shorter suspension period would provide enough time for due process and fairness for the student. Otherwise, the School will continue with the reporting and reviewing procedures that are working effectively as designed.

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