EIN: 231352613
UEI: P3U1S9SVCB65
Audited by: Baker Tilly US, 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 29, 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 29, 2026 (30 days from today).
What is a management decision? →Federal Program - Federal Direct Student Loan Program, Federal Pell Grant Program Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable Assistance Listing Number – 84.268, 84.063 Award Number - P3U1S9SVCB65, P3U1S9SVCB65 Federal Award Year - June 30, 2025 Criteria: 34 CFR 685.309(b) states that upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary in the manner and format prescribed by the Secretary and within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Condition/Context: For 25 of the 25 students tested, their enrollment status was reported incorrectly and/or not in a timely or accurate manner to the National Student Loan Database System (NSLDS). For seven students that graduated, their change in status was not submitted to the NSLDS. For fourteen students their change in status was not reported within 60 days. For eight students tested NSLDS student status reported did not agree to the institutional record. For eighteen students tested NSLDS effective change in status date did not agree to the institutional record. The sample was not a statistically valid sample. Cause: The University utilizes a third-party servicer to facilitate student enrollment reporting. The third-party servicer report information was not accurate and complete based on the institution records. Third-party servicer submissions were not being transferred to NSLDS on a timely basis. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status and other information, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Questioned Costs: None. Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates and status changes are reported to NSLDS within required time frames, as well as create accurate reports internally to track all students’ whose status changed and verify against the roster submitted to NSLDS. This could include a review of withdrawal or graduation dates compared to the effective dates reported to NSLDS to make sure they are accurate. View of Responsible Officials: The Registrar's Office is working with the National Student Clearinghouse (NSC) administrator to address concerns with submitted reports being updated in NSLDS. Each error was corrected within the system. Going forward, the Registrar's Office is working with its Information Technology group on updated internal reports to track and review the status changes and start dates to ensure they are being accurately reported.
Show full finding ▾Hide full finding ▴Federal Program - Federal Direct Student Loan Program, Federal Pell Grant Program Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable Assistance Listing Number – 84.268, 84.063 Award Number - P3U1S9SVCB65, P3U1S9SVCB65 Federal Award Year - June 30, 2025 Criteria: 34 CFR 685.309(b) states that upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary in the manner and format prescribed by the Secretary and within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Condition/Context: For 25 of the 25 students tested, their enrollment status was reported incorrectly and/or not in a timely or accurate manner to the National Student Loan Database System (NSLDS). For seven students that graduated, their change in status was not submitted to the NSLDS. For fourteen students their change in status was not reported within 60 days. For eight students tested NSLDS student status reported did not agree to the institutional record. For eighteen students tested NSLDS effective change in status date did not agree to the institutional record. The sample was not a statistically valid sample. Cause: The University utilizes a third-party servicer to facilitate student enrollment reporting. The third-party servicer report information was not accurate and complete based on the institution records. Third-party servicer submissions were not being transferred to NSLDS on a timely basis. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by the schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status and other information, then the Title IV student loan records will be inaccurate, which impacts student loan repayments. Questioned Costs: None. Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates and status changes are reported to NSLDS within required time frames, as well as create accurate reports internally to track all students’ whose status changed and verify against the roster submitted to NSLDS. This could include a review of withdrawal or graduation dates compared to the effective dates reported to NSLDS to make sure they are accurate. View of Responsible Officials: The Registrar's Office is working with the National Student Clearinghouse (NSC) administrator to address concerns with submitted reports being updated in NSLDS. Each error was corrected within the system. Going forward, the Registrar's Office is working with its Information Technology group on updated internal reports to track and review the status changes and start dates to ensure they are being accurately reported.
Action Taken: The Registrar's Office is working with the NSC administrator to address concerns with submitted reports being updated in NSLDS. Each error was corrected within the system. Going forward, the Registrar's Office is working with IT on updated internal reports to track and review the status changes and start dates to ensure they are being accurately reported. Responsible Individual for Corrective Action: Registrar - Jennifer Melon Anticipated Completion Date: June 30, 2026 If there are any questions regarding this corrective action plan, please call Jennifer Ginnetti, Sr. Associate VP/ Deputy CFO, at 215-641-5506 or email Ginnetti.j@gmercyu.edu.
FAC accepted this audit on March 18, 2025 — management decision was due September 18, 2025.
