EASTERN UNIVERSITY

EIN: 231409675

UEI: HEJ8RLLYCJH5

Data as of August 26, 2026

EASTERN UNIVERSITY10 audit years13 findings4 repeat
10
Audit Years
13
Total Findings
4
Repeat Findings

FY 2025-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 30, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 30, 2026 (35 days from today).

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2025-001
Special Tests & Provisions
REPEATQUESTIONED COSTS

When students withdrew officially, the University did not always return unearned Title IV aid timely. Criteria: 34 CFR 668.22 Questioned Costs: $423 Context: Out of 60 students tested for withdrawal consideration, 2 students who withdrew during the audit period tested had funds returned late. One student was an official withdrawal for Spring 2025 and had $1,697 in federal loans returned in June 2025, 14 days late as this was caught during review of the unofficial withdrawals. The other student was an official withdrawal for Fall 2024 and the University did not complete R2T4 as required and needs to return $423 of Pell. The University is in process to review for any additional late returns for consideration. Cause: This was an oversight by the University. Effect: Noncompliance with R2T4 regulations regarding withdrawals from modular programs. Identification as repeat finding, if applicable: 2024-001 and 2023-001 Recommendation: We recommend that the University run a report of official withdrawals on a monthly basis to process R2T4's and any returns on a monthly basis to ensure those returns are done timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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Untimely Returns of Title IV Funds (R2T4) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans, 84.063 Federal Pell Grants Federal Award Identification #: 2024-2025 Financial Aid Year Condition: When students withdrew officially, the University did not always return unearned Title IV aid timely. Criteria: 34 CFR 668.22 Questioned Costs: $423 Context: Out of 60 students tested for withdrawal consideration, 2 students who withdrew during the audit period tested had funds returned late. One student was an official withdrawal for Spring 2025 and had $1,697 in federal loans returned in June 2025, 14 days late as this was caught during review of the unofficial withdrawals. The other student was an official withdrawal for Fall 2024 and the University did not complete R2T4 as required and needs to return $423 of Pell. The University is in process to review for any additional late returns for consideration. Cause: This was an oversight by the University. Effect: Noncompliance with R2T4 regulations regarding withdrawals from modular programs. Identification as repeat finding, if applicable: 2024-001 and 2023-001 Recommendation: We recommend that the University run a report of official withdrawals on a monthly basis to process R2T4's and any returns on a monthly basis to ensure those returns are done timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: As a result of the 24-25 annual audit and the Department of Education’s Program Review that is just being wrapped up now, I’ve worked with our IT department and Brightspace department on updating our data retrieval. The update to this process started in November of 2024 and concluded in May of 2025. We now have updated processes and reports in place that allow for quicker notification of withdrawals, non-attendance, and failed courses. The report is now run at least once a month to capture any changes in enrollment for students who fall into these categories. This information is also being included in the Department of Education’s Program Review response that will be submitted to them by the end of March 2026. Person Responsible for Corrective Action Plan: Andréa L. Ruth- Director of Financial Aid Anticipated Date of Completion: March 31, 2026

Prior Finding References

2024-001

About Special Tests and Provisions →

FY 2024-06-30

FAC accepted this audit on March 28, 2025 — management decision was due September 28, 2025.

