EIN: 160743040
UEI: V66KTME156Z3
Audited by: BONADIO & CO. 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 March 30, 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 30, 2026 (31 days from today).
What is a management decision? →FAC accepted this audit on March 27, 2025 — management decision was due September 27, 2025.
Finding 2024-001 U.S. Department of Education Assistance Listing Numbers 84.063 Timely Return of Title IV Funds Condition- During the audit, it was identified that for two out of three students selected for testing did not have their funds returned to the federal government within the required timeframe. Criteria- Per federal regulations, institutions are required to return Title IV funds within 45 days of a student’s withdrawal. Cause- The delay in returning funds was caused by a lack of adequate resources in the Student Financial Aid Department, leading to insufficient capacity to process withdrawals and returns in a timely manner. Effect- The Colleges did not return Title IV Funds within the required timeframe which could impact the Colleges’ ability to drawdown Pell and Direct Loans. Recommendation- We recommend that the Colleges assess and address staffing levels in the Student Financial Aid Department to ensure adequate resources are available to process Title IV fund returns timely. Additionally, the Colleges should develop policies and procedures to ensure timely processing of returns within the required 45-day period. Management Response – Additional staffing has been put in place to ensure that we have enough resources to complete title IV refund processing in a timely fashion. A new assistant director (hired in November 2024) will be monitoring the notifications that students have withdrawn and notify the director when title IV refunds are required. The new assistant director is also currently being trained in title IV refund processing and has experience with title IV refunding prior to being hired. The associate director (hired in July 2024) is also an expert in the return of federal funding through EDCONNECT and perform a supportive role in this process.
Show full finding ▾Hide full finding ▴Finding 2024-001 U.S. Department of Education Assistance Listing Numbers 84.063 Timely Return of Title IV Funds Condition- During the audit, it was identified that for two out of three students selected for testing did not have their funds returned to the federal government within the required timeframe. Criteria- Per federal regulations, institutions are required to return Title IV funds within 45 days of a student’s withdrawal. Cause- The delay in returning funds was caused by a lack of adequate resources in the Student Financial Aid Department, leading to insufficient capacity to process withdrawals and returns in a timely manner. Effect- The Colleges did not return Title IV Funds within the required timeframe which could impact the Colleges’ ability to drawdown Pell and Direct Loans. Recommendation- We recommend that the Colleges assess and address staffing levels in the Student Financial Aid Department to ensure adequate resources are available to process Title IV fund returns timely. Additionally, the Colleges should develop policies and procedures to ensure timely processing of returns within the required 45-day period. Management Response – Additional staffing has been put in place to ensure that we have enough resources to complete title IV refund processing in a timely fashion. A new assistant director (hired in November 2024) will be monitoring the notifications that students have withdrawn and notify the director when title IV refunds are required. The new assistant director is also currently being trained in title IV refund processing and has experience with title IV refunding prior to being hired. The associate director (hired in July 2024) is also an expert in the return of federal funding through EDCONNECT and perform a supportive role in this process.
CORRECTIVE ACTION PLAN U.S. Department Education Hobart and William Smith Colleges respectfully submit the following corrective action plan for the year ended June 30, 2024 Name and address of independent public accounting firm: Bonadio & Co., LLP 171 Sully's Trail Pittsford, NY 14534 Audit period: July 1, 2023 - June 30, 2024 The findings from the 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAMS SIGNIFICANT DEFICIENCY 2024-001 Timely Return of Title IV Funds Recommendation: We recommend that the Colleges assess and address staffing levels in the Student Financial Aid Department to ensure adequate resources are available to process Title IV fund returns timely. Additionally, the Colleges should develop policies and procedures to ensure timely processing of returns within the required 45-day period. Corrective Action Plan: Additional staffing has been put in place to ensure that we have enough resources to complete title IV refund processing in a timely fashion. A new assistant director (hired in November 2024) will be monitoring the notifications that students have withdrawn and notify the director when title IV refunds are required. The new assistant director is also currently being trained in title IV refund processing and has experience with title IV refunding prior to being hired. The associate director (hired in July 2024) is also an expert in the return of federal funding through EDCONNECT and perform a supportive role in this process. Lisa Hoskey, Director of Financial Aid, is responsible for implementing this plan and can be reached at Hoskey@hws.edu.