FAC accepted this audit on March 14, 2024 — management decision was due September 14, 2024.
For one of the twenty-five students tested, their effective date of status change at the campus level did not agree to that at the program level. For three of the twenty-five students tested, the effective date of the status change at both the campus and program levels did not match the date in which the University determined that their status changed. Cause: For one student, the registrar mistakenly entered the wrong date within their system, which was then transferred to NSLDS at the campus level. This date did not match that at the program level, which was correctly reported. For three of the twenty-five students tested, these students changed status between terms, in which case the effective date of their status change should have been reported as the first day of the semester with the status change, in line with University policy. However, the Registrar erroneously reported a different effective date, which in each case was within two weeks of the date that should have been reported, but ultimately did not match the date exactly. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned Costs: None. Recommendation: It is recommended that the University review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Management Response: Each error was corrected within the system. Going forward, the reports submitted to NSLDS will be closely reviewed to ensure effective dates for student changes are appropriately reported.
Show full finding ▾Hide full finding ▴Finding 2023-001: Enrollment Reporting - Significant Deficiency ALN: 84.268 Federal Direct Loan Program Award Year: July 1, 2022 - June 30, 2023 Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: For one of the twenty-five students tested, their effective date of status change at the campus level did not agree to that at the program level. For three of the twenty-five students tested, the effective date of the status change at both the campus and program levels did not match the date in which the University determined that their status changed. Cause: For one student, the registrar mistakenly entered the wrong date within their system, which was then transferred to NSLDS at the campus level. This date did not match that at the program level, which was correctly reported. For three of the twenty-five students tested, these students changed status between terms, in which case the effective date of their status change should have been reported as the first day of the semester with the status change, in line with University policy. However, the Registrar erroneously reported a different effective date, which in each case was within two weeks of the date that should have been reported, but ultimately did not match the date exactly. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned Costs: None. Recommendation: It is recommended that the University review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Management Response: Each error was corrected within the system. Going forward, the reports submitted to NSLDS will be closely reviewed to ensure effective dates for student changes are appropriately reported.
Finding 2023-001- Enrollment Reporting Recommendation: It is recommended that the University review policies and procedures in place to resolve reporting issues in a timely manner to facilitate compliance with Title IV regulations. Action Taken: Each error was corrected within the system. Going forward, the reports submitted to NSLDS will be closely reviewed to ensure effective dates for student changes are appropriately reported. In addition, the registrar has updated their process notes which are used each time they pull the report. Responsible Individual for Corrective Action: Registrar - Joanna Raudenbush Anticipated Completion Date: December 31, 2023
FAC accepted this audit on March 28, 2023 — management decision was due September 28, 2023.
The University has not performed a risk assessments to address (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 and document safeguards for identified risks as required by the Gramm-Leach Bliley Act (GLBA). In addition, the University has not documented safeguards for identified risks. Cause: The University did not have an updated security assessment completed during the year to address procedures and processes in place specific to GLBA and therefore, did not document the required risk assessment or risk mitigation. Effect: With no updated policies and procedures surrounding student information security, the University may be susceptible to threats of consumer nonpublic personal information. Failure to comply with GLBA standards may bring penalties ranging from monetary fines to restriction or loss of eligibility for Title IV funding. Questioned Costs: None. Recommendation: The University should perform and document an annual risk assessment to determine the University's specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the University should have at least one risk statement aligned or referenced to each of the three required areas noted in the GLBA law at 16 CFR 314.4 (b). Finally, the University should identify and document at least one safeguard (i.e., control) for each of the risks identified and document in the risk assessment. Each control should be aligned or referenced to the risk(s) to which the safeguard applies. Management Response: While a specific GLBA audit has not been performed, the University does have a well-developed document titled "Institutional Policies for Safety, Security and Technology" which was released in September 2020. There are policies and procedures within that indirectly address the requirements of GLBA. The Chief Information Officer (CIO) position was transitioned in 2022 and the new CIO noted that the University had not engaged with any new vendor to produce a Security Assessment Report during fiscal year 2022. The University has since engaged with the Cybersecurity and Infrastructure Agency (CISA) to perform vulnerability scanning and penetration testing reporting, so they now have operational security assessment reports from CISA that serve as the framework for applying patches and identifying equipment that needs attention. The University implemented the security assessments in the Fall of 2022. The University has taken the following steps to address the risks identified during the audit: 1. Employee Training and Management a. The University deployed the Knowbe4 Security Awareness Program to all full time staff. The program provides training for managing user data and email messages. To date the University has distributed two campaigns to combat email phishing attempts. 