EIN: 131916574
UEI: W3LCLYPNVBU8
Data as of August 22, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on April 7, 2021. 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 7, 2021 (1780 days ago).
What is a management decision? →Not all of the required language (per 34 CFR 668.25(c) concerning compliance, liability, referrals, disbursements and returns, and repayments of Title IV funds) is included in the executed contract between the College and ECSI. Questioned costs: None Context: The College?s contract with ECSI did not include the language required by 34 CFR 668.25(c). Cause: The College did not have procedures in place to ensure that their contract with ECSI included the language required by 34 CFR 668.25(c). Effect: ECSI?s contract with the College did not include the language required by 34 CFR 668.25(c) concerning compliance, liability, referrals, disbursements and returns, and repayments of Title IV funds. Any finding ECSI receives becomes a finding of the institution they service. Repeat finding: No. Recommendation: When contracting with an institution for performing or providing any relevant Title IV function, the servicer and/or any of its contractors, essentially ?steps into the shoes? of the institution with respect to compliance with the requirements for institutional administration of the Title IV student assistance program activity. The institution must ensure that its contract with any third-party servicer contains the required elements outlined in the regulations at 34 CFR 668.25(c). This can be done through contract review and inquiry of the third-party servicer. Views of responsible officials: See attached corrective action plan.
Show full finding ▾Hide full finding ▴Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster CFDA number: 84.038 Award period: 9/1/19 ? 8/31/20 Type of finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: The College utilizes a third-party service provider, Educational Computer Systems, Inc. (ECSI), to perform certain functions related to the servicing of the College?s Federal Perkins Loan Program. Regulations require that an institution and a third-party service provider shall agree to comply with all requirements of 34 CFR 668.25(c) concerning compliance, liability, referrals, disbursements and returns, and repayments of Title IV funds. 34 CFR 668.25(c) states that in a contract with an institution, a third-party servicer shall agree to: ? Comply with all statutory or regulatory provisions, and special arrangements, agreements, limitations, suspensions, and terminations entered into under Title IV programs; ? Refer to the Office of Inspector General of the U.S. Department of Education for investigation any information indicating there is reasonable cause to believe that: o The institution might have engaged in fraud or other criminal misconduct in connection with the institution?s administration of any Title IV program, or o An applicant for Title IV program assistance might have engaged in fraud or other criminal misconduct in connection with his or her application; ? Be jointly and severally liable with the institution for any violation by the servicer of any statutory or regulatory provisions, and special arrangements, agreements, or limitations entered into under Title IV programs; Condition: Not all of the required language (per 34 CFR 668.25(c) concerning compliance, liability, referrals, disbursements and returns, and repayments of Title IV funds) is included in the executed contract between the College and ECSI. Questioned costs: None Context: The College?s contract with ECSI did not include the language required by 34 CFR 668.25(c). Cause: The College did not have procedures in place to ensure that their contract with ECSI included the language required by 34 CFR 668.25(c). Effect: ECSI?s contract with the College did not include the language required by 34 CFR 668.25(c) concerning compliance, liability, referrals, disbursements and returns, and repayments of Title IV funds. Any finding ECSI receives becomes a finding of the institution they service. Repeat finding: No. Recommendation: When contracting with an institution for performing or providing any relevant Title IV function, the servicer and/or any of its contractors, essentially ?steps into the shoes? of the institution with respect to compliance with the requirements for institutional administration of the Title IV student assistance program activity. The institution must ensure that its contract with any third-party servicer contains the required elements outlined in the regulations at 34 CFR 668.25(c). This can be done through contract review and inquiry of the third-party servicer. Views of responsible officials: See attached corrective action plan.
Department of Education New York Chiropractic College respectfully submits the following corrective action plan for the year ended August 31, 2020. Audit period: September 1, 2019 - August 31, 2020 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT No findings over financial statement audit. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS Department of Education 2020-001 Student Financial Assistance Cluster ? CFDA No. 84.038 Recommendation: We recommend that the College implement a thorough review process of all third-party servicer contracts to make sure they comply with all Department of Education Rules and Regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College executed a contract amendment with its third-party servicer, ECSI, in February 2021 to comply with requirements of 34 CFR 668.25(c). The College will implement a thorough review process of all its third-party servicer contracts to ensure they comply with all Department of Education Rules and Regulations and will review servicer audit reports annually to identify any findings related to the services provided to the College. Name(s) of the contact person(s) responsible for corrective action: Sean Anglim Planned completion date for corrective action plan: April 2021 If the Department of Education has questions regarding this plan, please call Sean Anglim at 315-568-3092.
FAC accepted this audit on December 18, 2016 — management decision was due June 18, 2017.
GSA_MIGRATION
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GSA_MIGRATION
2015-001
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