2024-001
Special Tests & Provisions
REPEATQUESTIONED COSTS

When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid accurately and timely. Title IV funds disbursed were not always returned when students failed to begin attendance. Criteria: 34 CFR 668.21 and 34 CFR 668.22 Questioned Costs: $5,217 Context: Out of 60 students tested, we noted 4 students who withdrew did not have a return completed accurately and timely. These 4 students in total had $1,510 of Pell and $2,388 of Federal Direct Loans under returned and included in questioned costs. 1 student of these 4 also had a Pell adjustment error for $925 that should have been returned prior to the R2T4 calculation. Out of 60 students tested, we also noted 1 online student that did not begin attendance and received a disbursement of $1,319 of Federal Direct Loans which should have been returned entirely and is included in questioned costs. The University has corrected some of these errors during the audit and during an ED program review. Cause: This was an oversight by the University. Effect: Return of Title IV funds calculations were not performed timely and a student who did not begin attendance was disbursed aid. Identification as repeat finding, if applicable: 2023-001. Recommendation: We recommend that the University continue to work on running zero credit reports at the end of each module or semester and that these reports provide all the necessary information for financial aid to complete R2T4’s accurately and timely. We also recommend that for online students, evidence of academic engagement be required prior to disbursing aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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Incorrect Return of Title IV (R2T4) Funds Calculations and Untimely Returns Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid accurately and timely. Title IV funds disbursed were not always returned when students failed to begin attendance. Criteria: 34 CFR 668.21 and 34 CFR 668.22 Questioned Costs: $5,217 Context: Out of 60 students tested, we noted 4 students who withdrew did not have a return completed accurately and timely. These 4 students in total had $1,510 of Pell and $2,388 of Federal Direct Loans under returned and included in questioned costs. 1 student of these 4 also had a Pell adjustment error for $925 that should have been returned prior to the R2T4 calculation. Out of 60 students tested, we also noted 1 online student that did not begin attendance and received a disbursement of $1,319 of Federal Direct Loans which should have been returned entirely and is included in questioned costs. The University has corrected some of these errors during the audit and during an ED program review. Cause: This was an oversight by the University. Effect: Return of Title IV funds calculations were not performed timely and a student who did not begin attendance was disbursed aid. Identification as repeat finding, if applicable: 2023-001. Recommendation: We recommend that the University continue to work on running zero credit reports at the end of each module or semester and that these reports provide all the necessary information for financial aid to complete R2T4’s accurately and timely. We also recommend that for online students, evidence of academic engagement be required prior to disbursing aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Incorrect Return of Title IV (R2T4) Funds Calculations and Untimely Returns Planned Corrective Action: When this was identified last year, the Director of Financial Aid Office spent the next year working with the Department of Education as they conducted two separate reviews. The first review was completed and we were notified that everything was good. The second review recently concluded via an exit interview where we were notified that a final report would be sent to us within the next two months. Additionally, the Director of Financial Aid has been working with the IT department, the Registrar’s Office, and our Academic Technology department to streamline the identification of students who need a R2T4 completed. This has been an ongoing process in the midst of the program reviews and getting clarification and guidance from the Department of Education, coupled with the FAFSA issues, continued to cause further delays with R2T4 calculations. Person Responsible for Corrective Action Plan: Andrea Ruth, Director of Financial Aid Anticipated Date of Completion: 3/22/2025

Prior Finding References

2023-001

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2024-002
Special Tests & Provisions
QUESTIONED COSTS

Verification was incorrectly waived and not completed for 2 students who received need based federal aid. Criteria: 34 CFR 668.54 Questioned Costs: $28,874 Context: Out of 281 students selected for verification from the Central Processing System that had federal aid, we noted verification was not completed on 5 students that were included in our sample of 25. We noted 2 of these students that did not have verification completed were disbursed need based federal financial aid. The need based federal aid disbursed to these students included $2,990 in Pell, $7,918 in subsidized direct loans, and $1,660 in FSEOG. The students were also disbursed $3,960 in unsubsidized direct loans and $12,346 in parent plus loans. Cause: Verification was incorrectly waived in the system. There was no review process to ensure that students selected for verification with a status of verification not completed did not receive need based federal aid. Effect: Need based aid is impacted directly by the results of verification. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the University periodically review students selected for verification with a status of verification not completed to ensure they did not receive need based federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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Verification DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, and 84.007 Federal Award Identification #: 2023-2024 Award Year Condition: Verification was incorrectly waived and not completed for 2 students who received need based federal aid. Criteria: 34 CFR 668.54 Questioned Costs: $28,874 Context: Out of 281 students selected for verification from the Central Processing System that had federal aid, we noted verification was not completed on 5 students that were included in our sample of 25. We noted 2 of these students that did not have verification completed were disbursed need based federal financial aid. The need based federal aid disbursed to these students included $2,990 in Pell, $7,918 in subsidized direct loans, and $1,660 in FSEOG. The students were also disbursed $3,960 in unsubsidized direct loans and $12,346 in parent plus loans. Cause: Verification was incorrectly waived in the system. There was no review process to ensure that students selected for verification with a status of verification not completed did not receive need based federal aid. Effect: Need based aid is impacted directly by the results of verification. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the University periodically review students selected for verification with a status of verification not completed to ensure they did not receive need based federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Verification Planned Corrective Action: We will periodically review students selected for verification with a status of verification not completed to ensure they did not receive need based federal aid. Person Responsible for Corrective Action Plan: Andrea Ruth, Director of Financial Aid Anticipated Date of Completion: 3/22/2025