2. Information systems, including network and software design, as well as information processing, storage, transmission and disposal a. The University has formulated a digital transformation strategy to reduce on premises systems and applications. All the critical business systems are hosted at a colocation or are SaaS solutions. b. The University performs backups of all on premises systems using technology that creates immutable storage. c. The University leverages the cybersecurity experience of resellers and manufacturers to ensure all core network technology is installed and configured to minimize any attack surface. 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks as required by the Gramm-Leach Bliley Act (GLBA). a. The University has deployed a redundant pair of Fortinet Advanced Firewalls to monitor and block traffic with suspicious payloads. b. The University has updated to the latest version of Microsoft Advanced Threat Defender to serve as optimal end point protection for managing email traffic. c. The University contracted with the Cybersecurity and Infrastructure Security Agency (CISA) to perform vulnerability scans and penetration testing. The IT department evaluates the weekly reports and remediates highlighted deficiencies. d. The University has removed all admin rights from school managed computers, eliminating the ability to install local software. e. The University has deployed an updated VPN client to all school managed computers providing a secure tunnel for access network services. f. The University manages web browsers of all school managed computers.
Show full finding ▾Hide full finding ▴Finding 2022-01 - Gramm-Leach Bliley Act (GLBA) ALN: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program, 84.033 Federal Work Study Program, 84.007 Federal Supplemental Education Opportunity Grant; 84.038 Federal Perkins Loan Program Award Year: July 1, 2021 - June 30, 2022 Federal Agency: U.S. Department of Education Pass Through Entity: Not applicable Criteria: In accordance with Title IV regulations (CFR 314.1 (b)), an Institution must protect student financial aid information by designating an individual to coordinate the information security program, perform a risk assessment that addresses (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 and document safeguards for identified risks. Condition: The University has not performed a risk assessments to address (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 and document safeguards for identified risks as required by the Gramm-Leach Bliley Act (GLBA). In addition, the University has not documented safeguards for identified risks. Cause: The University did not have an updated security assessment completed during the year to address procedures and processes in place specific to GLBA and therefore, did not document the required risk assessment or risk mitigation. Effect: With no updated policies and procedures surrounding student information security, the University may be susceptible to threats of consumer nonpublic personal information. Failure to comply with GLBA standards may bring penalties ranging from monetary fines to restriction or loss of eligibility for Title IV funding. Questioned Costs: None. Recommendation: The University should perform and document an annual risk assessment to determine the University's specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the University should have at least one risk statement aligned or referenced to each of the three required areas noted in the GLBA law at 16 CFR 314.4 (b). Finally, the University should identify and document at least one safeguard (i.e., control) for each of the risks identified and document in the risk assessment. Each control should be aligned or referenced to the risk(s) to which the safeguard applies. Management Response: While a specific GLBA audit has not been performed, the University does have a well-developed document titled "Institutional Policies for Safety, Security and Technology" which was released in September 2020. There are policies and procedures within that indirectly address the requirements of GLBA. The Chief Information Officer (CIO) position was transitioned in 2022 and the new CIO noted that the University had not engaged with any new vendor to produce a Security Assessment Report during fiscal year 2022. The University has since engaged with the Cybersecurity and Infrastructure Agency (CISA) to perform vulnerability scanning and penetration testing reporting, so they now have operational security assessment reports from CISA that serve as the framework for applying patches and identifying equipment that needs attention. The University implemented the security assessments in the Fall of 2022. The University has taken the following steps to address the risks identified during the audit: 1. Employee Training and Management a. The University deployed the Knowbe4 Security Awareness Program to all full time staff. The program provides training for managing user data and email messages. To date the University has distributed two campaigns to combat email phishing attempts. 2. Information systems, including network and software design, as well as information processing, storage, transmission and disposal a. The University has formulated a digital transformation strategy to reduce on premises systems and applications. All the critical business systems are hosted at a colocation or are SaaS solutions. b. The University performs backups of all on premises systems using technology that creates immutable storage. c. The University leverages the cybersecurity experience of resellers and manufacturers to ensure all core network technology is installed and configured to minimize any attack surface. 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks as required by the Gramm-Leach Bliley Act (GLBA). a. The University has deployed a redundant pair of Fortinet Advanced Firewalls to monitor and block traffic with suspicious payloads. b. The University has updated to the latest version of Microsoft Advanced Threat Defender to serve as optimal end point protection for managing email traffic. c. The University contracted with the Cybersecurity and Infrastructure Security Agency (CISA) to perform vulnerability scans and penetration testing. The IT department evaluates the weekly reports and remediates highlighted deficiencies. d. The University has removed all admin rights from school managed computers, eliminating the ability to install local software. e. The University has deployed an updated VPN client to all school managed computers providing a secure tunnel for access network services. f. The University manages web browsers of all school managed computers.
