Brooklyn Law School

EIN: 237227990

UEI: XHSCXMK1VCK8

Data as of August 25, 2026

Brooklyn Law School10 audit years9 findings1 repeat
10
Audit Years
9
Total Findings
1
Repeat Findings

FY 2025-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 5, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 5, 2026 (11 days from today).

What is a management decision? →
2025-001
Special Tests & Provisions

The Law School did not notify the National Student Loan Data System (NSLDS) in a timely manner for 23 students with status changes in our sample of 25 students. For 2 out of 25 students selected in the sample, the effective date that was reported to the NSLDS did not match the date that the student changed status. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The Law School's controls surrounding the reporting of students' statuses and status effective dates to the NSLDS did not appropriately ensure the information was submitted accurately or timely. Effect: The accuracy of the Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Recommendation: We recommend that the Law School review its procedures for student status changes and NSLDS notifications to ensure there are follow-up and review procedures being performed for all students with status changes at the Law School to ensure accurate and timely reporting. Management Response: Management agrees with the finding, The Director of Financial Aid and the Registrar will implement procedures and controls in fiscal 2026 to ensure accurate and timely updating of the enrollment reports to NSLDS.

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Finding 2025-001: Significant Deficiency - NSLDS Enrollment Reporting Assistance listing No.: ALN 84.268 Federal program title: Federal Direct Student Loan Program Award No.: N/A Award Year: 2025 Name of pass-through entity, when applicable: N/A Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary of the Department of Education (Secretary), institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless the institution expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution 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 institution, and the student has ceased to be enrolled on at least a halftime 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 institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: The Law School did not notify the National Student Loan Data System (NSLDS) in a timely manner for 23 students with status changes in our sample of 25 students. For 2 out of 25 students selected in the sample, the effective date that was reported to the NSLDS did not match the date that the student changed status. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The Law School's controls surrounding the reporting of students' statuses and status effective dates to the NSLDS did not appropriately ensure the information was submitted accurately or timely. Effect: The accuracy of the Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Recommendation: We recommend that the Law School review its procedures for student status changes and NSLDS notifications to ensure there are follow-up and review procedures being performed for all students with status changes at the Law School to ensure accurate and timely reporting. Management Response: Management agrees with the finding, The Director of Financial Aid and the Registrar will implement procedures and controls in fiscal 2026 to ensure accurate and timely updating of the enrollment reports to NSLDS.

Corrective Action Plan

Brooklyn Law School Single Audit Corrective Action Plan For the Year Ending June 30, 2025 Section III - Federal Awards Findings and Questioned Costs Finding 2025-001: Significant Deficiency - NSLDS Enrollment Reporting Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary of the Department of Education (Secretary), institutions must update all information included in the report and return the report to the Secretary: (I) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless the institution expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution 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 institution, and the student has ceased to be enrolled on at least a halftime 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 institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: The Law School did not notify the National Student Loan Data System (NSLDS) in a timely manner for 23 students with status changes in our sample of 25 students. For 2 out of 25 students selected in the sample, the effective date that was reported to the NSLDS did not match the date that the student changed status. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The Law School's controls surrounding the reporting of students’ statuses and status effective dates to the NSLDS did not appropriately ensure the information was submitted accurately or timely. Effect: The accuracy of the Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Recommendation: We recommend that the Law School review its procedures for student status changes and NSLDS notifications to ensure there are follow-up and review procedures being performed for all students with status changes at the Law School to ensure accurate and timely reporting. Management Response: Management agrees with the finding, The Director of Financial Aid and the Registrar will implement procedures and controls in fiscal 2026 to ensure accurate and timely updating of the enrollment reports to NSLDS. Anticipated Completion Date: June 30, 2026 Responsible Person: John K. Zhang, Vice President for Finance and Board Treasurer (718)-780-7503 - john.zhang@brooklaw.edu

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FY 2023-06-30

FAC accepted this audit on March 28, 2024 — management decision was due September 28, 2024.

2023-001
Special Tests & Provisions
QUESTIONED COSTS

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.

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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

About Special Tests and Provisions →
2023-002
Special Tests & Provisions

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. View of Responsible Officials: The Law School agrees with the finding and will ensure that enrollment reporting is accurate and timely.

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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. View of Responsible Officials: The Law School agrees with the finding and will ensure that enrollment reporting is accurate and timely.

