EIN: 131624238
UEI: JCTLP6ZCJP85
Audited by: PKF O'Connor Davies LLP
Oversight agency: 84 [Department of Education]
View federal awards & risk assessment →
Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 24, 2025. 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 June 24, 2026 (69 days ago).
What is a management decision? →Two of three students’ enrollment status changes were not recorded accurately and timely to NSLDS and during the year ended June 30, 2025. Cause: Due to turnover in the Seminary’s Registrar department, enrollment reporting during high volume periods, such as graduation, were delayed due limits in work capacity of the staff available during the fiscal year. Effect: The Seminary was not in compliance with enrollment reporting requirements. Questioned Costs: None. Repeat Finding: Yes, see prior year finding 2024-006. Recommendation: We recommend that the Seminary enhance existing policies to comply with enrollment reporting requirements. This policy should include a method for ensuring both timely enrollment updates as well as accuracy of the data reported. Views of Responsible Officials: See corrective action plan attached.
Show full finding ▾Hide full finding ▴Special Tests – Enrollment Reporting Federal Assistance Listing Number: 84.268 Name of Program or Cluster: Federal Direct Student Loans (Student Financial Aid Cluster) Agency: Department of Education Criteria: Institutions are required to report enrollment information under the Federal Pell Grant and Federal Direct Student Loans programs via the National Student Loan Data System (“NSLDS”). Institutions must complete and return the Enrollment Reporting roster placed in their Student Aid Internet Gateway mailboxes sent by the U.S. Department of Education via NSLDS within 15 days of receipt of the roster. Additionally, institutions are required to report changes in student enrollment status via NSLDS within 60 days. Condition: Two of three students’ enrollment status changes were not recorded accurately and timely to NSLDS and during the year ended June 30, 2025. Cause: Due to turnover in the Seminary’s Registrar department, enrollment reporting during high volume periods, such as graduation, were delayed due limits in work capacity of the staff available during the fiscal year. Effect: The Seminary was not in compliance with enrollment reporting requirements. Questioned Costs: None. Repeat Finding: Yes, see prior year finding 2024-006. Recommendation: We recommend that the Seminary enhance existing policies to comply with enrollment reporting requirements. This policy should include a method for ensuring both timely enrollment updates as well as accuracy of the data reported. Views of Responsible Officials: See corrective action plan attached.
This Repeat Finding has been acknowledged. Union has taken several steps towards making the required changes to ensure compliance with our enrollment reporting responsibilities. This includes implementing process improvements related to our National Clearing House (NSC) submissions and reviewing our academic policies related to academic leaves of absence and withdrawals. Timeliness of Enrollment Reporting Rosters: As of January 2024, Union completed the setup and configuration of our enrollment reporting services with NSC as our third-party service provider. The new process is administered by the school Registrar, with back-up responsibilities handled by the Assistant Dean, Director of Financial Aid, and the Vice President of Admissions and Views of Responsible Officials: This Repeat Finding has been acknowledged. Union’s Academic Office is in the late stages of implementing a multi-year action plan to implement the required system, policy, and procedural changes to ensure compliance with all enrollment reporting regulations. As of January 2024, Union completed our migration to the National Clearinghouse (NSC) as our third service provider for enrollment reporting services. We have already experienced a strong positive impact on the timeliness of our enrollment reporting. For example, we have fully addressed the timeliness of our NSLDS Roster response, which is due within 15 days. This year’s testing sample yielded zero (0) errors, demonstrating our ability to successfully address enrollment reporting issues. The steps outlined below will allow us to address the enrollment reporting issue identified in this year’s testing sample. Earlier this academic year, Union revised both our Academic Leave of Absence and Term Withdrawal policies to ensure alignment with our compliance obligations. Due to these changes, Union has already noted a reduction in reporting errors and inconsistencies. The FY25 Single Audit finding is related to the reporting of withdrawal/dismissal actions that took place in summer, a non-required term for students in our programs. Our corrective action will be to: (1) further modify our policies and procedures to specifically address non-required and interim terms; and (2) increase the number of batch enrollment updates to NSC/NSLDS during non-required terms to ensure that all summer withdrawals are communicated within 60 days.
