EIN: 231352655
UEI: T59JHM69NCZ3
Audited by: CliftonLarsonAllen LLP
Oversight agency: 84 [Department of Education]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 23, 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 July 23, 2026 (43 days ago).
What is a management decision? →FAC accepted this audit on November 23, 2024 — management decision was due May 23, 2025.
Through our testing of 64 students whose accounts had a credit balance resulting from federal funds during the year, we noted that 6 students did not have the credit balance refunded within the 14-day period. Questioned Costs: N/A Context: During our testing, we noted that six students were owed a Title IV credit refund that was not completed within the 14-day period. Cause: The University did not properly review Credit Balance required procedures. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by DOE regulations. Repeat Finding: No. Recommendation: We recommend that the University put a process in place to refund student credit balances that arose from federal funds within 14 days. Views of responsible officials: Management agrees with the findings and has developed a plan to correct the finding.
Show full finding ▾Hide full finding ▴2024 – 001 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, "Whenever an institution disburses title IV, HEA program funds by crediting a student's account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: Through our testing of 64 students whose accounts had a credit balance resulting from federal funds during the year, we noted that 6 students did not have the credit balance refunded within the 14-day period. Questioned Costs: N/A Context: During our testing, we noted that six students were owed a Title IV credit refund that was not completed within the 14-day period. Cause: The University did not properly review Credit Balance required procedures. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by DOE regulations. Repeat Finding: No. Recommendation: We recommend that the University put a process in place to refund student credit balances that arose from federal funds within 14 days. Views of responsible officials: Management agrees with the findings and has developed a plan to correct the finding.
Student Financial Assistance Cluster – Assistance Listing Number 84.007, 84.063, 84.268 Recommendation: We recommend that the University put a process in place to refund student credit balances that arose from federal funds within 14 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has in place a systematic procedure wherein reviews of credit balances are conducted promptly after aid is transmitted. The University will ensure that this procedure is followed thoroughly. Name(s) of the contact person(s) responsible for corrective action: H. Jonas Javier Planned completion date for corrective action plan: November 4, 2024
Eight checks totaling $494.20 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2024. Questioned Costs: $494.20 Context: The University did not have an official process is in place to ensure the funds never escheat back to the state or other agencies. Cause: The University did not properly review SFA Outstanding Student Title IV Check required procedures. Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department. Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of responsible officials: Management agrees with the findings and has developed a plan to correct the finding.
Show full finding ▾Hide full finding ▴2024 – 002 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. Condition: Eight checks totaling $494.20 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2024. Questioned Costs: $494.20 Context: The University did not have an official process is in place to ensure the funds never escheat back to the state or other agencies. Cause: The University did not properly review SFA Outstanding Student Title IV Check required procedures. Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department. Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of responsible officials: Management agrees with the findings and has developed a plan to correct the finding.
Student Financial Assistance Cluster – Assistance Listing Number 84.007, 84.063, 84.268 Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will develop and implement a procedure wherein uncashed checks will be reviewed more closely. Student refunds identified as uncashed as of 60 days will be forwarded to the Bursar’s Office. Bursar’s Office will conduct outreach to refund recipients. If refund remains uncashed after 180 days, Bursar’s Office will return funds to federal agency. Name(s) of the contact person(s) responsible for corrective action: H. Jonas Javier Planned completion date for corrective action plan: November 4, 2024
The University had not updated changes in top management positions within the allotted 10-day timeframe. Questioned Costs: N/A Context: The University did not have an official process is in place to ensure top management positions were updated timely. Cause: The University did not properly update management positions on the Eligibility and Certification Approval Report in a timely fashion. Effect: The University is not in compliance with Department of Education requirements. Recommendation: We recommend that the University review its procedures related to updating the Eligibility and Certification Approval Report in a timely fashion. Views of responsible officials: Management agrees with the findings and has developed a plan to correct the finding.