Finding 2022-001: Gramm-Leach Bliley Act (GLBA) Recommendation: The University should perform and document an annual risk assessment to determine the University's specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the University should have at least one risk statement aligned or referenced to each of the three required areas noted in the GLBA law at 16 CFR 314.4 (b). Finally, the University should identify and document at least one safeguard (i.e., control) for each of the risks identified and document in the risk assessment. Each control should be aligned or referenced to the risk(s) to which the safeguard applies. Action Taken: The University has taken the following steps to address the risks identified during the audit: 1. Employee Training and Management a. The University deployed the Knowbe4 Security Awareness Program to all full time staff. The program provides training for managing user data and email messages. To date the University has distributed two campaigns to combat email phishing attempts. 2. Information systems, including network and software design, as well as information processing, storage, transmission and disposal a. The University has formulated a digital transformation strategy to reduce on premises systems and applications. All the critical business systems are hosted at a colocation or are SaaS solutions. b. The University performs backups of all on premises systems using technology that creates immutable storage. c. The University leverages the cybersecurity experience of resellers and manufacturers to ensure all core network technology is installed and configured to minimize any attack surface. 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks as required by the Gramm-Leach Bliley Act (GLBA). a. The University has deployed a redundant pair of Fortinet Advanced Firewalls to monitor and block traffic with suspicious payloads. b. The University has updated to the latest version of Microsoft Advanced Threat Defender to serve as optimal end point protection for managing email traffic. c. The University contracted with the Cybersecurity and Infrastructure Security Agency (CISA) to perform vulnerability scans and penetration testing. The IT department evaluates the weekly reports and remediates highlighted deficiencies. d. The University has removed all admin rights from school managed computers, eliminating the ability to install local software. e. The University has deployed an updated VPN client to all school managed computers providing a secure tunnel for access network services. f. The University manages web browsers of all school managed computers. The University will take the results of the security assessment that was completed and draft the GLBA policy in conformity with the DOE requirements by June 2023. Responsible Individual for Corrective Action: Chief Information Officer ? Gregg Chottiner Anticipated Completion Date: June 30, 2023
The change in student status for one of twenty-five students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, the student was ultimately reported to the National Student Data Loan System. Cause: For this student who withdrew from the University, the University?s procedures for reporting the change in status were not designed appropriately in order to allow for timely reporting to the NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, the Title IV student loan records will be inaccurate. Questioned Costs: None. Recommendation: The University should revise its procedures to ensure accurate enrollment information is sent to the NSLDS within the required timeframe for all students and that notifications between departments are communicated timely. Management Response: As of the date that this student withdrew, the Registrar's office was working with the Information Technology (IT) department to implement a process of receiving automatic email notifications when a student has been determined as withdrawn in the student management system (Colleague). At the beginning of calendar year 2022, these notifications were implemented and are now sent to the Registrar?s Office, Student Billing Office, Residence Life Office, and the Financial Aid Office, notifying them when a student is withdrawn from all of their courses. These notifications will now help mitigate the risk of untimely reporting. Additionally, the University has created a weekly report that is pulled by the Registrar?s Office to find students who are active but not enrolled or listed as on Leave Of Absence (LOA) but are not enrolled in a future class.