Corrective Action Plan

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

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FY 2022-06-30

FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.

2022-002
Procurement & Suspension/Debarment
REPEAT

The Law School could not provide sufficient documented rationales for sole source awards for 2 out of 2 vendors selected for testing. Cause: A Procurement Policy incorporating federal procurement standards identified in 2 CRF Part 200 was not adopted by the Law School until June 15, 2022. As such, the Law School did not have adequate policy during fiscal 2022. Effect: Sole source awards were not properly documented. Questioned Costs: None Context: This is a repeat audit finding from the prior year audit and was reported as finding 2021-002. Recommendation: The Law School should ensure that they have sufficient documentation to support rationale for sole source awards and are in compliance with the federal procurement standards. View of Responsible Officials: The Law School agrees with the finding and have adopted an appropriate procurement policy as of June 15, 2022. Awards, including sole source awards will be adequately documented.

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Section III. Findings and Questioned Costs for Federal Awards 2022-002 Procurement United States Department of Education? ALN 84.425F Education Stabilization Fund - Institutional Portion Criteria: Non-federal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Law School could not provide sufficient documented rationales for sole source awards for 2 out of 2 vendors selected for testing. Cause: A Procurement Policy incorporating federal procurement standards identified in 2 CRF Part 200 was not adopted by the Law School until June 15, 2022. As such, the Law School did not have adequate policy during fiscal 2022. Effect: Sole source awards were not properly documented. Questioned Costs: None Context: This is a repeat audit finding from the prior year audit and was reported as finding 2021-002. Recommendation: The Law School should ensure that they have sufficient documentation to support rationale for sole source awards and are in compliance with the federal procurement standards. View of Responsible Officials: The Law School agrees with the finding and have adopted an appropriate procurement policy as of June 15, 2022. Awards, including sole source awards will be adequately documented.

Corrective Action Plan

2022-002 Procurement United States Department of Education? ALN 84.425F Education Stabilization Fund - Institutional Portion Criteria: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Law School could not provide sufficient documented rationales for sole source awards for 2 out of 2 vendors selected for testing. Cause: A Procurement Policy incorporating federal procurement standards identified in 2 CRF Part 200 was not adopted by the Law School until June 15, 2022. As such, the Law School did not have adequate policy during fiscal 2022. Effect: Sole source awards were not properly documented. Questioned Costs: None Context: See condition above. Recommendation: The Law School should ensure that they have sufficient documentation to support rationale for sole source awards and are in compliance with the federal procurement standards. Corrective Action: Effective June 15, 2022, the procurement policy will be adhered to and purchases will be adequately documented. Responsible Persons: Stephanie Vullo, Chief Compliance Officer, 718-780-0605, stephanie.vullo@brooklaw.edu; Herberth Melendez, Associate General Counsel, 718-780-7952, herberth.melendez@brooklaw.edu

Prior Finding References

2021-002

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FY 2021-06-30

FAC accepted this audit on August 25, 2022 — management decision was due February 25, 2023.

2021-001
Special Tests & Provisions

The Law School did not report a change in enrollment within the required 60 days for 23 out of 24 students selected for testing. Cause: The Law School provided the enrollment reporting files to the National Student Clearinghouse. The National Student Clearinghouse is a service provider engaged to upload all enrollment reporting through the NSLDS. The Law School received an email confirmation from the National Student Clearinghouse confirming the files for the selected students had been uploaded. However, upon review, the Law School identified that the files were never uploaded. Effect: The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Enrollment information is used to determine several factors related to payment and interest on direct loans. Questioned Costs: None Context: See condition above. Recommendation: The Law School should implement controls to ensure timely submission occurs within the required 60 days. View of Responsible Officials: The law school will continue to upload graduate files within the required 60 days and will work with our representatives from National Student Clearinghouse to verify the information we submit has been properly uploaded to the NSLDS. We will also verify with the NSLDS that this information has been received. The people responsible for this will be Julie Brown (and other members of the Registrar?s Office that upload information to the National Student Clearinghouse) and Florence Attino. This will be an ongoing process as we upload this information multiple times a year.