Show full finding ▾Hide full finding ▴2024 – 003 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Each University that participates in federal Title IV financial aid programs is required to obtain an Eligibility and Certification Approval Report. This report includes certain information about the University including which financial aid programs the University is eligible for, locations of the University and top management and board officials. Any time there is a change in top management, including the President, Director of Financial Aid and Senior VP for Business, Finance and Technology, this is required to be reported within 10 days. During the year, it was noted that changes were not always reported within the required 10 days. We recommend the University review their procedures around updating this report to ensure compliance with Department of Education requirements. Condition: The University had not updated changes in top management positions within the allotted 10-day timeframe. Questioned Costs: N/A Context: The University did not have an official process is in place to ensure top management positions were updated timely. Cause: The University did not properly update management positions on the Eligibility and Certification Approval Report in a timely fashion. Effect: The University is not in compliance with Department of Education requirements. Recommendation: We recommend that the University review its procedures related to updating the Eligibility and Certification Approval Report in a timely fashion. Views of responsible officials: Management agrees with the findings and has developed a plan to correct the finding.
Student Financial Assistance Cluster – Assistance Listing Number 84.007, 84.063, 84.268 Recommendation: We recommend that the University review its procedures related to updating the Eligibility and Certification Approval Report in a timely fashion. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: University will review which individuals are listed on the ECAR. Upon learning of their departure, the University will update ECAR immediately. Name(s) of the contact person(s) responsible for corrective action: H. Jonas Javier Planned completion date for corrective action plan: November 4, 2024
During our testing of suspension and debarment, we noted the University did not have support for debarment checks five of the five vendors tested. Questioned Costs: N/A Context: During our testing of suspension and debarment, we noted the University was unable to provide support for debarment checks five of the five vendors tested. Cause: The University did not have support to verify debarment checks were completed before entering into agreements or occurring expenditures for five of the five vendors selected. Effect: Suspended or debarred vendors could have been charged to the grant, resulting in unallowable expenditures occurring. Repeat Finding: Yes – 2023-005. Recommendation: The University should evaluate their procedures surrounding the maintenance of suspension and debarment checks. Views of responsible officials: Management agrees with the findings and has developed a plan to correct the finding.
Show full finding ▾Hide full finding ▴2024 – 004 Federal Agency: Department of Education Federal Program Name: Higher Education Aid – Title III Assistance Listing Numbers: 84.031 Federal Award Identification Number and Year: P031E200019, P031B170023 and P031B220048, grants were awarded within the 2023-24 award year. Award Period: July 1, 2023, through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of suspension and debarment, we noted the University did not have support for debarment checks five of the five vendors tested. Questioned Costs: N/A Context: During our testing of suspension and debarment, we noted the University was unable to provide support for debarment checks five of the five vendors tested. Cause: The University did not have support to verify debarment checks were completed before entering into agreements or occurring expenditures for five of the five vendors selected. Effect: Suspended or debarred vendors could have been charged to the grant, resulting in unallowable expenditures occurring. Repeat Finding: Yes – 2023-005. Recommendation: The University should evaluate their procedures surrounding the maintenance of suspension and debarment checks. Views of responsible officials: Management agrees with the findings and has developed a plan to correct the finding.
Higher Educational Aid – Title III – Assistance Listing Number 84.031 Recommendation: The University should evaluate their procedures surrounding the maintenance of suspension and debarment checks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has in place a systematic procedure wherein vendors are reviewed for suspension or debarment statuses. The University will evaluate procedures to determine if any changes are necessary. Procurement Staff will continue to follow these procedures and maintain timely records of the debarment/suspension reviews. Name(s) of the contact person(s) responsible for corrective action: H. Jonas Javier Planned completion date for corrective action plan: December 1, 2024 If the U.S. Department of Education has questions regarding this plan, please contact the individual(s) noted above.
2023-005
FAC accepted this audit on March 27, 2024 — management decision was due September 27, 2024.
The University did not use the formula provided in the Final Rule when determining the amount of funds to claim under lost revenue. Questioned Costs: N/A Context: The University did not use the correct methodology when calculating lost revenue. Cause: The University did not use the correct methodology when calculating lost revenue. Effect: Lost revenue amount calculated could have resulted in more than allowed lost revenue being claimed. Repeat Finding: No. Recommendation: The University should evaluate their procedures and review their policies surrounding earmarking requirements.