FAC accepted this audit on March 6, 2024 — management decision was due September 6, 2024.
FAC accepted this audit on February 27, 2023 — management decision was due August 27, 2023.
FAC accepted this audit on December 16, 2021 — management decision was due June 16, 2022.
Finding 2021-002 - 84.268, 84.063, 84.033, 84.007 Student Financial Aid Cluster Federal Agency - U.S. Department of Education Grant Period ? Year ended May 31, 2021 Criteria - Institutions participating in Title IV programs are required to comply with various laws and regulations as part of their signed Program Participation Agreement (PPA), including but not limited to, the Federal Trade Commission?s Gramm-Leach-Bliley Act GLBA) Safeguards Rule (Title 16, Chapter I, Subchapter C, Part 314). Condition - The Colleges have not performed a thorough information security risk assessment that includes covering vendors with access to student data and related safeguards. Cause - The Colleges information security program does not include procedures for the performance of formally documented regular risk assessments addressing the Colleges compliance with GLBA. Effect - As the Colleges have not performed an information security risk assessment, it may be unaware of the risks to its sensitive data, specifically datasets protected under GLBA. Recommendation - The Colleges should work to implement a standardized and detailed risk management framework, such as those provided by National Institute of Standards and Technology (NIST). Risk assessment documentation should include detailed information regarding current procedures in place, justifications for scoring, safeguards for each identified risk, and remediation plans.
Show full finding ▾Hide full finding ▴Finding 2021-002 - 84.268, 84.063, 84.033, 84.007 Student Financial Aid Cluster Federal Agency - U.S. Department of Education Grant Period ? Year ended May 31, 2021 Criteria - Institutions participating in Title IV programs are required to comply with various laws and regulations as part of their signed Program Participation Agreement (PPA), including but not limited to, the Federal Trade Commission?s Gramm-Leach-Bliley Act GLBA) Safeguards Rule (Title 16, Chapter I, Subchapter C, Part 314). Condition - The Colleges have not performed a thorough information security risk assessment that includes covering vendors with access to student data and related safeguards. Cause - The Colleges information security program does not include procedures for the performance of formally documented regular risk assessments addressing the Colleges compliance with GLBA. Effect - As the Colleges have not performed an information security risk assessment, it may be unaware of the risks to its sensitive data, specifically datasets protected under GLBA. Recommendation - The Colleges should work to implement a standardized and detailed risk management framework, such as those provided by National Institute of Standards and Technology (NIST). Risk assessment documentation should include detailed information regarding current procedures in place, justifications for scoring, safeguards for each identified risk, and remediation plans.
2021-002 Recommendation: Our auditors recommend that we work to implement a standardized and detailed risk management framework, such as those provided by National Institute of Standards and Technology (NIST). Risk assessment documentation should include detailed information regarding current procedures in place, justifications for scoring, safeguards for each identified risk, and remediation plans. Corrective Action Plan: Management agrees and is working to implement a standardized and detailed risk management framework. Management understands the need for and importance of maintaining formal documentation and will ensure its risk assessment documentation includes detailed information regarding current procedures in place, justifications for scoring, safeguards for each identified risk, and plans for any required remediation. Fred Damiano, Vice President for Strategic Initiatives and Chief Information Officer, is responsible for implementing this plan and can be reached at damiano@hws.edu or (315) 781-3955.
FAC accepted this audit on March 3, 2021 — management decision was due September 3, 2021.
FAC accepted this audit on March 2, 2020 — management decision was due September 2, 2020.
FAC accepted this audit on February 27, 2019 — management decision was due August 27, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on January 16, 2018 — management decision was due July 16, 2018.
FAC accepted this audit on January 22, 2017 — management decision was due July 22, 2017.
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