EIN: 116002404
UEI: DMJQEF9VK8E7
Audited by: Craig, Fitzsimmons & Meyer, 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 31, 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 October 1, 2026 (29 days from today).
What is a management decision? →Return of Title IV Funds (R2T4) – Untimely Return of Unearned Title IV Funds. Recommendation We recommend that management strengthen controls over the Return of Title IV Funds process by implementing procedures to ensure that required returns are submitted within the 45-day regulatory timeframe. This may include formal tracking of withdrawal determination dates, periodic supervisory review of pending R2T4 returns, and documented follow-up procedures to ensure timely submission. Federal Program Student Financial Aid Cluster Federal Supplemental Educational Opportunity Grant (ALN 84.007) Federal Pell Grant Program (ALN 84.063) Federal Direct Student Loans (ALN 84.268) Compliance Requirement Return of Title IV Funds (R2T4) Criteria Federal regulations require that when a Title IV recipient withdraws from an institution prior to completing the payment period or period of enrollment, the institution must return any unearned Title IV funds no later than 45 days after the date the institution determines that the student withdrew (34 CFR §668.22(j)). Institutions are required to establish internal controls to ensure withdrawals are identified timely, R2T4 calculations are accurate, and required returns are made within prescribed timeframes. Condition During our testing of compliance with the Return of Title IV Funds requirements, we identified that required returns of unearned Title IV funds were not made within the 45-day regulatory timeframe. Specifically, for all 7 students who withdrew during the audit period and were selected for testing, the institution returned unearned Title IV funds between 69 and 118 days after the withdrawal determination date. While the institution accurately identified withdrawals, correctly determined withdrawal dates, and accurately calculated the amount of Title IV aid earned and unearned, returns were consistently processed after the required deadline. Cause The institution did not have effective controls in place to ensure that R2T4 returns were processed and submitted within the required 45-day timeframe. Although R2T4 calculations were prepared and reviewed, the control procedures did not include adequate monitoring or escalation to ensure timely submission of required returns. Effect Failure to return unearned Title IV funds within required timeframes constitutes noncompliance with federal regulations. Although all required funds were ultimately returned and no calculation errors were identified, untimely returns increase the risk of improper retention of federal funds and may subject the institution to administrative action or penalties by the U.S. Department of Education. Questioned Costs None. All unearned Title IV funds were ultimately returned, and no amounts were identified as ineligible or improperly calculated.
Show full finding ▾Hide full finding ▴Return of Title IV Funds (R2T4) – Untimely Return of Unearned Title IV Funds. Recommendation We recommend that management strengthen controls over the Return of Title IV Funds process by implementing procedures to ensure that required returns are submitted within the 45-day regulatory timeframe. This may include formal tracking of withdrawal determination dates, periodic supervisory review of pending R2T4 returns, and documented follow-up procedures to ensure timely submission. Federal Program Student Financial Aid Cluster Federal Supplemental Educational Opportunity Grant (ALN 84.007) Federal Pell Grant Program (ALN 84.063) Federal Direct Student Loans (ALN 84.268) Compliance Requirement Return of Title IV Funds (R2T4) Criteria Federal regulations require that when a Title IV recipient withdraws from an institution prior to completing the payment period or period of enrollment, the institution must return any unearned Title IV funds no later than 45 days after the date the institution determines that the student withdrew (34 CFR §668.22(j)). Institutions are required to establish internal controls to ensure withdrawals are identified timely, R2T4 calculations are accurate, and required returns are made within prescribed timeframes. Condition During our testing of compliance with the Return of Title IV Funds requirements, we identified that required returns of unearned Title IV funds were not made within the 45-day regulatory timeframe. Specifically, for all 7 students who withdrew during the audit period and were selected for testing, the institution returned unearned Title IV funds between 69 and 118 days after the withdrawal determination date. While the institution accurately identified withdrawals, correctly determined withdrawal dates, and accurately calculated the amount of Title IV aid earned and unearned, returns were consistently processed after the required deadline. Cause The institution did not have effective controls in place to ensure that R2T4 returns were processed and submitted within the required 45-day timeframe. Although R2T4 calculations were prepared and reviewed, the control procedures did not include adequate monitoring or escalation to ensure timely submission of required returns. Effect Failure to return unearned Title IV funds within required timeframes constitutes noncompliance with federal regulations. Although all required funds were ultimately returned and no calculation errors were identified, untimely returns increase the risk of improper retention of federal funds and may subject the institution to administrative action or penalties by the U.S. Department of Education. Questioned Costs None. All unearned Title IV funds were ultimately returned, and no amounts were identified as ineligible or improperly calculated.