2024-006
FAC accepted this audit on February 28, 2025 — management decision was due August 28, 2025.
We noted that four of five Enrollment Reporting Rosters that were selected for testing were not returned within the 15 period as required. In addition, the date of three of five students’ enrollment status changes were not recorded accurately to NSLDS during the year ended June 30, 2024. Cause: Due to turnover in the Seminary’s Registrar department, enrollment reporting during high volume periods such as graduation were delayed due limits in work capacity of the staff available during the fiscal year. Effect: The Seminary was not in compliance with enrollment reporting requirements. Questioned Costs: None. Repeat Finding: Yes, see prior year finding 2023-008. Recommendation: We recommend that the Seminary enhance existing policies to comply with enrollment reporting requirements. This policy should include a method for ensuring both timely enrollment updates as well as accuracy of the data reported. Views of Responsible Officials: See corrective action plan attached.
Show full finding ▾Hide full finding ▴Federal Assistance Listing Number: 84.268 Name of Program or Cluster: Federal Direct Student Loans (Student Financial Aid Cluster) Agency: Department of Education Criteria: Institutions are required to report enrollment information under the Federal Pell Grant and Federal Direct Student Loans programs via the National Student Loan Data System (“NSLDS”). Institutions must complete and return the Enrollment Reporting roster placed in their Student Aid Internet Gateway mailboxes sent by the U.S. Department of Education via NSLDS within 15 days of receipt of the roster. Additionally, institutions are required to report changes in student enrollment status via NSLDS within 60 days. Condition: We noted that four of five Enrollment Reporting Rosters that were selected for testing were not returned within the 15 period as required. In addition, the date of three of five students’ enrollment status changes were not recorded accurately to NSLDS during the year ended June 30, 2024. Cause: Due to turnover in the Seminary’s Registrar department, enrollment reporting during high volume periods such as graduation were delayed due limits in work capacity of the staff available during the fiscal year. Effect: The Seminary was not in compliance with enrollment reporting requirements. Questioned Costs: None. Repeat Finding: Yes, see prior year finding 2023-008. Recommendation: We recommend that the Seminary enhance existing policies to comply with enrollment reporting requirements. This policy should include a method for ensuring both timely enrollment updates as well as accuracy of the data reported. Views of Responsible Officials: See corrective action plan attached.
This Repeat Finding has been acknowledged. Union has taken several steps towards making the required changes to ensure compliance with our enrollment reporting responsibilities. This includes implementing process improvements related to our National Clearing House (NSC) submissions and reviewing our academic policies related to academic leaves of absence and withdrawals. Timeliness of Enrollment Reporting Rosters: As of January 2024, Union completed the set-up and configuration of our enrollment reporting services with NSC as our third-party service provider. The new process is administered by the school Registrar, with back-up responsibilities handled by the Assistant Dean, Director of Financial Aid, and the Vice President of Admissions and Financial Aid. Since implementing the new system, Union has submitted our Enrollment Reporting Roster on a regular and timely basis. Under NSC, our submissions have occurred at least once per month and within the 15-day reporting requirement. As a result, we do not anticipate late reporting of Enrollment Reporting Rosters for FY25 or future periods.. Accuracy of Enrollment Status Changes: In order to further improve the timeliness and accuracy of our enrollment report submissions, we plan to make the following changes to our process with NSC. First, we will schedule additional submissions of our Enrollment Roster at key points during the academic year: (1) prior to the start of each semester, (2) immediately after the end of the drop-add period, and (3) during our non-required summer term. Second, we will work with NSC on our system configuration and error correction process, to ensure that enrollment status is accurately reported and that all status errors are resolved correctly and in a timely manner. Enrollment Roster transmissions will continue to take place according to a preset schedule. This process includes email communication from NSC the week prior to an enrollment submission, confirmation of a successful submission, and notification of potential errors. Union’s Registrar, who has 17 years of experience, is also working directly with NSLDS to address errors found in past submissions and working with internal stakeholders in the Academic Office, Financial Aid Office, Bursar’s Office, and IT Department to ensure that all student records accurately and correctly configured.