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FY 2023-06-30

FAC accepted this audit on March 25, 2024 — management decision was due September 25, 2024.

2023-001
Special Tests & Provisions
MATERIAL WEAKNESSREPEAT

When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely. Criteria: 34 CFR 668.22 Questioned Costs: $-0- Context: Out of 25 students tested for accurate and timely R2T4s, 5 students who withdrew during the audit period tested had $5,255 returned late. Four of the late returns were made after the fiscal year and between 160-475 days late. One return was during the fiscal year and 109 days late. Cause: This was an oversight by the University. Effect: Returns of Title IV funds were not performed timely. Identification as repeat finding, if applicable: 2022-002 Recommendation: We recommend a zero-credit report be run at the end of each semester to ensure all unofficial withdrawals are followed up on so that R2T4s are completed timely when required. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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Untimely Returns of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid timely. Criteria: 34 CFR 668.22 Questioned Costs: $-0- Context: Out of 25 students tested for accurate and timely R2T4s, 5 students who withdrew during the audit period tested had $5,255 returned late. Four of the late returns were made after the fiscal year and between 160-475 days late. One return was during the fiscal year and 109 days late. Cause: This was an oversight by the University. Effect: Returns of Title IV funds were not performed timely. Identification as repeat finding, if applicable: 2022-002 Recommendation: We recommend a zero-credit report be run at the end of each semester to ensure all unofficial withdrawals are followed up on so that R2T4s are completed timely when required. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: Determining the last date of academically related activity for Return of Title IV Funds was identified as a finding from last audit year (2021-2022). A Department of Education review was completed and once this was done and determined that we made the proper adjustments for 21-22, a complete and detailed review for 22-23 to correct any incorrect R2T4’s was completed. This resulted in untimely returns but has since been resolved. Person Responsible for Corrective Action Plan: Andrea Ruth, Director of Financial Aid Anticipated Date of Completion: August 2023

Prior Finding References

2022-002

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2023-002
Special Tests & Provisions

The University did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not updated its written information security program in alignment with the revised regulations; sufficiently documented its security risk assessment and safeguards, including general threats; implemented multi-factor authentication on systems containing personally identifiable information (PII); implemented continuous monitoring, such as penetration testing and vulnerability scanning; implemented sufficient vendor management policies and reviews; implemented an incident response plan; or provided a written, annual report to the board. Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA. Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not updated its written information security program in alignment with the revised regulations; sufficiently documented its security risk assessment and safeguards, including general threats; implemented multi-factor authentication on systems containing personally identifiable information (PII); implemented continuous monitoring, such as penetration testing and vulnerability scanning; implemented sufficient vendor management policies and reviews; implemented an incident response plan; or provided a written, annual report to the board. Cause: The University has not allocated sufficient resources to address and document compliance with the updated requirements of GLBA. Effect: The University has not adequately addressed the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The University concurs with the audit finding of partial compliance and recognizes the need to fully comply with GLBA regulations. The University has updated its written risk assessment. The University is working on improving safeguards, improving continuous monitoring provided from a vendor, implementing procedures for staff training which will be required for all employees, implementing procedures for assessing service providers, documenting an incident response plan, and completing a written annual status report to the board. Person Responsible for Corrective Action Plan: Eric McCloy, CIO Anticipated Date of Completion: April 30, 2024. Board report will be June 30, 2024.

