EIN: 141713034
UEI: PCWWUCWEV363
Audited by: BST & Co. CPAs, LLP
Oversight agency: 84 [Department of Education]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 15, 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 15, 2026 (75 days ago).
What is a management decision? →FAC accepted this audit on March 31, 2025 — management decision was due October 1, 2025.
FAC accepted this audit on February 5, 2024 — management decision was due August 5, 2024.
The College did not prepare a SEFA that was accurate and complete in accordance with the Uniform Guidance, as there was one program missing from the original SEFA that was provided for audit along with five items that were missing Assistance Listing numbers. Cause: The cause is likely due to limited internal controls related to the preparation and review of the SEFA and understanding of which items should be included. Effect or potential effect: Without adequate internal controls over the SEFA, the College may not identify all the federal awards received and related compliance and reporting requirements applicable to each award. Identification as a repeat finding, if applicable: This is a repeat of finding 2022-003 in the prior year. Recommendations: The College must assign individuals who are experienced and knowledgeable in the compliance requirements of the Uniform Guidance to monitor all federal grants received to ensure the College has met the applicable compliance and reporting requirements of each federal award. View of responsible officials: Refer to the Corrective Action Plan prepared by the College on page 12.
Show full finding ▾Hide full finding ▴2023-001: Accurate and Complete Schedule of Expenditures of Federal Awards Criteria or specific requirement: The College must prepare a Schedule of Expenditures of Federal Awards (SEFA) that is accurate and complete in accordance with Title 2 U.S. Code of Federal Regulation Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Condition: The College did not prepare a SEFA that was accurate and complete in accordance with the Uniform Guidance, as there was one program missing from the original SEFA that was provided for audit along with five items that were missing Assistance Listing numbers. Cause: The cause is likely due to limited internal controls related to the preparation and review of the SEFA and understanding of which items should be included. Effect or potential effect: Without adequate internal controls over the SEFA, the College may not identify all the federal awards received and related compliance and reporting requirements applicable to each award. Identification as a repeat finding, if applicable: This is a repeat of finding 2022-003 in the prior year. Recommendations: The College must assign individuals who are experienced and knowledgeable in the compliance requirements of the Uniform Guidance to monitor all federal grants received to ensure the College has met the applicable compliance and reporting requirements of each federal award. View of responsible officials: Refer to the Corrective Action Plan prepared by the College on page 12.
Bard College’s SEFA incorporates financial transactions initiated through various departments. Going forward, a SEFA review committee will be established representing the Financial Aid, Development, Grants Finance and Finance Departments to ensure proper reporting of expended federal funds. Laura Ramsey, Controller is responsible for this corrective action plan, which will be completed during the year ending June 30, 2024.
2022-003
FAC accepted this audit on March 14, 2023 — management decision was due September 14, 2023.
The College did not prepare a SEFA that was accurate and complete in accordance with the Uniform Guidance as there were two programs missing from the original SEFA that was provided for audit. In addition, the federal expenditures for the Higher Education Emergency Relief Fund were not accurate. Cause: The cause is likely due to limited internal controls related to the preparation and review of the SEFA and understanding of which items should be included. Effect or potential effect: Without adequate internal controls over the SEFA, the College may not identify all the federal awards received and related compliance and reporting requirements applicable to each award. Recommendations: The College must assign individuals who are experienced and knowledgeable in the compliance requirements of the Uniform Guidance to monitor all federal grants received to ensure the College has met the applicable compliance and reporting requirements of each federal award.
Show full finding ▾Hide full finding ▴Criteria or specific requirement: The College must prepare a Schedule of Expenditures of Federal Awards (SEFA) that is accurate and complete in accordance with Title 2 U.S. Code of Federal Regulation Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Condition: The College did not prepare a SEFA that was accurate and complete in accordance with the Uniform Guidance as there were two programs missing from the original SEFA that was provided for audit. In addition, the federal expenditures for the Higher Education Emergency Relief Fund were not accurate. Cause: The cause is likely due to limited internal controls related to the preparation and review of the SEFA and understanding of which items should be included. Effect or potential effect: Without adequate internal controls over the SEFA, the College may not identify all the federal awards received and related compliance and reporting requirements applicable to each award. Recommendations: The College must assign individuals who are experienced and knowledgeable in the compliance requirements of the Uniform Guidance to monitor all federal grants received to ensure the College has met the applicable compliance and reporting requirements of each federal award.
Bard College?s SEFA incorporates financial transactions initiated through various departments. Going forward, a SEFA review committee will be established representing the Financial Aid, Development, Grants Finance and Finance Departments to ensure proper reporting of expended federal funds. Laura Ramsey, Controller is responsible for this corrective action plan, which will be completed during the year ending June 30, 2023.
FAC accepted this audit on December 9, 2021 — management decision was due June 9, 2022.