Show full finding ▾Hide full finding ▴2023 – 003 Federal Agency: Department of Treasury Federal Program Name: Coronavirus State & Local Fiscal Recovery Fund Assistance Listing Numbers: 21.027 Federal Award Identification Number and Year: SLFRP1746, grants were awarded within the 2022-23. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Recipients of Coronavirus State & Local Fiscal Recovery Funds may use payments from SLRFR to replace lost public sector revenue to provide government services. Recipients may use this funding to provide government services to the extent of the reduction in revenue experience due to the pandemic. Under the Final Rule, recipients can elect a one-time “standard allowance” or they can calculate lost revenue based on the formula provide in the Final Rule to determine the amount of funds that can be used for the provision of government services. Condition: The University did not use the formula provided in the Final Rule when determining the amount of funds to claim under lost revenue. Questioned Costs: N/A Context: The University did not use the correct methodology when calculating lost revenue. Cause: The University did not use the correct methodology when calculating lost revenue. Effect: Lost revenue amount calculated could have resulted in more than allowed lost revenue being claimed. Repeat Finding: No. Recommendation: The University should evaluate their procedures and review their policies surrounding earmarking requirements.
Action taken in response to finding: Fiscal Affairs will more carefully review methodologies provided by the granting agency when seeking funding, maintain more thoroughly documented records of any pertinent calculations and communications, and ensure that information is disseminated to appropriate parties.
The University did not have support of the required reports being completed or submitted. Questioned Costs: N/A Context: The University did not have support of the required reports being completed or submitted. Cause: The University’s policies and procedures did not ensure that grant reporting requirements were timely and accurately met. Effect: The University is not complying with awarding requirements, which could affect the amount of Federal funding received. Repeat Finding: No. Recommendation: The University should evaluate their procedures and review their policies surrounding review of grant reporting requirements.
Show full finding ▾Hide full finding ▴2023 – 004 Federal Agency: Department of Treasury Federal Program Name: Coronavirus State & Local Fiscal Recovery Fund Assistance Listing Numbers: 21.027 Federal Award Identification Number and Year: SLFRP1746, grants were awarded within the 2022-23. Award Period: July 1, 2022, through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. There are two components to reporting for Coronavirus State & Local Fiscal Recovery Funds: 1.) Obligation and Expenditures - Quantifiable objective criteria: Reported obligations and expenditures include Current period obligation, Cumulative obligation, Current period expenditure, and Cumulative expenditure. 2.) Capital Expenditures - Quantifiable Objective Criteria: The recipient has the required written justification in their grant file if the total of the capital expenditures costs in a project is greater than or equal to $1 million and less than $10 million. Condition: The University did not have support of the required reports being completed or submitted. Questioned Costs: N/A Context: The University did not have support of the required reports being completed or submitted. Cause: The University’s policies and procedures did not ensure that grant reporting requirements were timely and accurately met. Effect: The University is not complying with awarding requirements, which could affect the amount of Federal funding received. Repeat Finding: No. Recommendation: The University should evaluate their procedures and review their policies surrounding review of grant reporting requirements.
Action taken in response to finding: Fiscal Affairs will review reporting requirements for any funding received; communicate such requirements to the appropriate parties within the University; and coordinate with Office of Research & Sponsored Programs to ensure that the reporting requirement is met.
During our testing of suspension and debarment, we noted the University did not have support for debarment checks two of the six vendors tested. Questioned Costs: N/A Context: During our testing of suspension and debarment, we noted the University did not have support for debarment checks two of the six vendors tested. Cause: The University did not have support to verify debarment checks were completed before entering into agreements or occurring expenditures for two of the six vendors selected. Effect: Suspended or debarred vendors could have been charged to the grant, resulting in unallowable expenditures occurring. Repeat Finding: No. Recommendation: The University should evaluate their procedures surrounding the maintenance of suspension and debarment checks.