Management agrees with the finding and has indicated that corrective actions will be implemented to improve monitoring and timeliness of R2T4 returns. Management’s corrective action plan is included in the accompanying schedule.
Federal Program Student Financial Aid Cluster Federal Supplemental Educational Opportunity Grant (ALN 84.007) Federal Pell Grant Program (ALN 84.063) Federal Direct Student Loans (ALN 84.268) Compliance Requirement Special Tests and Provisions – Information Security Criteria The GLBA Safeguards Rule requires covered institutions to develop, implement, and maintain a written information security program containing administrative, technical, and physical safeguards to protect customer information. [ftc.gov], [ecfr.gov] Condition VEEB is subject to the requirements of the Gramm-Leach-Bliley Act (GLBA) Safeguards Rule. During the audit, it was noted that VEEB does not have a written information security program as required by 16 CFR Part 314. While certain informal information security practices may be in place, the absence of a formally documented program does not meet GLBA requirements. Cause Management has not formalized information security policies and procedures into a written information security program. Effect Without a written information security program, VEEB is not in full compliance with GLBA requirements applicable to its participation in federal student financial assistance programs. This increases the risk that sensitive student information may not be adequately safeguarded. Questioned Costs None. Recommendation We recommend that management develop, implement, and maintain a written information security program that complies with the GLBA Safeguards Rule, including documented administrative, technical, and physical safeguards appropriate to the size and complexity of the organization.
Show full finding ▾Hide full finding ▴Federal Program Student Financial Aid Cluster Federal Supplemental Educational Opportunity Grant (ALN 84.007) Federal Pell Grant Program (ALN 84.063) Federal Direct Student Loans (ALN 84.268) Compliance Requirement Special Tests and Provisions – Information Security Criteria The GLBA Safeguards Rule requires covered institutions to develop, implement, and maintain a written information security program containing administrative, technical, and physical safeguards to protect customer information. [ftc.gov], [ecfr.gov] Condition VEEB is subject to the requirements of the Gramm-Leach-Bliley Act (GLBA) Safeguards Rule. During the audit, it was noted that VEEB does not have a written information security program as required by 16 CFR Part 314. While certain informal information security practices may be in place, the absence of a formally documented program does not meet GLBA requirements. Cause Management has not formalized information security policies and procedures into a written information security program. Effect Without a written information security program, VEEB is not in full compliance with GLBA requirements applicable to its participation in federal student financial assistance programs. This increases the risk that sensitive student information may not be adequately safeguarded. Questioned Costs None. Recommendation We recommend that management develop, implement, and maintain a written information security program that complies with the GLBA Safeguards Rule, including documented administrative, technical, and physical safeguards appropriate to the size and complexity of the organization.
Management acknowledges the audit finding related to the absence of a formally documented written information security program. While VEEB has implemented certain administrative and technical safeguards to protect sensitive information, these practices have not been consolidated into a single, written information security program as required. Management is committed to addressing this matter and plans to formalize its existing information security practices into a written information security program that is appropriate to the size, complexity, and risk profile of the organization. Management expects to complete the development and implementation of the written program during the upcoming fiscal year. Management believes that this condition does not reflect a failure to safeguard information, but rather a documentation gap that will be remedied through the actions described above.
FAC accepted this audit on March 31, 2025 — management decision was due October 1, 2025.
FAC accepted this audit on April 2, 2024 — management decision was due October 2, 2024.
FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.
FAC accepted this audit on May 30, 2022 — management decision was due November 30, 2022.
FAC accepted this audit on October 11, 2021 — management decision was due April 11, 2022.
Our review of the VEEB?s written policies and procedures determined the following; Questioned Costs: None. Context: Certain policies were written however audit evidence determined that they were not adequate. Effect: The absence of adequately documented policies could jeopardize the VEEB?s ability to establish and maintain effective internal control over their Federal awards. Additionally, the lack of adequate policies may also jeopardize the VEEBs ability to maintain compliance with Federal statutes, regulations and the terms and conditions of their Federal awards. Cause: While in most cases policies were written, they have not been updated since 2010. Recommendation: We recommend the Board routinely reviews and affirms their written policies concerning their federal awards. Additionally, an assessment should be made as to the adequacy of the policy in place on a routine basis.