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Criteria: Enrollment reporting: Institutions are required to report enrollment information under the Direct Loan program via the National Student Loan Data System (NSLDS). Institutions are responsible for timely reporting, whether they report directly or via a third party servicer. Institutions must report all enrollment changes within 60 days of the change in an enrollment status. Condition: The Law School did not report a change in enrollment within the required 60 days for 23 out of 24 students selected for testing. Cause: The Law School provided the enrollment reporting files to the National Student Clearinghouse. The National Student Clearinghouse is a service provider engaged to upload all enrollment reporting through the NSLDS. The Law School received an email confirmation from the National Student Clearinghouse confirming the files for the selected students had been uploaded. However, upon review, the Law School identified that the files were never uploaded. Effect: The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Enrollment information is used to determine several factors related to payment and interest on direct loans. Questioned Costs: None Context: See condition above. Recommendation: The Law School should implement controls to ensure timely submission occurs within the required 60 days. View of Responsible Officials: The law school will continue to upload graduate files within the required 60 days and will work with our representatives from National Student Clearinghouse to verify the information we submit has been properly uploaded to the NSLDS. We will also verify with the NSLDS that this information has been received. The people responsible for this will be Julie Brown (and other members of the Registrar?s Office that upload information to the National Student Clearinghouse) and Florence Attino. This will be an ongoing process as we upload this information multiple times a year.

Corrective Action Plan

2021-001 Special Tests and Provisions, Enrollment Reporting United States Department of Education Student Financial Assistance Cluster ALN 84.033 Federal Work Study Program ALN 84.268 Federal Direct Loan Program Criteria: Enrollment reporting: Institutions are required to report enrollment information under the Direct Loan program via the National Student Loan Data System (NSLDS). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must report all enrollment changes within 60 days of the change in an enrollment status. Condition: The Law School did not report a change in enrollment within the required 60 days for 23 out of 24 students selected for testing. Cause: The Law School provided the enrollment reporting files to the National Student Clearinghouse. The National Student Clearinghouse is a service provider engaged to upload all enrollment reporting through the NSLDS. The Law School received an email confirmation from the National Student Clearinghouse confirming the files for the selected students had been uploaded. However, upon review, the Law School identified that the files were never uploaded. Effect: The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Enrollment information is used to determine several factors related to payment and interest on direct loans. Questioned Costs: None Context: See condition above. Recommendation: The Law School should implement controls to ensure timely submission occurs within the required 60 days. Corrective Actions Taken or Planned/ View of Responsible Officials: The law school will continue to upload graduate files within the required 60 days and will work with our representatives from National Student Clearinghouse to verify the information we submit has been properly uploaded to the NSLDS. We will also verify with the NSLDS that this information has been received. The people responsible for this will be Julie Brown (and other members of the Registrar?s Office that upload information to the National Student Clearinghouse) and Florence Attino. This will be an ongoing process as we upload this information multiple times a year. Responsible Persons: Julie Brown, Registrar, 718-780-7918, julie.brown@brooklaw.edu; Sarah Schimel, Associate Registrar, 718-780-7913, sarah.schimel@brooklaw.edu; Florence Attino, Assistant Director ? Office of Financial Aid, 718-780-7915, florence.attino@brooklaw.edu;

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2021-002
Procurement & Suspension/Debarment
MATERIAL WEAKNESS

The Law School does not have a written procurement policy. As such, the Law School could not provide sufficient documented rationale for sole source awards. Cause: The Law School has not previously received federal awards for programs requiring procurement of goods and services. As such, they were not aware of the procurement standards required regarding federal award programs. Effect: Procurements did not follow prescribed procurement standards. Sole source awards were not properly documented. Questioned Costs: None Context: See condition above. Recommendation: The Law School should develop a written procurement policy in line with the federal procurement standards. The Law School should ensure that the policy includes sufficient documentation to support compliance with the federal procurement standards. View of Responsible Officials: A Procurement Policy incorporating federal procurement standards identified in 2 CRF Part 200 will be posted by July 11, 2022. Awards, including sole source awards will be documented.

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Criteria: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Law School does not have a written procurement policy. As such, the Law School could not provide sufficient documented rationale for sole source awards. Cause: The Law School has not previously received federal awards for programs requiring procurement of goods and services. As such, they were not aware of the procurement standards required regarding federal award programs. Effect: Procurements did not follow prescribed procurement standards. Sole source awards were not properly documented. Questioned Costs: None Context: See condition above. Recommendation: The Law School should develop a written procurement policy in line with the federal procurement standards. The Law School should ensure that the policy includes sufficient documentation to support compliance with the federal procurement standards. View of Responsible Officials: A Procurement Policy incorporating federal procurement standards identified in 2 CRF Part 200 will be posted by July 11, 2022. Awards, including sole source awards will be documented.