Show full finding ▾Hide full finding ▴2023 – 005 Federal Agency: Department of Education Federal Program Name: Higher Education Aid – Title III Assistance Listing Numbers: 84.031 Federal Award Identification Number and Year: P031E200019, P031B170023 and P031B220048, grants were awarded within the 2022-23 award year. Award Period: July 1, 2022, through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of suspension and debarment, we noted the University did not have support for debarment checks two of the six vendors tested. Questioned Costs: N/A Context: During our testing of suspension and debarment, we noted the University did not have support for debarment checks two of the six vendors tested. Cause: The University did not have support to verify debarment checks were completed before entering into agreements or occurring expenditures for two of the six vendors selected. Effect: Suspended or debarred vendors could have been charged to the grant, resulting in unallowable expenditures occurring. Repeat Finding: No. Recommendation: The University should evaluate their procedures surrounding the maintenance of suspension and debarment checks.
Action taken in response to finding: Review current procurement procedures and implement necessary changes to ensure that proper diligence is performed on all potential vendors and that documentation of the debarment confirmation is maintained.
FAC accepted this audit on March 14, 2023 — management decision was due September 14, 2023.
During our testing of Institutional Quarterly Public reports the University posted the 1 of the 2 Quarterly Institutional tested 68 days late. Questioned costs: None Context: During our testing of Institutional Quarterly Public reports, we noted that the University was not posting required Quarterly Public reports within 10 days of the calendar quarter. Cause: The University did not have processes in place to maintain documentation of updates to student portion quarterly reports posted to their website. In addition, the University did not have process in place to timely update quarterly Institutional Quarterly Public reports. Effect: Failure to file the required reports timely may result in the loss of funding or delay in payments under the award agreement. Repeat Finding: Yes. Recommendation: We recommend the University enhances its procedures, controls, and review policies around HEERF reporting. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program Name: Coronavirus Aid, Relief and Economic Security Act ? Higher Education Emergency Relief Fund ? Institution Portions & Historically Black Colleges and University (HBCUs) Assistance Listing Number: 84.425F & 84.425J Federal Award Identification Number and Year: P425F200155 & P425J200032, 2022 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF III to submit a report to the secretary, at such time in such a manner as the secretary may require. 1.) Quarterly Public Reporting for Institutional requires a new, separate form to be posted covering aggregate amounts spent for HEERF I, HEERF II, and HEERF III funds each quarterly reporting period due no later than 10 days after the end of each calendar quarter. Condition: During our testing of Institutional Quarterly Public reports the University posted the 1 of the 2 Quarterly Institutional tested 68 days late. Questioned costs: None Context: During our testing of Institutional Quarterly Public reports, we noted that the University was not posting required Quarterly Public reports within 10 days of the calendar quarter. Cause: The University did not have processes in place to maintain documentation of updates to student portion quarterly reports posted to their website. In addition, the University did not have process in place to timely update quarterly Institutional Quarterly Public reports. Effect: Failure to file the required reports timely may result in the loss of funding or delay in payments under the award agreement. Repeat Finding: Yes. Recommendation: We recommend the University enhances its procedures, controls, and review policies around HEERF reporting. Views of responsible officials: There is no disagreement with the audit finding.
Department of Education Lincoln University of the Commonwealth System of Higher Education respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 through June 30, 2022 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-FEDERAL AWARD PROGRAMS AUDITS 2022-001 Coronavirus Aid, Relief and Economic Security Act- Higher Education Emergency Relief Fund -Institution Portions - Assistance Listing No. 84.425F Recommendation: We recommend the University enhances its procedures, controls, and review policies around HEERF reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The organization has implemented policies and procedures to ensure the posting of quarterly reporting to the Lincoln website by the due date and that the posting includes verification of the posting date. Name(s) of the contact person(s) responsible for corrective action: Sharon Falade, Grants Accountant - sfalade@lincoln.edu Planned completion date for corrective action plan: April 2022 If the Department of Education has questions regarding this plan, please call: Chuck Gradowski, Vice President, Division of Finance & Administration 484-365-8049
2021-004
FAC accepted this audit on April 25, 2022 — management decision was due October 25, 2022.