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2023-003
Eligibility
REPEATQUESTIONED COSTS

Pell was not awarded based on enrollment status and Expected Family Contribution (EFC). Criteria: 34 CFR 690.63(b) Questioned Costs: $58 Context: Out of 42 students tested, two students were under awarded Pell based on their enrollment level. The total amount of Pell under awards was $1,885. One student was over awarded $58 in Pell due to the incorrect EFC being used. Cause: The over award of Pell was an oversight by the University. The under awards of Pell were students who changed enrollment status and did not have Pell adjusted accordingly. Effect: Students not awarded Pell based on eligibility. Identification as repeat finding, if applicable: 2022-004 Recommendation: We recommend a process be used to adjust the Pell formula used to be paid in alignment with enrollment status. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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Incorrect Pell Calculations DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Pell was not awarded based on enrollment status and Expected Family Contribution (EFC). Criteria: 34 CFR 690.63(b) Questioned Costs: $58 Context: Out of 42 students tested, two students were under awarded Pell based on their enrollment level. The total amount of Pell under awards was $1,885. One student was over awarded $58 in Pell due to the incorrect EFC being used. Cause: The over award of Pell was an oversight by the University. The under awards of Pell were students who changed enrollment status and did not have Pell adjusted accordingly. Effect: Students not awarded Pell based on eligibility. Identification as repeat finding, if applicable: 2022-004 Recommendation: We recommend a process be used to adjust the Pell formula used to be paid in alignment with enrollment status. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Incorrect Pell Calculations Planned Corrective Action: All of our undergraduate programs now follow a similar calendar pattern and enrollment requirements which will prevent issues when a student switches from one type of program to another. Person Responsible for Corrective Action Plan: Andrea Ruth, Director of Financial Aid Anticipated Date of Completion: Completed

Prior Finding References

2022-004

About Eligibility →

FY 2022-06-30

FAC accepted this audit on March 27, 2023 — management decision was due September 27, 2023.

2022-001
Special Tests & Provisions
MATERIAL WEAKNESSQUESTIONED COSTS

The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $47,676 Context: In the current year, we found several areas of noncompliance with the Department of Education regulations due to the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department experienced turnover in staffing as well as changes in regulations in the same year while responding to the COVID-19 crisis and applicable waivers. The transmission of information from the online course platform to the financial aid system did not capture the needed information for compliance, and several critical processes required manual entry. Effect: Noncompliance with a number of Title IV regulations. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the financial aid system and online course platform integration and create a cheat sheet of applicable COVID-19 waivers for each award year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2021-22 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $47,676 Context: In the current year, we found several areas of noncompliance with the Department of Education regulations due to the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department experienced turnover in staffing as well as changes in regulations in the same year while responding to the COVID-19 crisis and applicable waivers. The transmission of information from the online course platform to the financial aid system did not capture the needed information for compliance, and several critical processes required manual entry. Effect: Noncompliance with a number of Title IV regulations. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the financial aid system and online course platform integration and create a cheat sheet of applicable COVID-19 waivers for each award year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Lack of Administrative Capability Planned Corrective Action: We have re-reviewed the COVID waivers and made the necessary notes and documentation in our records. Our office is actively recruiting an additional aid counselor to assist with the increased workload due to our significant jump in enrollment (up 52% in the last two years). We are working with our Registrar, Assistant Provost, Brightspace Administrator, and IT to ensure our system is reporting the right information at the right time to the right departments. We have sought guidance from our Department of Education representative in Philadelphia to make sure we are interpreting regulations and guidelines appropriately. We have changed our policies for this upcoming 2023-2024 school year to not disburse any aid until after all of our terms for a given semester have passed their add/drop periods so we can ensure that each student has actively started their program, is continuing to be an active participant, and if not, that we take the necessary steps to adjust or cancel their aid appropriately. This is not something that we take lightly and are determined to correct these issues and take additional preventative measures so that they do not happen again. Person Responsible for Corrective Action Plan: Andrea L Ruth, Director of Financial Aid Anticipated Date of Completion: 4/1/2023