Corrective Action Plan

2021-002 Procurement United States Department of Education? ALN 84.425F Higher Education Emergency Relief Fund Institutional Portion ALN 84.425N Higher Education Emergency Relief Fund for the Improvement of Postsecondary Education Formula Grant Criteria: Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition: The Law School does not have a written procurement policy. As such, the Law School could not provide sufficient documented rationale for sole source awards. Cause: The Law School has not previously received federal awards for programs requiring procurement of goods and services. As such, they were not aware of the procurement standards required regarding federal award programs. Effect: Procurements did not follow prescribed procurement standards. Sole source awards were not properly documented. Questioned Costs: None Context: See condition above. Recommendation: The Law School should develop a written procurement policy in line with the federal procurement standards. The Law School should ensure that the policy includes sufficient documentation to support compliance with the federal procurement standards. Corrective Actions Taken or Planned/ View of Responsible Officials: A Procurement Policy incorporating federal procurement standards identified in 2 CRF Part 200 will be posted by July 11, 2022. Awards, including sole source awards will be documented. Responsible Persons: Stephanie Vullo, Chief Compliance Officer, 718-780-0605, stephanie.vullo@brooklaw.edu; Herberth Melendez, Associate General Counsel, 718-780-7952, herberth.melendez@brooklaw.edu.

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2021-003
Reporting

The Law School did not meet the deadline for posting the required information for six of seven reporting periods for the student portion. The Law School was unable to provide evidence of posting the required information for three of the required reporting periods for the student portion. The Law School did not meet the deadline for posting the required information for two of the reporting periods for the institutional portion. The Law School was unable to provide evidence of the filing of the annual report. Cause: The Law School did not have controls in place to track the required deadlines for posting required information. The Law School did maintain the required documentation to support the posting of the required information to the website. Effect: Reporting requirements were not met. Questioned Costs: None Context: See condition above. Recommendation: The Law School should develop controls to ensure timely posting of the required information and documentation is maintained to support that the reporting requirements were met. View of Responsible Officials: The student portion of the public reporting will be updated no later than July 11, 2022, and all quarters reported will remain on the website for that year.

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Criteria: Institutions that received Higher Education Emergency Relief Fund (HEERF) 18004(a)(1) student portion required information to be publicly posted on the institutions primary website. Institutions that received HEERF 18004(a)(2) and (a)(3) required information to be publicly posted in the same place as the student portion public reporting. Annual reporting is to be submitted via the portal. Condition: The Law School did not meet the deadline for posting the required information for six of seven reporting periods for the student portion. The Law School was unable to provide evidence of posting the required information for three of the required reporting periods for the student portion. The Law School did not meet the deadline for posting the required information for two of the reporting periods for the institutional portion. The Law School was unable to provide evidence of the filing of the annual report. Cause: The Law School did not have controls in place to track the required deadlines for posting required information. The Law School did maintain the required documentation to support the posting of the required information to the website. Effect: Reporting requirements were not met. Questioned Costs: None Context: See condition above. Recommendation: The Law School should develop controls to ensure timely posting of the required information and documentation is maintained to support that the reporting requirements were met. View of Responsible Officials: The student portion of the public reporting will be updated no later than July 11, 2022, and all quarters reported will remain on the website for that year.