2023-008
FAC accepted this audit on March 28, 2024 — management decision was due September 28, 2024.
We noted that four of five Enrollment Reporting Rosters that were selected for testing were not returned within the 15 period as required. In addition, the date of three of five students’ enrollment status changes were not recorded accurately to NSLDS during the year ended June 30, 2023. Cause: Due to turnover in the Seminary’s Registrar department, enrollment reporting during high volume periods such as graduation were delayed due limits in work capacity of the staff available during the fiscal year. Effect: The Seminary was not in compliance with enrollment reporting requirements. Questioned Costs: None. Repeat Finding: Yes, see prior year finding 2022-009.Recommendation: We recommend that the Seminary enhance existing policies to comply with enrollment reporting requirements. This policy should include a method for ensuring both timely enrollment updates as well as accuracy of the data reported. Views of Responsible Officials: See corrective action plan attached.
Show full finding ▾Hide full finding ▴Federal Assistance Listing Number: 84.268 Name of Program or Cluster: Federal Direct Student Loans (Student Financial Aid Cluster) Agency: Department of Education Criteria: Institutions are required to report enrollment information under the Federal Pell Grant and Federal Direct Student Loans programs via the National Student Loan Data System (“NSLDS”). Institutions must complete and return the Enrollment Reporting roster placed in their Student Aid Internet Gateway mailboxes sent by the U.S. Department of Education via NSLDS within 15 days of receipt of the roster. Additionally, institutions are required to report changes in student enrollment status via NSLDS within 60 days. Condition: We noted that four of five Enrollment Reporting Rosters that were selected for testing were not returned within the 15 period as required. In addition, the date of three of five students’ enrollment status changes were not recorded accurately to NSLDS during the year ended June 30, 2023. Cause: Due to turnover in the Seminary’s Registrar department, enrollment reporting during high volume periods such as graduation were delayed due limits in work capacity of the staff available during the fiscal year. Effect: The Seminary was not in compliance with enrollment reporting requirements. Questioned Costs: None. Repeat Finding: Yes, see prior year finding 2022-009.Recommendation: We recommend that the Seminary enhance existing policies to comply with enrollment reporting requirements. This policy should include a method for ensuring both timely enrollment updates as well as accuracy of the data reported. Views of Responsible Officials: See corrective action plan attached.
This Repeat Finding has been acknowledged. Union has completed its implementation of our Corrective Action Plan for this item, which involved entering into a Master Service Agreement with the National Student Clearinghouse (NSC) to perform enrollment and educational financial industry reporting, as well as education verification and authentication services. National Clearinghouse is the leading provider of educational reporting and data exchange, reporting on 97% of post-secondary student enrollments in the US. Union will be using a secure FTP process to send our enrollment data to NSC for timeline and consistent reporting to the National Student Loan Data System (NSLDS). As of January 2024, Union has completed the set-up and configuration of the new services. The new system will be managed by the school Registrar, with back-up responsibilities handled by the Assistant Dean, Director of Financial Aid, and the Vice President of Admissions and Financial Aid. This back-up involves both the Academic and Financial Aid offices in order to improve our ability to address issues brought about by staff absences and/or turnover. UTS has completed enrollment reporting submissions via the NSC master service agreement on 12/20/23, 1/10/24, 2/05/24, 2/20/24 and 3/10.24 . Subsequent transmissions will continue to take place according to a pre-set schedule. This process includes email communication from NSC the week prior to an enrollment submission, confirmation of a successful submission and notification of potential errors. Union’s new Registrar, who has 17 years of experience, is also working directly with NSLDS to address errors found in past submissions and working with internal stakeholders in the Academic Office, Financial Aid Office, Bursar’s Office and IT Department to ensure that all student records accurately and correctly configured.
2022-009
FAC accepted this audit on December 11, 2023 — management decision was due June 11, 2024.