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2022-002
Special Tests & Provisions
MATERIAL WEAKNESSQUESTIONED COSTS

The transmission of information from the online platform included activity that did not meet the definition of academic activity resulting in students not having a correct calculation performed. Additionally, the new modular regulations were not correctly applied. Criteria: 34 CFR 668.22 Questioned Costs: $29,626 Context: Out of 31 students, 16 students who withdrew during the audit period tested had an incorrect return or lack of return. Four students did not have academic activity as defined in the regulation for their online course, and all funds should be returned for that term. Nine students, of which the majority was online modular students not a meeting withdrawal exemption, did not complete past 60% of the semester and should have had funds returned. Two students did not have academic activity as defined in the regulations for an online course and should have had Pell recalculated. One student had an incorrect calculation due to an incorrect scheduled break calculation. Cause: The programming in the online platform for meeting the definition of academic activity was not accurately set up for the 2021-2022 award year and inadvertently included any activity such as just logging in. If the student attended a second module without completing the first module, all days of the first module were counted as attended instead of the actual attended days. There was an oversight in a calendar set up for a scheduled break as well as using the date of determination as the withdrawal date rather than the last date of attendance. Effect: Noncompliance with new R2T4 regulations regarding withdrawals from modular programs and incorrect returns. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the programming of the transmission of confirming attendance be specific to the regulations. We further recommend that federal aid is not disbursed to a student until academic activity in a class has been confirmed. We recommend the last date of academic activity be shared with the financial aid team systematically so calculations on all 0 credit students can be done timely. Should a student not begin attendance in an online class, we recommend the Pell be recalculated and returned immediately. We further recommend an additional layer of review on the calendar set up process. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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Return of Title IV (R2T4) Calculations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The transmission of information from the online platform included activity that did not meet the definition of academic activity resulting in students not having a correct calculation performed. Additionally, the new modular regulations were not correctly applied. Criteria: 34 CFR 668.22 Questioned Costs: $29,626 Context: Out of 31 students, 16 students who withdrew during the audit period tested had an incorrect return or lack of return. Four students did not have academic activity as defined in the regulation for their online course, and all funds should be returned for that term. Nine students, of which the majority was online modular students not a meeting withdrawal exemption, did not complete past 60% of the semester and should have had funds returned. Two students did not have academic activity as defined in the regulations for an online course and should have had Pell recalculated. One student had an incorrect calculation due to an incorrect scheduled break calculation. Cause: The programming in the online platform for meeting the definition of academic activity was not accurately set up for the 2021-2022 award year and inadvertently included any activity such as just logging in. If the student attended a second module without completing the first module, all days of the first module were counted as attended instead of the actual attended days. There was an oversight in a calendar set up for a scheduled break as well as using the date of determination as the withdrawal date rather than the last date of attendance. Effect: Noncompliance with new R2T4 regulations regarding withdrawals from modular programs and incorrect returns. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University adjust the programming of the transmission of confirming attendance be specific to the regulations. We further recommend that federal aid is not disbursed to a student until academic activity in a class has been confirmed. We recommend the last date of academic activity be shared with the financial aid team systematically so calculations on all 0 credit students can be done timely. Should a student not begin attendance in an online class, we recommend the Pell be recalculated and returned immediately. We further recommend an additional layer of review on the calendar set up process. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Return of Title IV (R2T4) Calculations Planned Corrective Action: I met with our Registrar, our Brightspace Administrator, our Assistant Provost and a faculty member of our Data Science department to collaborate on how to properly identify and document online student?s attendance, participation, and activity. We have already crafted a report that captures this information and we will continue to add to this report and utilize it for the current year to determine any adjustments that need to be made to Federal Student Aid. We are meeting again this week to discuss and finalize this report and test it out repeatedly to ensure it captures the right information every time. Person Responsible for Corrective Action Plan: Andrea L Ruth, Director of Financial Aid Anticipated Date of Completion: 4/1/2023