Show full finding ▾Hide full finding ▴Finding 2022-02 ? Enrollment Reporting ALN: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program Award Year: July 1, 2021 - June 30, 2022 Federal Agency: U.S. Department of Education Pass Through Entity: Not applicable Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary of Education (Secretary), institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a halftime basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: The change in student status for one of twenty-five students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, the student was ultimately reported to the National Student Data Loan System. Cause: For this student who withdrew from the University, the University?s procedures for reporting the change in status were not designed appropriately in order to allow for timely reporting to the NSLDS. Effect: The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, the Title IV student loan records will be inaccurate. Questioned Costs: None. Recommendation: The University should revise its procedures to ensure accurate enrollment information is sent to the NSLDS within the required timeframe for all students and that notifications between departments are communicated timely. Management Response: As of the date that this student withdrew, the Registrar's office was working with the Information Technology (IT) department to implement a process of receiving automatic email notifications when a student has been determined as withdrawn in the student management system (Colleague). At the beginning of calendar year 2022, these notifications were implemented and are now sent to the Registrar?s Office, Student Billing Office, Residence Life Office, and the Financial Aid Office, notifying them when a student is withdrawn from all of their courses. These notifications will now help mitigate the risk of untimely reporting. Additionally, the University has created a weekly report that is pulled by the Registrar?s Office to find students who are active but not enrolled or listed as on Leave Of Absence (LOA) but are not enrolled in a future class.
Finding 2022-02 ? Enrollment Reporting Recommendation: The University should revise its procedures to ensure accurate enrollment information is sent to the NSLDS within the required timeframe for all students and that notifications between departments are communicated timely. Action Taken: As of the date that this student withdrew, the Registrar's office was working with the Information Technology (IT) department to implement a process of receiving automatic email notifications when a student has been determined as withdrawn in the student management system (Colleague). At the beginning of calendar year 2022, these notifications were implemented and are now sent to the Registrar?s Office, Student Billing Office, Residence Life Office, and the Financial Aid Office, notifying them when a student is withdrawn from all of their courses. These notifications will now help mitigate the risk of untimely reporting. Additionally, the University has created a weekly report that is pulled by the Registrar?s Office to find students who are active but not enrolled or listed as on Leave Of Absence (LOA) but are not enrolled in a future class. Responsible Individual for Corrective Action: Registrar ? Joanna Raudenbush Anticipated Completion Date: June 30, 2022
The University drew down $53,560 of HEERF funds from the student portion in August 2021 however, a majority of those funds were not disbursed to students within the 15 days after the draw down occurred. Cause: The University was unsure of how the threat of rescission of HEERF funds, communicated by NAASFAA on August 17, 2021, would affect any of their outstanding funding. Therefore, the funds were drawn so as not to be potentially rescinded, but were not distributed to students within the 15 day time frame. Effect: The University could have drawn down funds for ineligible costs or with improper timing if sufficient allowable costs had not been identified that occurred prior to or within 15 days of the drawdown date. If ED identifies an institution as having an elevated risk or are suspected of improperly administering their HEERF grant funds, ED has a range of possible enforcement actions which could include heightened or more frequent reporting, monitoring or auditing of an institution and placing the HEERF grants on ?Route Payment Status?, which requires prior authorization from ED to draw down any remaining funds. As of the audit report date, the University has not received any notifications of any enforcement actions taken against the University related to the HEERF program. Questioned Costs: None. Recommendation: We recommend that the University implement controls and processes to ensure that all expenses are properly identified and documented before any drawdowns are made. Management Response: The funding was drawn down as the result of news publications from various sources in August 2021 indicating that the infrastructure package threatened to take away unused relief funds. At the time, no creditable source was able to confirm whether this meant the University would lose unused HEERF II and III funds. To safeguard the student funding, the University drew down the remaining balance for HEERF II, knowing they would have students to award the funds to shortly thereafter. All other HEERF awards were drawn down on a reimbursement basis.
