June 10, 2026
Pamela Madeiros, Shareholder
Greenberg Traurig, LLP
54 State Street
Albany, NY 12207
T +1 518.689.1412 | F +1 518.689.1499
MadeirosP@gtlaw.com
APPEAL DEADLINE: JUNE 15, 2026 — 5 DAYS FROM DATE OF THIS LETTER
Re:
BPSS License Renewal Denial — Identified Deficiencies, Immediate Corrective Action & 2026 Digital Infrastructure Plan
Case No.: 800000091543 · BPSS Determination Date: June 3, 2026
Dear Ms. Madeiros:
We write to provide you with a full account of the circumstances surrounding the June 3, 2026 license renewal denial issued by the New York State Education Department's Bureau of Proprietary School Supervision ("BPSS"), and to document the corrective actions management has taken — and is actively implementing — in response to the deficiencies identified.
We respectfully request your guidance on the appeal process under BPSS Policy Guideline 33-0217 and on the most effective way to present our corrective record to the Bureau. We want to be direct with counsel: the deficiencies BPSS identified are real. We do not dispute the factual findings. What we are here to demonstrate is that management has accepted full responsibility, identified the root causes, and is executing a structured plan — including immediate manual protocol corrections already in effect and a permanent digital infrastructure platform currently under active development — to ensure these failures do not recur.
I. Summary of BPSS Determination
On June 3, 2026, BPSS issued a denial of Efficient Care Training Center's license renewal application (Case No. 800000091543), citing nine areas of noncompliance identified during a renewal inspection of a 60-student file sample. The determination was signed by Melissa Lurie, Supervisor of Education Programs, and requires the school to cease enrolling new students effective June 3, 2026.
The nine cited areas of noncompliance are:
1. Failure to properly execute and fulfill the terms of student enrollment agreements
2. Failure to enroll only students meeting minimum entrance requirements
3. Failure to correctly charge and refund students
4. Failure to properly record and monitor students' attendance and earned instructional hours
5. Failure to evaluate students' academic progress and administer SAP procedures
6. Failure to demonstrate adequate administration and supervision of internship programs
7. Failure to accurately document student academic progress and program completion
8. Failure to utilize only appropriately licensed teachers
9. Failure to offer curricula as approved, in a compliant learning environment
BPSS additionally cited a pattern of noncompliance dating to the 2022 renewal review and a 2024 complaint investigation, noting that deficiencies previously agreed to under corrective action plans were repeated during the current licensure period.
II. Root Cause Assessment — What Management Found
Following receipt of the BPSS determination, management commissioned an internal operational review of every administrative process cited. Our findings were consistent with BPSS's: the school's systems were inadequate — not because individual staff were indifferent, but because the paper-based, manual infrastructure provided no enforcement mechanisms. Staff were expected to adhere to procedure by habit, without any system that made non-compliance impossible or even difficult.
Specifically, management identified the following root causes:
• Enrollment agreements were processed manually with no required-field enforcement, enabling incomplete or late execution to pass without administrative flag or block.
• Entrance requirement documentation was collected informally with no checklist or system block preventing enrollment without verified credentials on file.
• Attendance registers were maintained by individual student rather than by class cohort, making it impossible to identify scheduling conflicts, capacity violations, or simultaneous instructor assignments.
• Financial ledgers were populated manually and independently of enrollment agreements, creating conditions for charge inconsistencies across cohorts.
• SAP evaluation was entirely paper-dependent with no administrative trigger or reminder — the absence of completed forms was not surfaced until external review.
• Skills checklists were not subject to any timestamp or verification control, making pre-signing both possible and undetectable under the existing system.
• Internship documentation depended entirely on staff follow-through without any system-enforced verification or site registry.
• Instructor credential records were maintained in physical files with no automated expiration alert or class-assignment block.
These are systemic failures, not isolated incidents. Management accepts that responsibility fully and has taken the following immediate corrective actions while the permanent digital infrastructure is being built.
III. Leadership Change
As a direct result of this assessment, Best Career Training LLC has made a significant change in organizational leadership. Management has appointed a new Director of Education — a key employee of thirteen (13) years whose institutional knowledge, commitment to compliance, and operational experience have been demonstrated throughout her tenure with the school.
This appointment has been submitted to BPSS for approval in accordance with applicable regulations, and we are currently awaiting the Bureau's determination. The incoming Director has been fully briefed on every identified deficiency and on the corrective protocols now in effect. She has the authority and the mandate to enforce compliance at every level of the organization from day one.
Management's decision to change leadership reflects a fundamental conclusion: structural reform requires not only new systems, but accountable leadership with the standing to enforce them. We ask that this transition be considered by BPSS as evidence of management's good faith and its seriousness of purpose.