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2022-003
Reporting
MATERIAL WEAKNESS

The University did not accurately report their student grant information and institutional expenditures on the HEERF Annual Report for the calendar year 2021. Criteria: 2 CFR 200.329 Questioned Costs: $-0- Context: During the audit, it was identified that the University did not accurately report the total student grants and institutional expenses in the HEERF annual report. The University reviewed what was reported and corrected the report during the audit process. Cause: There was a transition in the key personnel completing the annual report, and part of the information used did not have the correct parameters for the calendar year 2021. Effect: The amounts reported on the annual report to the Department did not agree to the underlying records of the University or the quarterly reports prepared by the University. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University amend the 2021 annual report when the 2022 reporting cycle opens up the portal. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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Higher Education Stabilization Fund Reporting Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.425E, 84.425F, 84.425L Federal Award Identification #: P425E202018, P425F202629, P425L200204 Condition: The University did not accurately report their student grant information and institutional expenditures on the HEERF Annual Report for the calendar year 2021. Criteria: 2 CFR 200.329 Questioned Costs: $-0- Context: During the audit, it was identified that the University did not accurately report the total student grants and institutional expenses in the HEERF annual report. The University reviewed what was reported and corrected the report during the audit process. Cause: There was a transition in the key personnel completing the annual report, and part of the information used did not have the correct parameters for the calendar year 2021. Effect: The amounts reported on the annual report to the Department did not agree to the underlying records of the University or the quarterly reports prepared by the University. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University amend the 2021 annual report when the 2022 reporting cycle opens up the portal. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Higher Education Stabilization Fund Reporting Planned Corrective Action: I have worked with our IT department, specifically the individual that works closely with Financial Aid reports and data, to ensure I have received accurate data in order to correct this report. The IT person who initially provided me with the information for the report is no longer in that department. Additionally, I am working with our former CFO who still works for Eastern on Special Projects to submit the Year 3 report. We are sharing our data with our new CFO and our Director of Accounting and Finance to help close the information gap. Person Responsible for Corrective Action Plan: Andrea L Ruth, Director of Financial Aid Anticipated Date of Completion: 3/24/2023

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2022-004
Eligibility

3 students out of 32 were not properly awarded Pell based on enrollment status. Criteria: 34 CFR 690.63(b) Questioned Costs: $-0- Context: Two students were student teaching in one semester and were not properly classified as traditional students during that semester, resulting in underawards of Pell of $2,018. Additionally, one student was incorrectly classified for the summer sessions and was underawarded Pell of $1,625. Cause: One financial aid counselor did not identify the transition in student type to apply the correct Pell formula. Effect: There was an incorrect amount of Pell paid to these three students. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend a process be used to adjust the Pell formula used to be in alignment with the type of student for that semester. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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Incorrect Pell Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: 3 students out of 32 were not properly awarded Pell based on enrollment status. Criteria: 34 CFR 690.63(b) Questioned Costs: $-0- Context: Two students were student teaching in one semester and were not properly classified as traditional students during that semester, resulting in underawards of Pell of $2,018. Additionally, one student was incorrectly classified for the summer sessions and was underawarded Pell of $1,625. Cause: One financial aid counselor did not identify the transition in student type to apply the correct Pell formula. Effect: There was an incorrect amount of Pell paid to these three students. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend a process be used to adjust the Pell formula used to be in alignment with the type of student for that semester. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Incorrect Pell Calculations Planned Corrective Action: The Financial Aid Counselor that missed making these adjustments is no longer working in our office. Additionally, effective with the 23-24 school year, we as a University have chosen to align our enrollment requirements among undergraduate programs so as not to cause any further confusion or mistakes when a student switches from one program to another. Person Responsible for Corrective Action Plan: Andrea L Ruth, Director of Financial Aid Anticipated Date of Completion: 1/1/2023