Show full finding ▾Hide full finding ▴Finding 2022-03 - Cash Management ALN: 84.425E COVID-19 - Higher Education Emergency Relief Fund (HEERF) - Student Portion Award Year: July 1, 2021 - June 30, 2022 Federal Agency: U.S. Department of Education Pass Through Entity: Not applicable Criteria: The U.S. Department of Education (ED) communicated updated cash management guidance for the HEERF through the release of the HEERF II FAQs on January 14, 2021. The HEERF II FAQ #17 specified that grantees are under an obligation to minimize the time between drawing down funds from G5 and paying obligations incurred by the grantee. ED considered institutions compliant if they paid from the HEERF funds emergency grants to students within 15 days of the draw down and for all other uses within 3 days. The Uniform Guidance requires the identification and documentation of costs as federal expenditures to occur prior to or within the timeframe established for paying obligations when grantees must follow enhanced cash management requirements. Condition: The University drew down $53,560 of HEERF funds from the student portion in August 2021 however, a majority of those funds were not disbursed to students within the 15 days after the draw down occurred. Cause: The University was unsure of how the threat of rescission of HEERF funds, communicated by NAASFAA on August 17, 2021, would affect any of their outstanding funding. Therefore, the funds were drawn so as not to be potentially rescinded, but were not distributed to students within the 15 day time frame. Effect: The University could have drawn down funds for ineligible costs or with improper timing if sufficient allowable costs had not been identified that occurred prior to or within 15 days of the drawdown date. If ED identifies an institution as having an elevated risk or are suspected of improperly administering their HEERF grant funds, ED has a range of possible enforcement actions which could include heightened or more frequent reporting, monitoring or auditing of an institution and placing the HEERF grants on ?Route Payment Status?, which requires prior authorization from ED to draw down any remaining funds. As of the audit report date, the University has not received any notifications of any enforcement actions taken against the University related to the HEERF program. Questioned Costs: None. Recommendation: We recommend that the University implement controls and processes to ensure that all expenses are properly identified and documented before any drawdowns are made. Management Response: The funding was drawn down as the result of news publications from various sources in August 2021 indicating that the infrastructure package threatened to take away unused relief funds. At the time, no creditable source was able to confirm whether this meant the University would lose unused HEERF II and III funds. To safeguard the student funding, the University drew down the remaining balance for HEERF II, knowing they would have students to award the funds to shortly thereafter. All other HEERF awards were drawn down on a reimbursement basis.
Finding 2022-03 - Cash Management Recommendation: The University should implement controls and processes to ensure that all expenses are properly identified and documented before any drawdowns are made. Action Taken: The funding was drawn down as the result of news publications from various sources in August 2021 indicating that the infrastructure package threatened to take away unused relief funds. At the time, no creditable source was able to confirm whether this meant the University would lose unused HEERF II and III funds. To safeguard the student funding, the University drew down the remaining balance for HEERF II, knowing they would have students to award the funds to shortly thereafter. All other HEERF awards were drawn down on a reimbursement basis. Responsible Individual for Corrective Action: Sr. Associate VP / Deputy CFO ? Jennifer Ginnetti Anticipated Completion Date: December 31, 2022
FAC accepted this audit on May 16, 2022 — management decision was due November 16, 2022.
FAC accepted this audit on September 22, 2021 — management decision was due March 22, 2022.
CFDA No.: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program Award Year: July 1, 2019 - June 30, 2020 Federal Agency: U.S. Department of Education Pass Through Entity: Not applicable Criteria Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a halftime basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition The change in student status for sixteen of twenty-five students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, the students were ultimately reported to the National Student Data Loan System. Cause For fifteen of the students, the School's procedures for reporting graduated students was not designed appropriately in order to allow for timely reporting to the NSLDS. For one student, the Registrar's office was not informed timely of the student's withdrawal from their Counselor. Effect The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned Costs None noted. Context For the graduated students, the issue was related to one submission. The Registrar submitted the roster within the appropriate timeline, however there was an error with the file which cause it to not be accepted and processed. The error was not found until after the 60-day reporting period passed. For the withdrawn student, the instance was isolated to one student whose status change was not communicated timely to the Registrar. The sample was not a statistically valid sample but was determined using Chapter 21 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Government Auditing Standards and Single Audits Audit Guide. Recommendation The University should revise its procedures to ensure accurate enrollment information is sent to the NSLDS within the required timeframe for all students and that notifications between departments are communicated timely. Views of Responsible Officials Management has implemented a new process where the ?Degree Verify? file, as well as the "Grads Only" file, are sent to the Clearinghouse at the same time. The Registrar's office is also working with the IT department to implement a process of receiving automatic email notifications when a student has been determined as withdrawn in the student management system (Colleague).