IV. Immediate Manual Corrections — In Effect Now
Pending full deployment of the BestApp digital platform (see Section V), management has implemented written operational protocols for every cited deficiency. These protocols are in effect now, enforced by the Director of Education and documented in writing:
1. Enrollment Agreement ExecutionMandatory multi-point checklist before any enrollment agreement is issued. No agreement may be dated before all required fields are completed and all required attachments are on file. Agents are required to initial each checklist item and return the checklist with the agreement.
2. Entrance RequirementsA written intake checklist has been implemented requiring documented verification of: minimum age (government-issued ID), high school diploma or GED (certified copy), and work authorization. No enrollment may proceed without all three verified items in the student's file.
3. Tuition, Fees & Refund ProcessingAll charges and refunds are now routed through a dual-sign approval process requiring both the agent responsible for the enrollment and the Director of Education. A fee schedule reconciliation is performed at enrollment and at each billing milestone against the signed enrollment agreement.
4. Attendance RecordingA class-level (cohort-based) attendance register has replaced the individual student register format. Every roster now captures instructor name, class date, session start/end times, and student sign-in/sign-out. Rosters are submitted to administration within 24 hours of each class session.
5. SAP — Satisfactory Academic ProgressA calendar-based SAP review schedule has been implemented. SAP evaluations are required at the 50% program point and at program completion. The Director of Education is responsible for reviewing and countersigning all evaluations. A student whose SAP is not current is flagged and may not continue until the evaluation is completed.
6. Internship AdministrationA written internship site registry has been established listing every approved placement site with site supervisor, address, and agreement status. Students may only be placed at approved sites. Site visit documentation is required from the supervising instructor within 72 hours of each placement visit.
7. Student Progress & Completion DocumentationSkills checklists are now completed at the time of skills demonstration only — no advance preparation. Each checklist is time-stamped on submission by the supervising instructor. A student file is not considered complete until all required checklists, attendance, SAP, and completion documentation are present and signed.
8. Instructor LicensingA credential file has been established for every instructor of record, including copies of all applicable licenses and certifications with expiration dates. No instructor may be assigned to a class if their credential file is incomplete or contains an expired document. The Director reviews all credential files at the start of each month.
9. Curriculum & Learning EnvironmentThe BPSS-approved curriculum has been reinstated as the exclusive curriculum template. Any deviation from the approved curriculum requires prior written approval from the Director of Education and, where required, notification to BPSS. A classroom inspection checklist has been implemented to document physical compliance with approved learning environment standards before each class cycle begins.
V. 2026 Digital Infrastructure — BestApp Platform
The manual protocols described in Section IV are operational bridges — immediate, enforced, and documented — pending the deployment of a permanent digital compliance infrastructure currently under active development. This platform, internally designated BestApp, has been scoped and architected specifically to make every cited deficiency structurally impossible to repeat.
BestApp is not a revised policy manual or an administrative pledge. It is a purpose-built system that removes the human discretion responsible for the failures BPSS identified. The following capabilities are scheduled for Q4 2026 deployment:
Q4 2026 — Digital Infrastructure LaunchDigital enrollment with required-field enforcement · Entrance requirement document upload and verification · Fee schedule auto-population from enrollment agreement · Class-level attendance registers with instructor signature · Skills checklist with GPS-verified timestamp at point of demonstration · SAP triggers at 50% and completion · HCR auto-submission · Student portal for program verification · Internship site registry and visit documentation · Credential monitoring with auto-expiration alerts · 20-year encrypted archive with BPSS-formatted export
Architectural CommitmentNo enrollment agreement can be submitted with missing fields. No skills checklist can be pre-dated. No instructor can be assigned with a lapsed credential. Structural enforcement — not policy — is the compliance mechanism.
VI. Relief Requested
We respectfully request that counsel advise on the following:
(a) The form, content, and deadline requirements for a timely appeal of the June 3, 2026 BPSS determination under Policy Guideline 33-0217;
(b) The most effective way to present the manual corrections already in effect and the BestApp development roadmap as evidence of corrective action in the appeal proceeding;
(c) Whether the school may present its position at an administrative hearing, and how to request one;
(d) Any additional documentation, certifications, or representations counsel recommends the school provide to BPSS in support of license reinstatement;
(e) Whether BPSS has any informal resolution or consent order process that may permit resumption of enrollment while the appeal is pending.
We are committed to full transparency with counsel and with BPSS. We recognize that the school's prior corrective action commitments were not fulfilled, and we understand that the credibility of our current efforts depends entirely on demonstrated action rather than renewed assurances. We are prepared to provide whatever supplementary documentation, third-party verifications, or direct access to our systems counsel recommends.
We respectfully request your earliest guidance, given the June 15, 2026 appeal deadline. Please do not hesitate to contact us directly at the information below.
Respectfully submitted,
Aron Fried
President & Owner
Best Career Training LLC d/b/a Efficient Care Training Center
1399 Myrtle Avenue, 2nd Floor · Brooklyn, NY 11237
718-355-9006 · bestcareer@leibishfried.com
