Southwestern Law School

FINDING 2024-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance (See table in Text of the Audit FindingSchedule of Findings and Questioned Costs"). Criteria – 34 CFR section 685.309(b)(2): 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/context – A sample of 40 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2023-2024 academic year. The enrollment information and withdrawal, address change, or graduation date per the School’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Of the 40 students who had a change in address, graduated, or withdrew, 21 were not reported to the NSLDS within the required timeframe, 2 had incorrect effective dates reported to the NSLDS, and 1 had an incorrect status reported to the NSLDS. Cause – The School does not have formally documented policies requiring information submitted to the NSLDS be reviewed for completeness and accuracy, or policies for monitoring reporting deadlines. Effect – The NSLDS database did not include accurate information until the point at which it was corrected. This information is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status, deferment, and grace periods of student loans. Incorrect information could result in incorrect deferment, grace periods, billing, and repayment of student loans. Repeat Finding – This is not a repeat finding. Recommendation – We recommend Southwestern Law School establish a formal policy requiring a review of student status information submitted to the NSLDS, by a third-party intermediary on the School’s behalf, for completeness and accuracy. We also recommend the School establish a cadence of monitoring reporting deadlines, particularly those around classes of graduating students. Views of responsible officials and planned corrective actions – Management agrees with the finding. See the corrective action plan for further detail. Responsible Offices and Individuals – Improving procedures around enrollment reporting is the joint responsibility of the Registrar’s Office and the Information Technology Office. Eileen Zwiers, Registrar, and Sean Murphy, Chief Information Officer, are responsible for implementing the corrective action plan. Corrective Action Plan – Southwestern has prepared and implemented a new Enrollment Reporting Policy to ensure Title IV compliance when reporting changes in student enrollment status to the National Student Loan Data System. The policy outlines Southwestern’s procedures for timely, accurate, and complete reporting through the National Student Clearinghouse. Additionally, the Financial Aid Office will conduct monthly random audits of reported submissions directly from the National Student Loan Data System portal to ensure accuracy. The Financial Aid Office documents and securely stores these verified submissions to support the federal audit, in compliance with federal retention and data management policies. Anticipated Completion Date - The anticipated completion date of the corrective action plan is September 2024.

2019-002 ? Special Tests and Provisions ? Borrower Date Transmission and Reconciliations ? Significant Deficiency in Internal Control Over Compliance (See Schedule of Findings and Questioned Costs for table) Criteria ? Per the Uniform Guidance 34 CFR 685.300(b)(5), the Law School is required to reconcile its records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary on a monthly basis. Condition/Context ? During our testing over Borrower Data Transmission and Reconciliation (Direct Loan), monthly School Account Statement (SAS) reconciliations were not performed as required by the Uniform Guidance. Questioned Costs ? No questioned costs were identified as part of this finding Effect ? The SAS is similar to a bank statement and gives the Department?s official cash balance as of the end date of the reported period, based on data submitted by the school. It also gives detailed cash and loan or disbursement transactions for that reported period. The SAS is the primary tool for reconciliation and program year closeout. Therefore, the noncompliance and significant deficiency in Borrower Data Transmission and Reconciliation could result in un-reconciling cash balance between the Department and the Law School, which could impact program year close out and future findings. Cause ? This exception occurred as a result of lacking policy and procedures in place to ensure SAS reconciliation are performed monthly as required by the Uniform Guidance. Recommendation ? We recommend that the Law School develops policy and procedures to ensure SAS reconciliations are performed timely and reconciliations are performed and reviewed by two different appropriate individuals. Repeat Finding ? This is not a repeat finding. Views of responsible officials and planned corrective actions ? Management is updating their process for monthly reconciliations of Federal Direct Loan funds to include the additional review and reconciliation of the ending cash as reported on the Student Account Statement provided by the Department of Education.