Corrective Action Plan

2021-003 Reporting United States Department of Education? ALN 84.425F Higher Education Emergency Relief Fund Institutional Portion ALN 84.425N Higher Education Emergency Relief Fund for the Improvement of Postsecondary Education Formula Grant Criteria: Institutions that received Higher Education Emergency Relief Fund (HEERF) 18004(a)(1) student portion required information to be publicly posted on the institution?s primary website. Institutions that received HEERF 18004(a)(2) and (a)(3) required information to be publicly posted in the same place as the student portion public reporting. Annual reporting is to be submitted via the portal. Condition: The Law School did not meet the deadline for posting the required information for six of seven reporting periods for the student portion. The Law School was unable to provide evidence of posting the required information for three of the required reporting periods for the student portion. The Law School did not meet the deadline for posting the required information for two of the reporting periods for the institutional portion. The Law School was unable to provide evidence of the filing of the annual report. Cause: The Law School did not have controls in place to track the required deadlines for posting required information. The Law School did maintain the required documentation to support the posting of the required information to the website. Effect: Reporting requirements were not met. Questioned Costs: None Context: See condition above. Recommendation: The Law School should develop controls to ensure timely posting of the required information and documentation is maintained to support that the reporting requirements were met. Corrective Actions Taken or Planned/ View of Responsible Officials: The student portion of the public reporting will be updated no later than July 11, 2022, and all quarters reported will remain on the website for that year. Responsible Persons: Nancy Zahzam, Director of Financial Aid, 718-780-0308, nancy.zahzam@brooklaw.edu ;

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FY 2019-06-30

FAC accepted this audit on October 27, 2019 — management decision was due April 27, 2020.

2019-001
Special Tests & Provisions

The Law School does not have written policies that address the requirements identified by the Department of Education related to verification and satisfactory academic progress (SAP). Cause: The underlying cause is due to the relatively small population of need-based students receiving aid that would be subject to selection for verification. The Law School currently has a SAP policy; however, due to a lack of oversight, some of the specific requirements were not included in this policy. Effect: As a result of these matters, the Law School could provide aid to students that have not been appropriately verified or that are not meeting SAP. Questioned costs: None. Context: See condition and effect. There was no sampling required in testing compliance with these requirements related to written procedures. Recommendation: We recommend that management review the appropriate guidance and provisions and publish written policies for verification and satisfactory academic progress. View of Responsible Officials: See corrective action plan.

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2019 ? 001 Special Tests and Provisions, Written Policies and Procedures United Stated Department of Education ? Student Financial Assistance Cluster: CFDA # 84.033 Federal Work Study Program CFDA # 84.268 Federal Direct Loan Program Criteria: Verification: An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.63 for verifying applicant information. Institutional Eligibility: Institutions must establish and publish reasonable standards for measuring whether eligible students are maintaining satisfactory progress in their educational program. The institution?s standards are reasonable if the standards incorporate the provisions of 668.16(e) and 668.34. Condition: The Law School does not have written policies that address the requirements identified by the Department of Education related to verification and satisfactory academic progress (SAP). Cause: The underlying cause is due to the relatively small population of need-based students receiving aid that would be subject to selection for verification. The Law School currently has a SAP policy; however, due to a lack of oversight, some of the specific requirements were not included in this policy. Effect: As a result of these matters, the Law School could provide aid to students that have not been appropriately verified or that are not meeting SAP. Questioned costs: None. Context: See condition and effect. There was no sampling required in testing compliance with these requirements related to written procedures. Recommendation: We recommend that management review the appropriate guidance and provisions and publish written policies for verification and satisfactory academic progress. View of Responsible Officials: See corrective action plan.

Corrective Action Plan

2019-001 and 2019-002:The following corrective action will take place in November 2019:? A written policy will be created to incorporate the Department of Education requirements that require verifications as part of the Federal Student Aid program. ? A policy will be included in the student handbook to establish reasonable standards for measuring whether eligible students are maintaining satisfactory progress in their educational program. Persons responsible for implementation are: Nancy Zahzam 718-780-0308 Stephanie Vullo 718-780-0605

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2019-002
Special Tests & Provisions

2019 ? 002 Special Tests and Provisions United Stated Department of Education ? Student Financial Assistance Cluster: CFDA # 84.033 Federal Work Study Program CFDA # 84.268 Federal Direct Loan Program See 2019-001.

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2019 ? 002 Special Tests and Provisions United Stated Department of Education ? Student Financial Assistance Cluster: CFDA # 84.033 Federal Work Study Program CFDA # 84.268 Federal Direct Loan Program See 2019-001.

Corrective Action Plan

2019-001 and 2019-002:The following corrective action will take place in November 2019:? A written policy will be created to incorporate the Department of Education requirements that require verifications as part of the Federal Student Aid program. ? A policy will be included in the student handbook to establish reasonable standards for measuring whether eligible students are maintaining satisfactory progress in their educational program. Persons responsible for implementation are: Nancy Zahzam 718-780-0308 Stephanie Vullo 718-780-0605

About Special Tests and Provisions →

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