During our testing, we noted: 1) three of the 40 students tested were reported to NSLDS outside the 60 days. 2) two of the 40 students tested were reported to NSLDS with an incorrect enrollment effective date. 3) During our testing, we noted that the rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. 4) two of the 40 students tested were not reported correctly with the correct program enrollment date. Questioned Costs: None. Context: While the University has processes and controls in place for timely correcting its roster file, such controls did not operate effectively on a couple occasions as detailed in this finding As a result, the necessary corrections were not made within 10 the days but also caused students in our testing to be reported outside of 60 days. Lastly, enrollment and program dates were not reported correctly. Cause: While the University has processes and controls to follow up on NSLDS reporting errors, it did not fully adopt the process and controls to recently-changed more detailed program-level NSLDS requirements. Effect: 1) Reporting every 60 days at a minimum or reporting twice ensures that the grace period should or should not begin. 2) The enrollment effective date report to NSLDS is used to determine when the student?s grace period should begin. Not reporting a correct effective date, the grace period begin date for the student will be incorrect. 3) The NSLDS is not updated with the student information which can cause over-awarding should the student transfer to another University and the students may not properly enter the repayment period. 4) The program enrollment effective date reported to NSLDS is used to determine the student?s 150% limit for direct loans as well as when grace period should begin. By not reporting the correct status, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect. Repeat Finding: No. Recommendation: We recommend the university enhances its procedures, controls, and review policies surrounding the NSLDS reporting to assist them with correcting their roster file. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2021 ? 001 Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007 - Federal Supplemental Education Opportunity Grants 84.033 - Federal Work Study Program 84.063 - Federal Pell Grant Program 84.268 - Federal Direct Student Loan Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matter Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires 1) that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. 2) that the status includes an accurate effective date. 3) that the University makes necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. 4) the schools must have some arrangement to report students program enrollment effective date. Condition: During our testing, we noted: 1) three of the 40 students tested were reported to NSLDS outside the 60 days. 2) two of the 40 students tested were reported to NSLDS with an incorrect enrollment effective date. 3) During our testing, we noted that the rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. 4) two of the 40 students tested were not reported correctly with the correct program enrollment date. Questioned Costs: None. Context: While the University has processes and controls in place for timely correcting its roster file, such controls did not operate effectively on a couple occasions as detailed in this finding As a result, the necessary corrections were not made within 10 the days but also caused students in our testing to be reported outside of 60 days. Lastly, enrollment and program dates were not reported correctly. Cause: While the University has processes and controls to follow up on NSLDS reporting errors, it did not fully adopt the process and controls to recently-changed more detailed program-level NSLDS requirements. Effect: 1) Reporting every 60 days at a minimum or reporting twice ensures that the grace period should or should not begin. 2) The enrollment effective date report to NSLDS is used to determine when the student?s grace period should begin. Not reporting a correct effective date, the grace period begin date for the student will be incorrect. 3) The NSLDS is not updated with the student information which can cause over-awarding should the student transfer to another University and the students may not properly enter the repayment period. 4) The program enrollment effective date reported to NSLDS is used to determine the student?s 150% limit for direct loans as well as when grace period should begin. By not reporting the correct status, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect. Repeat Finding: No. Recommendation: We recommend the university enhances its procedures, controls, and review policies surrounding the NSLDS reporting to assist them with correcting their roster file. Views of Responsible Officials: There is no disagreement with the audit finding.