Show full finding ▾Hide full finding ▴CFDA No.: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program Award Year: July 1, 2019 - June 30, 2020 Federal Agency: U.S. Department of Education Pass Through Entity: Not applicable Criteria Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a halftime basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition The change in student status for sixteen of twenty-five students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, the students were ultimately reported to the National Student Data Loan System. Cause For fifteen of the students, the School's procedures for reporting graduated students was not designed appropriately in order to allow for timely reporting to the NSLDS. For one student, the Registrar's office was not informed timely of the student's withdrawal from their Counselor. Effect The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Questioned Costs None noted. Context For the graduated students, the issue was related to one submission. The Registrar submitted the roster within the appropriate timeline, however there was an error with the file which cause it to not be accepted and processed. The error was not found until after the 60-day reporting period passed. For the withdrawn student, the instance was isolated to one student whose status change was not communicated timely to the Registrar. The sample was not a statistically valid sample but was determined using Chapter 21 - Audit Sampling Considerations of Uniform Guidance Compliance Audits of the Government Auditing Standards and Single Audits Audit Guide. Recommendation The University should revise its procedures to ensure accurate enrollment information is sent to the NSLDS within the required timeframe for all students and that notifications between departments are communicated timely. Views of Responsible Officials Management has implemented a new process where the ?Degree Verify? file, as well as the "Grads Only" file, are sent to the Clearinghouse at the same time. The Registrar's office is also working with the IT department to implement a process of receiving automatic email notifications when a student has been determined as withdrawn in the student management system (Colleague).
FINDINGS - Enrollment Reporting Finding 2020-001: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program Recommendation: The University should revise its procedures to ensure accurate enrollment information is sent to the NSLDS within the required timeframe for all students and that notifications between departments are communicated timely. Action Taken: The Registrar's Office has implemented a new process where the Degree Verify file, as well as the "Grads only" file, are sent to the Clearinghouse at the same time. The Registrar's office is also working with the IT department to implement a process of receiving automatic email notifications when a student has been determined as withdrawn in Colleague, the system of record. Responsible Individual for Corrective Action: Registrar - Joanna Raudenbush Anticipated Completion Date: August 18, 2021 If there are any questions regarding this corrective action plan please call Jennifer Ginnetti, Sr. Associate VP for Finance/ Deputy CFO, at ginnetti.j@gmercyu.edu.
FAC accepted this audit on March 9, 2020 — management decision was due September 9, 2020.
Finding 2019-001: Return of Title IV Funds CFDA No.: 84.268 Federal Direct Loan Program Award Year: July 1, 2018 - June 30, 2019 Federal Agency: U.S. Department of Education Federal Award Number: P268K202101 Pass Through Entity: Not applicable Criteria Per 34 CFR 668.22(j), an institution must return the amount of Title IV funds for which it is responsible as soon as possible, but no later than 45 days after the date of the institution?s determination that the student withdrew. Condition The Title IV funds related to a student who withdrew was not returned within the required timeframe. Cause The University's procedures for the return of Title IV funds were not followed. Effect The University was in possession of funds belonging to the federal government longer than allowed. Questioned Costs The late refund amount was $4,117 for the one student. Context Out of 7 students tested for refunds processed, one student?s funds were returned beyond 45 days of when the University determined that the student withdrew. The sample selected was not statistically valid. Recommendation The University should increase emphasis on timely processing of refund transactions. Views of Responsible Officials The University noted that the R2T4 calculation for the student was accurately and in a timely manner. However, the student refund was not remitted within 45 days of when the University determined that the student withdrew. This delay in remittance was detected by the University during monthly reconciliation procedures. Although the R2T4 was calculated between reconciliation periods, the University?s reconciliation procedures did function as intended by identifying the error, thus preventing further delay in the return of funding. To confirm the timely and complete return of Title IV, the University has designated two financial aid specialists (one for traditional and one for graduate and professional studies student populations) to complete withdrawal calculations and track the Title IV fund return process. This process change was developed at the end of summer 2019 and implemented prior to the start of fall 2019. The withdrawal calculation process is set up to complete the actual withdrawal calculation within 30 days from the School Determination Date. Once completed, the specialist will ensure the aid return is set up for the COD transmission and account posting reversal. Then, the same specialist will review the aid return request within the seven days following the completion of the withdrawal calculation and determine if the aid was actually removed from the student account and adjusted on COD. If an error has occurred, the same specialist will make sure the aid is returned properly by requesting a special disbursement and following up again to confirm completion of the process. These expanded procedures will serve as additional preventative and detective controls for the R2T4 completion process.