Simon?s Rock did not post the required reporting forms for the institutional portion of HEERF on their website, as required. Cause: Simon?s Rock did not have any staff solely working on grant compliance to assist in understanding the requirements, leading to Simon?s Rock unfamiliarity of the reporting requirement. The HEERF program was new during the year ended June 30, 2020 and has had multiple revisions and updates since its introduction. Effect or potential effect: The effect of missing data from the website results in a lack of transparency over the College?s spending of federal grants. Sample Size: 4 reports missing for the quarters ended: ? September 30, 2020 ? December 30, 2020 ? March 31, 2021 ? June 30, 2021 Recommendations: Simon?s Rock officials should ensure that Institutional Portion reports are retroactively uploaded to the website going back to the beginning of the grant?s period of performance, and future forms are uploaded to the website within 10 days of the end of each quarter. Simon?s Rock should ensure finance and administration staff have a thorough understanding of all requirements for grant reporting. The College should implement controls at all locations to ensure grant reporting requirements are met. View of responsible officials: Refer to the Corrective Action Plan prepared by the College on page 13.
Show full finding ▾Hide full finding ▴2021-002: Public Reporting Requirement For Institutional Portion Of The Higher Education Emergency Relief Fund Criteria or specific requirement: The form that is used for reporting the institutional portion of the Higher Education Emergency Relief Fund (HEERF) awards must be conspicuously posted on the institution?s primary website within 10 days after the end of each calendar quarter. Condition: Simon?s Rock did not post the required reporting forms for the institutional portion of HEERF on their website, as required. Cause: Simon?s Rock did not have any staff solely working on grant compliance to assist in understanding the requirements, leading to Simon?s Rock unfamiliarity of the reporting requirement. The HEERF program was new during the year ended June 30, 2020 and has had multiple revisions and updates since its introduction. Effect or potential effect: The effect of missing data from the website results in a lack of transparency over the College?s spending of federal grants. Sample Size: 4 reports missing for the quarters ended: ? September 30, 2020 ? December 30, 2020 ? March 31, 2021 ? June 30, 2021 Recommendations: Simon?s Rock officials should ensure that Institutional Portion reports are retroactively uploaded to the website going back to the beginning of the grant?s period of performance, and future forms are uploaded to the website within 10 days of the end of each quarter. Simon?s Rock should ensure finance and administration staff have a thorough understanding of all requirements for grant reporting. The College should implement controls at all locations to ensure grant reporting requirements are met. View of responsible officials: Refer to the Corrective Action Plan prepared by the College on page 13.
This finding was specific to Bard?s small Simon?s Rock campus, which has since completed all missing reports. The Bard Annandale campus and Simon?s Rock campus are in contact regarding reporting requirements and upcoming deadlines. It is anticipated that June 30, 2022 will be the final year of HEERF funding, and all reporting will be completed within the ascribed deadlines. Laura Ramsey, Controller is responsible for this corrective action plan, which will be completed during the year ending June 30, 2022.
Such documentation related to lost revenue was not formally maintained by Bard College or Simon?s Rock. Cause: The HEERF program was new in 2020 and has had multiple modifications since its introduction. This likely led to the College?s unfamiliarity with the requirement. Effect or potential effect: The effect of not having supporting documentation for the Institutional Portion of HEERF is a lack of transparency over the College?s spending of federal grants. Recommendations: The College should ensure finance and administration staff have a thorough understanding of all requirements for grant reporting. The College should implement controls at all locations to ensure grant reporting requirements are met. College officials should ensure appropriate supporting documentation is kept for all federal grant drawdowns, including lost revenues. Such documentation has been subsequently prepared and maintained. View of responsible officials: Refer to the Corrective Action Plan prepared by the College on page 13.
Show full finding ▾Hide full finding ▴2021-003: Support for Institutional Portion of the Higher Education Emergency Relief Criteria or specific requirement: An institution must adequately document its estimate of lost revenue, including its rationale, calculations, methodology, underlying data, and budgets or projections used to determine the amount of lost revenue. Condition: Such documentation related to lost revenue was not formally maintained by Bard College or Simon?s Rock. Cause: The HEERF program was new in 2020 and has had multiple modifications since its introduction. This likely led to the College?s unfamiliarity with the requirement. Effect or potential effect: The effect of not having supporting documentation for the Institutional Portion of HEERF is a lack of transparency over the College?s spending of federal grants. Recommendations: The College should ensure finance and administration staff have a thorough understanding of all requirements for grant reporting. The College should implement controls at all locations to ensure grant reporting requirements are met. College officials should ensure appropriate supporting documentation is kept for all federal grant drawdowns, including lost revenues. Such documentation has been subsequently prepared and maintained. View of responsible officials: Refer to the Corrective Action Plan prepared by the College on page 13.
Staff of the College are continually attending professional development and webinar updates on all federal funds. Especially for HEERF monies, which have had a great deal of changing guidance, staff attends update webinars as they come out regarding changes in the program and reporting requirements. We maintain all documentation on student portion distributions and now keep necessary support for Institutional portion use as well. Information is shared between the Bard Annandale campus and Simon?s Rock campus regarding significant changes and upcoming deadlines. It is anticipated that June 30, 2022 will be the final year of HEERF funding, and all reporting will be completed within the ascribed deadlines. Laura Ramsey, Controller is responsible for this corrective action plan, which will be completed during the year ending June 30, 2022.
FAC accepted this audit on March 3, 2021 — management decision was due September 3, 2021.
FAC accepted this audit on February 10, 2020 — management decision was due August 10, 2020.
FAC accepted this audit on March 1, 2019 — management decision was due September 1, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on March 13, 2018 — management decision was due September 13, 2018.
FAC accepted this audit on March 1, 2017 — management decision was due September 1, 2017.
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