2021-001 Student Financial Assistance Cluster -Assistance Listing No. 84.007, 84.033, 84.063, and 84.268 Recommendation: We recommend the university enhances its procedures, controls, and review policies surrounding the NSLDS reporting to assist them with correcting their roster file. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. The Registrar reports directly to the National Student Clearinghouse, who in turn reports to NSLDS on our behalf. During the academic year, this is an automated process of sending files from our student information system to the National Student Clearinghouse. Once the Spring academic semester is complete, we must manually report changes to the National Student Clearinghouse, until the start of the subsequent Fall academic semester. Our processes and procedures for manually reporting are documented and in place. A newly hired staff member received training on this process in March, but we failed to review and verify the manual updating. To remedy this oversight we have implemented an additional step to this process to ensure our roster file is accurately and timely reported. This additional policy procedure is being performed by Financial Aid. Catherine Rutledge, Registrar Email: crutledge@lincoln.edu Completion Date: March 2022
During our testing, we noted two of 25 students? disbursements were not reported within the required 15 days. Questioned Costs: None Context: While the University has processes and controls are in place to accurately report Pell disbursements to COD within the required 15 days, there were some isolated occurrences detailed in this finding where such controls did not operate effectively Cause: While the university has processes and controls in place to accurately report Pell disbursements to COD within the required 15 days, on a couple isolated occasions, these controls did not operate effectively due to the uniqueness of the situation and special considerations required. Effect: Students? interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No. Recommendation: We recommend the University enhance its procedures, controls, and review their policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2021 ? 002 Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 - Federal Pell Grant Program 84.268 - Federal Direct Student Loan Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matter Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted two of 25 students? disbursements were not reported within the required 15 days. Questioned Costs: None Context: While the University has processes and controls are in place to accurately report Pell disbursements to COD within the required 15 days, there were some isolated occurrences detailed in this finding where such controls did not operate effectively Cause: While the university has processes and controls in place to accurately report Pell disbursements to COD within the required 15 days, on a couple isolated occasions, these controls did not operate effectively due to the uniqueness of the situation and special considerations required. Effect: Students? interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No. Recommendation: We recommend the University enhance its procedures, controls, and review their policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.
2021-002 Student Financial Assistance Cluster -Assistance Listing No. 84.063 and 84.268 Recommendation: We recommend the University enhance its procedures, controls, and review their policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. The Financial Aid Office has updated the policies and procedures for submitting student information to COD. The student information reported to COD is now in aggregate and will include all reportable data as opposed to a specific subset of data. This will ensure the reported student information is both complete and delivered timely to COD, who will disregard redundant records not needed. Kim Anderson, Director Financial Aid Email: kanderson@lincoln.edu Completion Date: February 2022
During our testing of borrowers with open loans we noted the University did not have original or true copies of master promissory note for 10 of the 60 students tested Questioned Costs: None Context: During our testing of borrowers with open loans we noted the University was not able to locate a couple original or true copies of all promissory and master promissory notes for older loans as detailed in this finding Cause: While the University has processes and controls in place to maintain Perkins loan promissory and master promissory notes, due to the age of some of the loans subject to testing, the controls around the maintenance of those forms did not operate effectively on a couple occasions. Effect: The University is currently undergoing preparation to a close out of the Perkins Loan Program, and understands that in situations similar to those described in this finding, they may have to purchase students? outstanding loans as a result of not retaining necessary information needed to assign them. Repeat Finding: No. Recommendation: We recommend the University enhances its procedures, controls, and review policies around maintaining required student information. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2021 ? 003 Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.038 - Federal Perkins Loan Program Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires the University to retain 1) original or true and exact copies of promissory and master promissory notes (MPN), 2) repayment records, 3) cancellation and deferment request for each Perkins loan made. Condition: During our testing of borrowers with open loans we noted the University did not have original or true copies of master promissory note for 10 of the 60 students tested Questioned Costs: None Context: During our testing of borrowers with open loans we noted the University was not able to locate a couple original or true copies of all promissory and master promissory notes for older loans as detailed in this finding Cause: While the University has processes and controls in place to maintain Perkins loan promissory and master promissory notes, due to the age of some of the loans subject to testing, the controls around the maintenance of those forms did not operate effectively on a couple occasions. Effect: The University is currently undergoing preparation to a close out of the Perkins Loan Program, and understands that in situations similar to those described in this finding, they may have to purchase students? outstanding loans as a result of not retaining necessary information needed to assign them. Repeat Finding: No. Recommendation: We recommend the University enhances its procedures, controls, and review policies around maintaining required student information. Views of Responsible Officials: There is no disagreement with the audit finding.
