EIN: 042104258
UEI: WC1GM4ABEXH4
Audited by: Grant Thornton, LLP
Oversight agency: 84 [Department of Education]
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Data as of August 31, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 24, 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 24, 2026 (23 days from today).
What is a management decision? →FAC accepted this audit on January 6, 2025 — management decision was due July 6, 2025.
FAC accepted this audit on February 27, 2024 — management decision was due August 27, 2024.
FAC accepted this audit on March 28, 2023 — management decision was due September 28, 2023.
FAC accepted this audit on April 11, 2022 — management decision was due October 11, 2022.
Finding 2021-001: Special Tests and Provisions: Enrollment Reporting (Significant Deficiency) Federal Programs U.S. Department of Education Federal Direct Student Loans (AL# 84.268) and Federal Pell Grant Program (AL#84.063) Award year ended June 30, 2021 Criteria: Under the Federal Pell Grant Program and U.S. Department of Education (?ED?) loan programs, institutions are required to report student enrollment information via the National Student Loan Data System (?NSLDS?) (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access website. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS maintains as the most recently certified enrollment information. There are two categories of enrollment information; ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. In addition, Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website. Condition and Context: In a sample of forty (40) students, we identified three (3) instances in which the College incorrectly reported the student as withdrawn, when in fact the student had graduated. Upon investigation by the College, it was noted that similar errors had occurred in reporting certain May 2021 graduates (as withdrawn, not graduated). We also noted that these status changes were not completed within the appropriate timeframe (outside of the 60 day window). Cause: Management?s review of the NSLDS reporting was not at the level to identify this error. Effect: Certain students were incorrectly reported as withdrawn and not as graduated, and the students? status changes were not submitted timely. Questioned Costs: None noted. Repeat Finding: No Recommendation: The College should implement procedures to ensure that students? enrollment reporting data are reported to the NSLDS accurately and in accordance with the NSLDS Enrollment Guide. Views of Responsible Officials: Management agrees with the finding and has implemented changes to controls and processes to ensure similar errors will not occur in the future. Refer to Corrective Action Plan for further information.
Show full finding ▾Hide full finding ▴Finding 2021-001: Special Tests and Provisions: Enrollment Reporting (Significant Deficiency) Federal Programs U.S. Department of Education Federal Direct Student Loans (AL# 84.268) and Federal Pell Grant Program (AL#84.063) Award year ended June 30, 2021 Criteria: Under the Federal Pell Grant Program and U.S. Department of Education (?ED?) loan programs, institutions are required to report student enrollment information via the National Student Loan Data System (?NSLDS?) (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access website. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS maintains as the most recently certified enrollment information. There are two categories of enrollment information; ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. In addition, Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via NSLDS. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website. Condition and Context: In a sample of forty (40) students, we identified three (3) instances in which the College incorrectly reported the student as withdrawn, when in fact the student had graduated. Upon investigation by the College, it was noted that similar errors had occurred in reporting certain May 2021 graduates (as withdrawn, not graduated). We also noted that these status changes were not completed within the appropriate timeframe (outside of the 60 day window). Cause: Management?s review of the NSLDS reporting was not at the level to identify this error. Effect: Certain students were incorrectly reported as withdrawn and not as graduated, and the students? status changes were not submitted timely. Questioned Costs: None noted. Repeat Finding: No Recommendation: The College should implement procedures to ensure that students? enrollment reporting data are reported to the NSLDS accurately and in accordance with the NSLDS Enrollment Guide. Views of Responsible Officials: Management agrees with the finding and has implemented changes to controls and processes to ensure similar errors will not occur in the future. Refer to Corrective Action Plan for further information.
Finding 2021-001 Summary response: In our research regarding the reporting error, it has been determined that there was an issue with the enrollment reporting batch of the May 2021 graduating seniors. The problem that occurred with this batch did not occur in either of the previous batches nor subsequent batches. In order to prevent this reporting error in the future, a quality control process has been established. The Registrar's Office will run a report including the entire list of recent graduates. This list will be given to the Office of Student Financial Services to investigate and determine if any of the recently graduating students are missing in the enrollment reporting batch. Any student missing from the batch will be reported to the Registrar's Office who will update the information in their system and run a new enrollment report batch which will be given to the Office of Student Financial Services to be evaluated. This process will continue until all discrepancies are resolved. Contact information for responsible official: Daniel O?Connell, Director of Student Financial Services Anticipated completion date: Completed
FAC accepted this audit on September 27, 2021 — management decision was due March 27, 2022.