We noted that three of five Enrollment Reporting Rosters that were selected for testing were not returned within the 15 day period as required. In addition, the date of two of five students’ enrollment status changes were not recorded accurately to NSLDS during the year ended June 30, 2022. Cause: Due to turnover in the Seminary’s Registrar department, enrollment reporting during high volume periods, such as graduation, were delayed due limits in work capacity of the staff available during the fiscal year. Effect: The Seminary was not in compliance with enrollment reporting requirements. Questioned Costs: None. Repeat Finding: Yes, see prior year finding 2021-008.Recommendation: We recommend that the Seminary enhance existing policies to comply with enrollment reporting requirements. This policy should include a method for ensuring both timely enrollment updates as well as accuracy of the data reported. Views of Responsible Officials: See corrective action plan attached.
Show full finding ▾Hide full finding ▴Federal Assistance Listing Number: 84.268 Name of Program or Cluster: Federal Direct Student Loans (Student Financial Aid Cluster) Agency: Department of Education Criteria: Institutions are required to report enrollment information under the Federal Pell Grant and Federal Direct Student Loans programs via the National Student Loan Data System (“NSLDS”). Institutions must complete and return the Enrollment Reporting roster placed in their Student Aid Internet Gateway mailboxes sent by the U.S. Department of Education via NSLDS within 15 days of receipt of the roster. Condition: We noted that three of five Enrollment Reporting Rosters that were selected for testing were not returned within the 15 day period as required. In addition, the date of two of five students’ enrollment status changes were not recorded accurately to NSLDS during the year ended June 30, 2022. Cause: Due to turnover in the Seminary’s Registrar department, enrollment reporting during high volume periods, such as graduation, were delayed due limits in work capacity of the staff available during the fiscal year. Effect: The Seminary was not in compliance with enrollment reporting requirements. Questioned Costs: None. Repeat Finding: Yes, see prior year finding 2021-008.Recommendation: We recommend that the Seminary enhance existing policies to comply with enrollment reporting requirements. This policy should include a method for ensuring both timely enrollment updates as well as accuracy of the data reported. Views of Responsible Officials: See corrective action plan attached.
This Repeat Finding has been acknowledged and corrective action is already in the process of being implemented. In November 2022, Union signed a Master Service Agreement with the National Student Clearinghouse (NSC) to perform enrollment and educational financial industry reporting, as well as education verification and authentication services. National Clearinghouse is the leading provider of educational reporting and data exchange, reporting on 97% of post-secondary student enrollments in the US. Union will be using a secure FTP process to send our enrollment data to NSC for timely and consistent reporting to the National Student Loan Data System (NSLDS). This Spring, Union completed the initial portion of the implementation by uploading a base set of enrollment data to NSC using Spring 2023 enrollment information. This was followed by one round of data clean-up. A second set of enrollment data was transmitted in December 2023. The Registrar and Financial Aid Director have been provided direct access to both NSC and NSLDS. As a backup, the Associate Dean of Academic Administration and Vice President of Admissions and Financial Aid have been granted NSC login credentials in order to ensure continuity of reporting in case of employee absence. The Registrar’s Office plans to begin regular monthly uploads of enrollment data to NSC beginning January 2024.
2021-008
FAC accepted this audit on September 29, 2022 — management decision was due March 29, 2023.
We noted that one of four Enrollment Reporting Rosters that were selected for testing were not returned within the 15 period as required. In addition, management was unable to provide a complete listing of students with enrollment changes during the year ended June 30, 2021, therefore we were not able to test the accuracy or completeness of enrollment status changes reported to NSLDS. Cause: Due to turnover in the Seminary?s Registrar department, enrollment reporting during high volume periods such as graduation were delayed due limits in work capacity of the staff available during the fiscal year. Effect: The Seminary was not in compliance with enrollment reporting requirements. Questioned Costs: None. Repeat Finding: Yes, see prior year finding 2020-002. Recommendation: We recommend that the Seminary enhance existing policies to comply with enrollment reporting requirements. This policy should include a method for ensuring both timely enrollment updates as well as accuracy of the data reported.