2021-003 Student Financial Assistance Cluster - Assistance Listing No. 84.038 Recommendation: We recommend the University enhances its procedures, controls, and review policies around maintaining required student information. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. The original master promissory notes not located included the following issuance dates: 1995 (1), 2014 (1), 2016 (3), and 2017(5). Our Perkins Loan servicer (ECSI) has the electronic payment histories for all ten students. Nine of the ten students' award history is located within our current student information system, and the tenth student's award history is located within our previous student information system. None of the ten students are currently enrolled. It is possible to assign a loan that has a missing promissory note by providing a payment history or an entitlement showing that the student was aware of the debt. Until the assignment period has ended we will continue to gather promissory notes not originally identified and stored within Perkins designated filing locations and we are working with the Registrar, Information Technology and Financial Aid to retrieve supplemental Perkins profile documentation which may be used to assign Perkins loans to the Department of Education in lieu of the original master promissory note. Norman Billie, Bursar Email: nbillie@lincoln.edu Completion Date: May 2022
During our testing of the quarterly public reports for the institutional and student aid portion, we identified the University did not post three of the four quarterly institutional reports and posted one quarterly institutional past the 10 day requirement. For the student aid portion, we tested two of the four quarterly reports, and identified they were published on the University?s website, however, there was no documentation for when this information was posted or updated within 10 days after the end of the quarter-end. Questioned Costs: None Context: During our testing of the quarterly public reports for the institutional and student aid portion, we noted that the University was not posting the required quarterly public reports within 10 days of the calendar quarter. Cause: The University did not have processes in place to submit the quarterly public reports for the institutional and student aid portion to their website. Effect: Failure to file the required reports timely may result in the loss of funding. Repeat Finding: No. Recommendation: We recommend the University enhances its procedures, controls, and review policies around CARES Act and the CRRSAA reporting requirement. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2021 ? 004 Federal Agency: Department of Education Federal Program Title: Coronavirus Aid, Relief and Economic Security Act ? Higher Education Emergency Relief Fund ? Student & Institution Portions Assistance Listing Number: 84.425E ? Student Aid Portion 84.425F ? Institutional Portion Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. 1) Quarterly public reporting for institutional requires a new, separate form to be posted covering aggregate amounts spent for HEERF I, HEERF II, and HEERF III funds each quarterly reporting period due no later than 10 days after the end of each calendar quarter. 2) The quarterly public reporting for the student aid portion requires certain information to be posted on the website no later than 10 days after the end of each calendar quarter Condition: During our testing of the quarterly public reports for the institutional and student aid portion, we identified the University did not post three of the four quarterly institutional reports and posted one quarterly institutional past the 10 day requirement. For the student aid portion, we tested two of the four quarterly reports, and identified they were published on the University?s website, however, there was no documentation for when this information was posted or updated within 10 days after the end of the quarter-end. Questioned Costs: None Context: During our testing of the quarterly public reports for the institutional and student aid portion, we noted that the University was not posting the required quarterly public reports within 10 days of the calendar quarter. Cause: The University did not have processes in place to submit the quarterly public reports for the institutional and student aid portion to their website. Effect: Failure to file the required reports timely may result in the loss of funding. Repeat Finding: No. Recommendation: We recommend the University enhances its procedures, controls, and review policies around CARES Act and the CRRSAA reporting requirement. Views of responsible officials: There is no disagreement with the audit finding.