Management was not able to provide sufficient evidence to support the accuracy of the information posted to the College?s website. Cause: Management worked with the Department of Education to verify that the information posted to the College?s website included all required elements. However, contemporaneous documentation of the information that was posted to the website was not stored in a manner that would allow management to provide supporting documentation that the required information posted to the website was accurate. Effect: Management is not able to provide evidence to support the information previously posted its website. Questioned Costs: None identified. Identified as a Repeat Finding: No. Recommendation: We recommend that the College maintain hard copy or electronic records of the information posted on its website as required by the Department of Education. Views of Responsible Officials: The College acknowledges its inability to provide proof supporting the accuracy of the required information being posted to the College?s website. Management intends to modify existing processes to ensure contemporaneous screen shots of the information posted to the website is maintained in the College?s records going forward. Please refer to the attached Corrective Action Plan for further detail.
Show full finding ▾Hide full finding ▴Finding 2020-001 Reporting Compliance and Internal Control (Significant Deficiency) U.S. Department of Education ? Education Stabilization Fund (Assistance Listing Number 84.425E ? Student Portion) Criteria: Per Section 18004(a)(1) Student Aid Portion Quarterly Public Reporting of the CARES Act, beginning on May 6, 2020, institutions that received a HEERF 18004(a)(1) Student Aid Portion award were required to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). Context and Condition: Management was not able to provide sufficient evidence to support the accuracy of the information posted to the College?s website. Cause: Management worked with the Department of Education to verify that the information posted to the College?s website included all required elements. However, contemporaneous documentation of the information that was posted to the website was not stored in a manner that would allow management to provide supporting documentation that the required information posted to the website was accurate. Effect: Management is not able to provide evidence to support the information previously posted its website. Questioned Costs: None identified. Identified as a Repeat Finding: No. Recommendation: We recommend that the College maintain hard copy or electronic records of the information posted on its website as required by the Department of Education. Views of Responsible Officials: The College acknowledges its inability to provide proof supporting the accuracy of the required information being posted to the College?s website. Management intends to modify existing processes to ensure contemporaneous screen shots of the information posted to the website is maintained in the College?s records going forward. Please refer to the attached Corrective Action Plan for further detail.
Finding 2020-001 Summary response: The College acknowledges our inability to provide acceptable proof of the required information posted in the College?s website. It is important to note the Department of Education representative was able to provide direct verification to Grant Thornton of our timely and accurate reporting. We believe their verification to not only be sufficient, but really the best proof that could be provided. Please find the direct quote below: ?I can confirm that Gordon College posted the required information to their website in reference to the HEERF student aid portion. I had frequent communications with Jess Haas Greus, the Executive Director at the time, and she was very thorough in her reporting communications with me. I am sorry that I do not have screenshots to share with you, but I did view the website when she communicated with me.? Our intended action plan is to save contemporaneous screen shots of the information posted with an appropriate time stamp. This will be part of our file going forward. It should be noted that due to the various extensions in time completing the Uniform Guidance Audit for fiscal 2020, this action plan was not able to be developed and implemented until the summer of 2021. As such, it is possible that there could be a repeat finding in future years. Contact information for responsible official: Stephen D. Lacorazza, VP for Finance & CFO Anticipated completion date: Completed
FAC accepted this audit on February 3, 2020 — management decision was due August 3, 2020.
FAC accepted this audit on February 7, 2019 — management decision was due August 7, 2019.
FAC accepted this audit on December 17, 2017 — management decision was due June 17, 2018.
FAC accepted this audit on February 7, 2017 — management decision was due August 7, 2017.
GSA_MIGRATION
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GSA_MIGRATION
2015-001
GSA_MIGRATION
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GSA_MIGRATION
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