Show full finding ▾Hide full finding ▴2021-008 Special Tests ? Enrollment Reporting Federal Assistance Listing Number: 84.268 Name of Program or Cluster: Federal Direct Student Loans (Student Financial Aid Cluster) Agency: Department of Education Criteria: Institutions are required to report enrollment information under the Federal Pell Grant and Federal Direct Student Loans programs via the National Student Loan Data System (?NSLDS?). Institutions must complete and return the Enrollment Reporting roster placed in their Student Aid Internet Gateway mailboxes sent by the U.S. Department of Education via NSLDS within 15 days of receipt of the roster. Condition: We noted that one of four Enrollment Reporting Rosters that were selected for testing were not returned within the 15 period as required. In addition, management was unable to provide a complete listing of students with enrollment changes during the year ended June 30, 2021, therefore we were not able to test the accuracy or completeness of enrollment status changes reported to NSLDS. Cause: Due to turnover in the Seminary?s Registrar department, enrollment reporting during high volume periods such as graduation were delayed due limits in work capacity of the staff available during the fiscal year. Effect: The Seminary was not in compliance with enrollment reporting requirements. Questioned Costs: None. Repeat Finding: Yes, see prior year finding 2020-002. Recommendation: We recommend that the Seminary enhance existing policies to comply with enrollment reporting requirements. This policy should include a method for ensuring both timely enrollment updates as well as accuracy of the data reported.
Acknowledged. Enrollment status change reports should include actual enrollment statuses as of the report submission deadline. Any imminent student status enrollment changes like impending graduating actions should be reported at and by the appropriate reporting deadline.
2020-002
Of 22 award disbursements selected for testing, 13 disbursements were made more than 10 days in advance of the first day of classes of the applicable enrollment period. Of the 13 identified disbursements, 3 disbursements are considered to have been made more than 3 days after the receipt of student financial assistance funds. Cause: Funds were disbursed to students early due to management oversight. Effect: All awards were disbursed to student accounts within 3 days of the Seminary?s receipt of funds from the U.S. Department of Education as required. However, due to the disbursement of 13 awards more than 10 days in advance of the first day of classes of the enrollment period, 3 awards were not disbursed within 4 days of the first day of classes for the enrollment period based on U.S. Department of Education requirements. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that student financial assistance award disbursement procedures are adjusted to ensure that disbursements are not made more than 10 days prior to the first day of the applicable enrollment period.
Show full finding ▾Hide full finding ▴2021-009 Disbursements to or on Behalf of Students and Cash Management Federal Assistance Listing Number: 84.268 Name of Program or Cluster: Federal Direct Student Loans (Student Financial Aid Cluster) Agency: Department of Education Criteria: Student financial assistance awards should not be disbursed to student accounts more than 10 days in advance of the first day of classes in the applicable enrollment period. Award disbursements made more than 10 days before the first day of classes in the enrollment period are considered by the U.S. Department of Education to have been disbursed 10 days before the first day of classes in the enrollment period. Student financial assistance funds must be disbursed to student accounts within 3 days of receipt of funds. Condition: Of 22 award disbursements selected for testing, 13 disbursements were made more than 10 days in advance of the first day of classes of the applicable enrollment period. Of the 13 identified disbursements, 3 disbursements are considered to have been made more than 3 days after the receipt of student financial assistance funds. Cause: Funds were disbursed to students early due to management oversight. Effect: All awards were disbursed to student accounts within 3 days of the Seminary?s receipt of funds from the U.S. Department of Education as required. However, due to the disbursement of 13 awards more than 10 days in advance of the first day of classes of the enrollment period, 3 awards were not disbursed within 4 days of the first day of classes for the enrollment period based on U.S. Department of Education requirements. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that student financial assistance award disbursement procedures are adjusted to ensure that disbursements are not made more than 10 days prior to the first day of the applicable enrollment period.
Acknowledged. UTS will adhere to student award disbursement deadlines of no more than 10 days prior to the student's first day of class as well as student financial assistance funds to be disbursed within 3 days of UTS' receipt of funds.
FAC accepted this audit on September 29, 2021 — management decision was due March 29, 2022.