Show full finding ▾Hide full finding ▴Finding 2019-001: Return of Title IV Funds CFDA No.: 84.268 Federal Direct Loan Program Award Year: July 1, 2018 - June 30, 2019 Federal Agency: U.S. Department of Education Federal Award Number: P268K202101 Pass Through Entity: Not applicable Criteria Per 34 CFR 668.22(j), an institution must return the amount of Title IV funds for which it is responsible as soon as possible, but no later than 45 days after the date of the institution?s determination that the student withdrew. Condition The Title IV funds related to a student who withdrew was not returned within the required timeframe. Cause The University's procedures for the return of Title IV funds were not followed. Effect The University was in possession of funds belonging to the federal government longer than allowed. Questioned Costs The late refund amount was $4,117 for the one student. Context Out of 7 students tested for refunds processed, one student?s funds were returned beyond 45 days of when the University determined that the student withdrew. The sample selected was not statistically valid. Recommendation The University should increase emphasis on timely processing of refund transactions. Views of Responsible Officials The University noted that the R2T4 calculation for the student was accurately and in a timely manner. However, the student refund was not remitted within 45 days of when the University determined that the student withdrew. This delay in remittance was detected by the University during monthly reconciliation procedures. Although the R2T4 was calculated between reconciliation periods, the University?s reconciliation procedures did function as intended by identifying the error, thus preventing further delay in the return of funding. To confirm the timely and complete return of Title IV, the University has designated two financial aid specialists (one for traditional and one for graduate and professional studies student populations) to complete withdrawal calculations and track the Title IV fund return process. This process change was developed at the end of summer 2019 and implemented prior to the start of fall 2019. The withdrawal calculation process is set up to complete the actual withdrawal calculation within 30 days from the School Determination Date. Once completed, the specialist will ensure the aid return is set up for the COD transmission and account posting reversal. Then, the same specialist will review the aid return request within the seven days following the completion of the withdrawal calculation and determine if the aid was actually removed from the student account and adjusted on COD. If an error has occurred, the same specialist will make sure the aid is returned properly by requesting a special disbursement and following up again to confirm completion of the process. These expanded procedures will serve as additional preventative and detective controls for the R2T4 completion process.
FINDING 2019-001: 84.268 Federal Direct Loan Program Recommendation: We recommend that the Bursar?s office and Financial Aid increase emphasis on timely processing of refund transactions. Action Taken: To confirm the timely and complete return of Title IV, the University has designated two financial aid specialists (one for traditional and one for graduate and professional studies student populations) to complete withdrawal calculations and track the Title IV fund return process. This process change was developed at the end of summer 2019 and implemented prior to the start of fall 2019. The withdrawal calculation process is set up to complete the actual withdrawal calculation within 30 days from the School Determination Date. Once completed, the specialist will ensure the aid return is set up for the COD transmission and account posting reversal. Then, the same specialist will review the aid return request within the seven days following the completion of the withdrawal calculation and determine if the aid was actually removed from the student account and adjusted on COD. If an error has occurred, the same specialist will make sure the aid is returned properly by requesting a special disbursement and following up again to confirm completion of the process. These expanded procedures will serve as additional preventative and detective controls for the R2T4 completion process. Responsible Individual for Corrective Action: Director of Financial Aid ? Elizabeth Howard Financial Aid Specialists ? Michelle Molina and Nicole Gibbons Anticipated Completion Date: August 26, 2019 If there are any questions regarding this corrective action plan please call Jennifer Ginnetti, Associate VP for Finance/Controller, at ginnetti.j@gmercyu.edu. Sincerely yours, Jennifer Ginnetti Associate VP for Finance/Controller
FAC accepted this audit on March 26, 2019 — management decision was due September 26, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on March 19, 2018 — management decision was due September 19, 2018.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on March 27, 2017 — management decision was due September 27, 2017.
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
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GSA_MIGRATION
2015-003
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