2021-004 Coronavirus Aid, Relief and Economic Security Act -Higher Education Emergency Relief Fund-Student & Institution Portions -Assistance Listing No. 84.425E & 84.425F Recommendation: We recommend the University enhances its procedures, controls, and review policies around CARES Act and the CRRSAA reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. In response to evolving requirements for CARES Act and the CRRSAA reporting and to address recent turnover within the Grants Accountant position responsible for reporting, the following policies and procedures have been implemented. By the 5th business day following the end of each calendar quarter the Grants Accountant will present a full accounting of CARES Act and CRRSAA transactions which have taken place during the previous quarter to the VP of Finance and Administration and receive approval for presentation submission. By the 10th day of the month following the end of each calendar quarter the Grants Accountant will ensure the appropriate and approved reporting has been posted to the Lincoln website and that the posting includes verification of the posting date. The CARES Act and the CRRSAA required reporting through that of the most recent calendar quarter ended is current on the Lincoln website. Sharon Falade, Grants Accountant Email: sfalade@lincoln.edu Completion Date: March 2022 If the Department of Education has questions regarding this plan, please call Chuck Gradowski, Vice President, Division of Finance & Administration, at 484-365-8049.
FAC accepted this audit on March 18, 2021 — management decision was due September 18, 2021.
FAC accepted this audit on November 19, 2019 — management decision was due May 19, 2020.
Finding 2019-001 ? U.S. Department of Education - Student Financial Aid Cluster - July 1, 2018 - June 30, 2019 Criteria: The compliance supplement requires the University to protect student financial aid information. Further it requires the University to have a designated individual to coordinate the information security program, perform a risk assessment for the areas as noted in the compliance supplement, and document a safeguard for each risk identified. Condition and Context: For the fiscal year ended June 30, 2019, the University did not designate an information security officer, perform a risk assessment review or document safeguards for each risk identified from its risk assessment. Cause: The University did not complete the single audit compliance supplement requirements for the fiscal year ended June 30, 2019, because of the timing of when the supplement was issued. Questioned Costs: Not Applicable Recommendation: We recommend the University designate an individual as its information security officer, perform a risk assessment, and document safeguards for each risk identified from its risk assessment. Management Response: Management agrees with the finding. See schedule of corrective actions. Repeat Finding: No
Show full finding ▾Hide full finding ▴Finding 2019-001 ? U.S. Department of Education - Student Financial Aid Cluster - July 1, 2018 - June 30, 2019 Criteria: The compliance supplement requires the University to protect student financial aid information. Further it requires the University to have a designated individual to coordinate the information security program, perform a risk assessment for the areas as noted in the compliance supplement, and document a safeguard for each risk identified. Condition and Context: For the fiscal year ended June 30, 2019, the University did not designate an information security officer, perform a risk assessment review or document safeguards for each risk identified from its risk assessment. Cause: The University did not complete the single audit compliance supplement requirements for the fiscal year ended June 30, 2019, because of the timing of when the supplement was issued. Questioned Costs: Not Applicable Recommendation: We recommend the University designate an individual as its information security officer, perform a risk assessment, and document safeguards for each risk identified from its risk assessment. Management Response: Management agrees with the finding. See schedule of corrective actions. Repeat Finding: No
1. Date ? November 21, 2019 2. Finding 2019-001 ? U.S. Department of Education - Student Financial Aid Cluster - July 1, 2018 - June 30, 2019 3. Responsible Official?s Response and Corrective Action Plan ? a. Lincoln University has created a new position, Vice President of Human Resources. Jake Tanksley was hired in June 2019. He is responsible for the development of training programs at Lincoln University. b. CliftonLarsonAllen LLP (CPA firm) is in the process of finalizing a University wide risk assessment for Lincoln University. c. The results of the CliftonLarsonAllen risk assessment will be used to design a program for detecting, preventing and responding to attacks, intrusions or other system failures. Many procedures are currently in place to address these issues as well. d. The finalization of the CliftonLarsonAllen risk assessment will involve documenting safeguards for each identified risk. 4. Person Responsible for Corrective Action ? Justin McKenzie has been designated the security data officer. 5. Planned Implementation Date of Corrective Action ? The CliftonLarsonAllen risk assessment is in final draft form with implementation scheduled in the second quarter of calendar year 2020.
FAC accepted this audit on December 18, 2018 — management decision was due June 18, 2019.
FAC accepted this audit on December 20, 2017 — management decision was due June 20, 2018.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on December 1, 2016 — management decision was due June 1, 2017.
GSA_MIGRATION
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GSA_MIGRATION
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