We noted that the Seminary did not have a formalized policy to perform a risk assessment that addresses the required areas noted in 16 CFR 314.4 (b). Cause: Management has not implemented formal written policies or documented their risk assessments to comply with the Program Participation Agreement and Gramm-Leach-Bliley Act. Effect: The Seminary is not in compliance with the Seminary?s Program Participation Agreement and the Gramm-Leach-Bliley Act. Questioned Costs: None. Repeat Finding: Yes, see prior year finding 2019-001. Section III ? Federal Award Findings and Questioned Costs (continued) 2020-001 Special Tests ? Gramm-Leach-Bliley Act (continued) Recommendation: We recommend that the Seminary develop and implement policies and procedures to monitor compliance with the Gramm-Leach-Bliley Act as well as take appropriate measures to comply with the Seminary?s Program Participation Agreement and the Gramm-Leach-Bliley Act. Views of Responsible Officials: See Corrective Action Plan attached.
Show full finding ▾Hide full finding ▴2020-001 Special Tests ? Gramm-Leach-Bliley Act CFDA Number: 84.268 / 84.038 / 84.033 Name of Program or Cluster: Student Financial Aid Cluster Agency: Department of Education Criteria: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. Under an institution?s Program Participation Agreement with the U.S. Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the U.S. Department of Education or otherwise obtained in support of the administration of federal student financial aid programs. Institutions are required to perform a risk assessment that addresses the three required areas noted in 16 CFR 314.4 (b), which are (1) employee training and management; (2) information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures. In addition, for all risks identified, the Seminary must address each risk with a documented safeguard. Condition: We noted that the Seminary did not have a formalized policy to perform a risk assessment that addresses the required areas noted in 16 CFR 314.4 (b). Cause: Management has not implemented formal written policies or documented their risk assessments to comply with the Program Participation Agreement and Gramm-Leach-Bliley Act. Effect: The Seminary is not in compliance with the Seminary?s Program Participation Agreement and the Gramm-Leach-Bliley Act. Questioned Costs: None. Repeat Finding: Yes, see prior year finding 2019-001. Section III ? Federal Award Findings and Questioned Costs (continued) 2020-001 Special Tests ? Gramm-Leach-Bliley Act (continued) Recommendation: We recommend that the Seminary develop and implement policies and procedures to monitor compliance with the Gramm-Leach-Bliley Act as well as take appropriate measures to comply with the Seminary?s Program Participation Agreement and the Gramm-Leach-Bliley Act. Views of Responsible Officials: See Corrective Action Plan attached.
On May 7, 2021, an outside consulting firm completed a GLBA risk assessment with UTS. The school carefully reviewed the findings for improvement actions. We are committed to developing an IT strategic plan as part of our FY 2023 budget development. The plan includes hardware and software migrations; process improvements needed to strengthen our IT management and security; and periodic reviews and reassessments of our data security and GLBA practices. UTS is also are re-introducing periodic FERPA/data security training as part of our post-COVID back to campus practice.
2019-001
2020-002 Special Tests ? Enrollment Reporting CFDA Number: 84.268 Name of Program or Cluster: Federal Direct Student Loans (Student Financial Aid Cluster) Agency: Department of Education Criteria: Institutions are required to report enrollment information under the Federal Pell Grant Program and Federal Direct Student Loans via the National Student Loan Data System (?NSLDS?). Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by the U.S. Department of Education via NSLDS. In addition, institutions are required to report student enrollment changes within 30 days of the change in enrollment, unless the institution expects to submit its next enrollment report to the U.S. Department of Education within the next 60 days. Condition/Context: We noted that one of four Enrollment Reporting Rosters were not returned within the 15 period as required. In addition, we noted two of four student enrollment status updates were not reported within 30 days, and one of four student enrollment status updates were not accurately reported. These submissions were inaccurate and/or delayed due to staffing constraints which resulted in a delay in the performance of enrollment reporting procedures. Cause: Due to a vacancy in the Registrar position through December 2019, one individual performed the duties of both the Registrar position, as well as that of Assistant Dean for Academic Administration. As a result, periodic delays occurred in enrollment reporting processes. Effect: The Seminary is not in compliance with enrollment reporting requirements. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that the Seminary enhance existing policies to comply with enrollment reporting requirements. This policy should include a method for ensuring both timely enrollment updates as well as accuracy of the data reported. Views of Responsible Officials: See Corrective Action Plan attached.