Show full finding ▾Hide full finding ▴Department of Education CFDA #84.007 Federal Supplemental Education Opportunity Grants CFDA #84.063 Federal Pell Grant Program CFDA #84.268 Federal Direct Student Loans Criteria: Uniform guidance 2 CFR part 200 Subpart D establishes requirements organizations must adopt and maintain once they have received federal awards. These requirements include written policies and procedures related to certain aspects of the post federal award. Condition: Our review of the VEEB?s written policies and procedures determined the following; Questioned Costs: None. Context: Certain policies were written however audit evidence determined that they were not adequate. Effect: The absence of adequately documented policies could jeopardize the VEEB?s ability to establish and maintain effective internal control over their Federal awards. Additionally, the lack of adequate policies may also jeopardize the VEEBs ability to maintain compliance with Federal statutes, regulations and the terms and conditions of their Federal awards. Cause: While in most cases policies were written, they have not been updated since 2010. Recommendation: We recommend the Board routinely reviews and affirms their written policies concerning their federal awards. Additionally, an assessment should be made as to the adequacy of the policy in place on a routine basis.
Management agrees with the finding presented. The Board of Directors is currently reviewing the Organization?s existing policies and procedures to ensure same are appropriate, and further, ensure the Organization is in compliance with 2 CFR 200 Subpart D. Moreover, the Board of Directors, at its annual organizational meeting, is instituting a mandatory review of all the Organization?s policies and procedures.
2019-007
FAC accepted this audit on May 3, 2020 — management decision was due November 3, 2020.
Our review of the VEEB?s written policies and procedures determined the following; Policy or Procedure Uniform Guidance Subsection Written Policy In Place? Policy Considered Adequate? Financial Management 200.302 Yes No Record Retention 200.333 Yes No Request for Transfer of Records 200.334 Yes No Methods for Collection, Transmission & Storage 200.335 No No Access to Records 200.336 Yes No Restrictions on Public Access 200.337 No No Payment 200.305 No No General Procurement 200.318 Yes Yes Competition 200.319 Yes Yes Methods of Procurement 200.320 Yes Yes Compensation - Personal Services 200.430 No No Compensation - Fringe Benefits 200.431 No No Relocation of Costs of Employees 200.464 No No Travel Costs 200.474 Yes No Questioned Costs: None. Context: Certain policies were written however audit evidence determined that they were not adequate. Effect: The absence of adequately documented policies could jeopardize the VEEB?s ability to establish and maintain effective internal control over their Federal awards. Additionally, the lack of adequate policies may also jeopardize the VEEBs ability to maintain compliance with Federal statutes, regulations and the terms and conditions of their Federal awards. Cause: While in most cases policies were written, they have not been updated since 2010. Recommendation: We recommend the Board routinely reviews and affirms their written policies concerning their federal awards. Additionally, an assessment should be made as to the adequacy of the policy in place on a routine basis.
Show full finding ▾Hide full finding ▴Department of Education CFDA #84.007 Federal Supplemental Education Opportunity Grants CFDA #84.063 Federal Pell Grant Program CFDA #84.268 Federal Direct Student Loans Criteria: Uniform guidance 2 CFR part 200 Subpart D establishes requirements organizations must adopt and maintain once they have received federal awards. These requirements include written policies and procedures related to certain aspects of the post federal award. Condition: Our review of the VEEB?s written policies and procedures determined the following; Policy or Procedure Uniform Guidance Subsection Written Policy In Place? Policy Considered Adequate? Financial Management 200.302 Yes No Record Retention 200.333 Yes No Request for Transfer of Records 200.334 Yes No Methods for Collection, Transmission & Storage 200.335 No No Access to Records 200.336 Yes No Restrictions on Public Access 200.337 No No Payment 200.305 No No General Procurement 200.318 Yes Yes Competition 200.319 Yes Yes Methods of Procurement 200.320 Yes Yes Compensation - Personal Services 200.430 No No Compensation - Fringe Benefits 200.431 No No Relocation of Costs of Employees 200.464 No No Travel Costs 200.474 Yes No Questioned Costs: None. Context: Certain policies were written however audit evidence determined that they were not adequate. Effect: The absence of adequately documented policies could jeopardize the VEEB?s ability to establish and maintain effective internal control over their Federal awards. Additionally, the lack of adequate policies may also jeopardize the VEEBs ability to maintain compliance with Federal statutes, regulations and the terms and conditions of their Federal awards. Cause: While in most cases policies were written, they have not been updated since 2010. Recommendation: We recommend the Board routinely reviews and affirms their written policies concerning their federal awards. Additionally, an assessment should be made as to the adequacy of the policy in place on a routine basis.