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2022-005
Eligibility
QUESTIONED COSTS

The University missed requiring a formal satisfactory academic progress (SAP) appeals for one student. Criteria: 34 CFR 668.34(c) Questioned Costs: $7,676 Context: 1 student out of 12 tested was awarded federal aid but was ineligible due to not making SAP and did not have an approved appeal to reinstate eligibility. The University returned the federal aid during the audit process. Cause: There was an oversight of requiring an appeal for a student not making SAP. Effect: An ineligible student was awarded federal aid. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University ensure those students who were not meeting SAP have an approved appeal documented prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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Satisfactory Academic Progress Appeals DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The University missed requiring a formal satisfactory academic progress (SAP) appeals for one student. Criteria: 34 CFR 668.34(c) Questioned Costs: $7,676 Context: 1 student out of 12 tested was awarded federal aid but was ineligible due to not making SAP and did not have an approved appeal to reinstate eligibility. The University returned the federal aid during the audit process. Cause: There was an oversight of requiring an appeal for a student not making SAP. Effect: An ineligible student was awarded federal aid. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University ensure those students who were not meeting SAP have an approved appeal documented prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Satisfactory Academic Progress Appeals Planned Corrective Action: This particular student mistakenly received a record that indicated that they had passed Satisfactory Academic Progress as well as failed passing Satisfactory Academic Progress. This issue has been fixed and the affected student had their Federal Aid removed and replaced with Eastern University aid. Person Responsible for Corrective Action Plan: Andrea L Ruth, Director of Financial Aid Anticipated Date of Completion: 2/1/2023

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2022-006
Special Tests & Provisions
QUESTIONED COSTS

Students selected for V4 verification inappropriately had the full V1 waiver applied. Criteria: 34 CFR 668.56 Questioned Costs: $10,374 Context: Out of 6 tested for the V4 or V5 flag of verification, 2 students did not have a statement of educational purpose on file. These students were corrected during the audit process. Cause: The waiver for verification only applied to the V1 portion of the flag but was inadvertently applied to the whole V4 flag. Effect: These students were not eligible for federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University obtain the signed statement of educational purpose, ID, and required transcripts for the V4 flag prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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Verification DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.379 Federal Award Identification #: 2021-22 Financial Aid Year Condition: Students selected for V4 verification inappropriately had the full V1 waiver applied. Criteria: 34 CFR 668.56 Questioned Costs: $10,374 Context: Out of 6 tested for the V4 or V5 flag of verification, 2 students did not have a statement of educational purpose on file. These students were corrected during the audit process. Cause: The waiver for verification only applied to the V1 portion of the flag but was inadvertently applied to the whole V4 flag. Effect: These students were not eligible for federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University obtain the signed statement of educational purpose, ID, and required transcripts for the V4 flag prior to disbursing federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Verification Planned Corrective Action: We have reviewed our Verification report and made the necessary adjustments to ensure that all of the correct information is included on each and every report. This will allow us to confirm that only those students who have completed all necessary paperwork for their particular Verification flag have been cleared to have Financial Aid disbursed to their account. The affected students had their Federal Aid removed and replaced with Eastern University aid. Person Responsible for Corrective Action Plan: Andrea L Ruth, Director of Financial Aid Anticipated Date of Completion: 3/1/2023

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FY 2017-06-30

FAC accepted this audit on January 25, 2018 — management decision was due July 25, 2018.

2017-001
Special Tests & Provisions

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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