Show full finding ▾Hide full finding ▴2020-002 Special Tests ? Enrollment Reporting CFDA Number: 84.268 Name of Program or Cluster: Federal Direct Student Loans (Student Financial Aid Cluster) Agency: Department of Education Criteria: Institutions are required to report enrollment information under the Federal Pell Grant Program and Federal Direct Student Loans via the National Student Loan Data System (?NSLDS?). Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by the U.S. Department of Education via NSLDS. In addition, institutions are required to report student enrollment changes within 30 days of the change in enrollment, unless the institution expects to submit its next enrollment report to the U.S. Department of Education within the next 60 days. Condition/Context: We noted that one of four Enrollment Reporting Rosters were not returned within the 15 period as required. In addition, we noted two of four student enrollment status updates were not reported within 30 days, and one of four student enrollment status updates were not accurately reported. These submissions were inaccurate and/or delayed due to staffing constraints which resulted in a delay in the performance of enrollment reporting procedures. Cause: Due to a vacancy in the Registrar position through December 2019, one individual performed the duties of both the Registrar position, as well as that of Assistant Dean for Academic Administration. As a result, periodic delays occurred in enrollment reporting processes. Effect: The Seminary is not in compliance with enrollment reporting requirements. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that the Seminary enhance existing policies to comply with enrollment reporting requirements. This policy should include a method for ensuring both timely enrollment updates as well as accuracy of the data reported. Views of Responsible Officials: See Corrective Action Plan attached.
The Registrar and Assistant Dean acknowledge the late submissions and emphasize a vacancy in the Registrar?s office during the Fall 2019 semester when the inaccuracies were reported. The office is committed to implementing usage of the National Student Clearinghouse (NSC) for enrollment reporting to the NSLDS. This allows for a more systematic approach of date submissions related to enrollment reporting, and also allows for timely, proper and accurate reporting consistent with what is expected in enrollment updates and changes.?
FAC accepted this audit on June 15, 2020 — management decision was due December 15, 2020.
Criteria: The Gramm-Leach-Bliley Act requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department of Education or otherwise obtained in support of the administration of federal student financial aid programs. Condition/Context: We noted that the Seminary did not have a formal written policy or perform the required risk assessments to address student information security. Cause: Management has not implemented formal written policies or documented their risk assessments to comply with the Program Participation Agreement and Gramm-Leach-Bliley Act. Effect: The Seminary is not in compliance with the Seminary?s Program Participation Agreement and the Gramm-Leach-Bliley Act. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that the Seminary develop and implement a policy to comply with the Seminary?s Program Participation Agreement and the Gramm-Leach-Bliley Act. Views of Responsible Officials: See Corrective Action Plan attached.
Show full finding ▾Hide full finding ▴Criteria: The Gramm-Leach-Bliley Act requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department of Education or otherwise obtained in support of the administration of federal student financial aid programs. Condition/Context: We noted that the Seminary did not have a formal written policy or perform the required risk assessments to address student information security. Cause: Management has not implemented formal written policies or documented their risk assessments to comply with the Program Participation Agreement and Gramm-Leach-Bliley Act. Effect: The Seminary is not in compliance with the Seminary?s Program Participation Agreement and the Gramm-Leach-Bliley Act. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that the Seminary develop and implement a policy to comply with the Seminary?s Program Participation Agreement and the Gramm-Leach-Bliley Act. Views of Responsible Officials: See Corrective Action Plan attached.
The Seminary does have protections and protocols in place to safeguard sensitive student data, but has not fully documented its data security policies. Management will perform a full risk assessment on student information security by October 31, 2020 and will update and document all data security policies by February 28, 2021.
FAC accepted this audit on March 28, 2019 — management decision was due September 28, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on March 28, 2018 — management decision was due September 28, 2018.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2016-001
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2016-002
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on March 29, 2017 — management decision was due September 29, 2017.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2015-001
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2015-002
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
Browse other Single Audit organizations in New York →
Track your findings and corrective action plans across audit cycles.
Start tracking findings →Monitor subrecipient audit findings and filing records.
Start monitoring →© 2026 Single Audit Intelligence. All data is public domain.