Management agrees with the finding presented. The Board of Directors is currently reviewing the Organization?s existing policies and procedures to ensure same are appropriate, and further, ensure the Organization is in compliance with 2 CFR 200 Subpart D. Moreover, the Board of Directors, at its annual organizational meeting, is instituting a mandatory review of all the Organization?s policies and procedures.
During our audit we noted two transfers from the Education program to the County program. One was for $204,063.49 the other for $300,000. While we found evidence the $300,000 was returned within two months, we found no evidence the $204,063.49 was returned in full. Questioned Costs: None. Context: See ?Condition? above. Effect: According to the supplement, funding should be drawn down to meet the immediate cash requirements for the approved program. The approved program in this case is the Nursing Program (Education). Failure to adhere to the supplement?s principles could result in the termination or discontinuance of program funding. Cause: Policies and procedures established by the VEEB are not being adhered to. Recommendation: We recommend the VEEB?s Board provide adequate training and education to VEEB management pertaining to cash management principles of federal awards.
Show full finding ▾Hide full finding ▴Department of Education CFDA #84.007 Federal Supplemental Education Opportunity Grants CFDA #84.063 Federal Pell Grant Program CFDA #84.268 Federal Direct Student Loans Criteria: Uniform guidance 2 CFR part 200 subsection 305 specifically states, ?The non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. Advance payments to a non- Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions.? Condition: During our audit we noted two transfers from the Education program to the County program. One was for $204,063.49 the other for $300,000. While we found evidence the $300,000 was returned within two months, we found no evidence the $204,063.49 was returned in full. Questioned Costs: None. Context: See ?Condition? above. Effect: According to the supplement, funding should be drawn down to meet the immediate cash requirements for the approved program. The approved program in this case is the Nursing Program (Education). Failure to adhere to the supplement?s principles could result in the termination or discontinuance of program funding. Cause: Policies and procedures established by the VEEB are not being adhered to. Recommendation: We recommend the VEEB?s Board provide adequate training and education to VEEB management pertaining to cash management principles of federal awards.
In prior years, the Organization waited until year-end to bill the Program for the applicable administrative management fee; amounts identified as a ?loan? during the year ended under audit did not exceed the applicable administrative management fee. Moving forward, the Organization will bill the Program on a quarterly basis to ensure it does not have to borrow against program or restricted funds. Moreover, the Organization is working with legal counsel to determine if the Organization may secure a small business line of credit should liquidity constraints arise during the year.
During our audit we noted the VEEB was not in compliance with their matching provisions. A flat dollar amount of $60 was awarded to all student files we sampled. Questioned Costs: $983 Context: See ?Condition? above. Effect: Matching for certain students may be over or understated. Cause: The VEEB uses an invoice item feature in QuickBooks which is mapped to reflect 25% for FSEOG. The issue is that the mapped invoice item is not formula driven. It is a hardcoded $60 value. Proper controls were not in place to ensure oversight of this calculation was being done properly. Recommendation: We recommend the VEEB revise their QuickBooks file to adequately reflect the proper matching amount according to the VEEB?s matching provisions.
Show full finding ▾Hide full finding ▴Department of Education CFDA #84.007 Federal Supplemental Education Opportunity Grants CFDA #84.063 Federal Pell Grant Program CFDA #84.268 Federal Direct Student Loans Criteria: The VEEB provides for matching of Federal Supplemental Education Opportunity Grants (FSEOG) as described under the provisions of Uniform guidance 2 CFR part 200 subsection 306. The VEEB matches 25% of FSEOG as in-kind contributions. Condition: During our audit we noted the VEEB was not in compliance with their matching provisions. A flat dollar amount of $60 was awarded to all student files we sampled. Questioned Costs: $983 Context: See ?Condition? above. Effect: Matching for certain students may be over or understated. Cause: The VEEB uses an invoice item feature in QuickBooks which is mapped to reflect 25% for FSEOG. The issue is that the mapped invoice item is not formula driven. It is a hardcoded $60 value. Proper controls were not in place to ensure oversight of this calculation was being done properly. Recommendation: We recommend the VEEB revise their QuickBooks file to adequately reflect the proper matching amount according to the VEEB?s matching provisions.
Management agrees with the finding presented. Management is working with a third-party consultant to assist the Organization with applying the applicable twenty-five percent (25%) matching of the Federal Supplemental Education Opportunity Grants as described under the provisions of 2 CFR 200 Subsection 306.
FAC accepted this audit on March 4, 2019 — management decision was due September 4, 2019.
FAC accepted this audit on March 21, 2018 — management decision was due September 21, 2018.
FAC accepted this audit on March 20, 2017 — management decision was due September 20, 2017.
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