EIN: 250981156
UEI: EJM6MLJ88NS3
Audited by: Schneider Downs & Co., Inc.
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 February 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 August 23, 2026 (11 days ago).
What is a management decision? →The College failed to report enrollment status changes to the NSLDS through the National Student Clearinghouse within the required timeframe as required under 34 CFR 668.32 for 3 of 60 students tested. Cause: The delay in the reporting of student enrollment changes was a failure in the College’s processes and controls surrounding review of exchange students’ and high school students’ reporting information. The College did not include all student enrollment changes in the clearinghouse timely. Effect or Potential Effect: A student’s enrollment status determines eligibility for in-school status, deferment and grace periods, as well as for the payment interest subsidies to FFEL Program loan holders by ED. Enrollment reporting in a timely and accurate manner is critical for effective management of the program. Changes in enrollment status were not submitted on time to the National Student Loan Data System as required under 34 CFR 668.32. This potentially caused a late conversion of student loans into repayment status. Questioned Costs: There are no questioned costs. Context: The sample selected for testing is representative of the population. Identification as a Repeat Finding, if applicable: This is not a repeat finding. Recommendation: We recommend the College implement a review over the exchange students’ and high school students’ enrollment change submission to the NSLDS. We also recommend that the College develop and document policies and procedures to ensure that all enrollment changes are reported accurately, completely and in a timely manner. Views of Responsible Officials and Planned Corrective Actions: Management concurs with this finding. See separate corrective action plan document.
Show full finding ▾Hide full finding ▴This section identifies the audit findings required to be reported by 2 CFR 200.516(a) (significant deficiencies, material weaknesses, material instances of noncompliance, including questioned costs and material abuse.) Finding 2025-001: Student Financial Assistance Cluster, Department of Education Programs Program Names: Federal Direct Student Loans Assistance Listing Numbers: 84.268 Criteria or Specific Requirement: 34 CFR section 685.309 states that once a change in student enrollment status has been received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the National Student Loan Data System (NSLDS) website. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to Federal Family Education Loan Program (FFEL) loan holders by the Department of Education (ED). Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. 34 CFR 668.32 requires that an organization report student status changes within 60 days of graduation, withdrawal, or other roster status changes. Condition: The College failed to report enrollment status changes to the NSLDS through the National Student Clearinghouse within the required timeframe as required under 34 CFR 668.32 for 3 of 60 students tested. Cause: The delay in the reporting of student enrollment changes was a failure in the College’s processes and controls surrounding review of exchange students’ and high school students’ reporting information. The College did not include all student enrollment changes in the clearinghouse timely. Effect or Potential Effect: A student’s enrollment status determines eligibility for in-school status, deferment and grace periods, as well as for the payment interest subsidies to FFEL Program loan holders by ED. Enrollment reporting in a timely and accurate manner is critical for effective management of the program. Changes in enrollment status were not submitted on time to the National Student Loan Data System as required under 34 CFR 668.32. This potentially caused a late conversion of student loans into repayment status. Questioned Costs: There are no questioned costs. Context: The sample selected for testing is representative of the population. Identification as a Repeat Finding, if applicable: This is not a repeat finding. Recommendation: We recommend the College implement a review over the exchange students’ and high school students’ enrollment change submission to the NSLDS. We also recommend that the College develop and document policies and procedures to ensure that all enrollment changes are reported accurately, completely and in a timely manner. Views of Responsible Officials and Planned Corrective Actions: Management concurs with this finding. See separate corrective action plan document.
The College’s Vice President for Academic Affairs and Dean of the College concurred with the finding identified. The College has revised its policies and procedures as follows: Historically, Student Affairs coded only those students who took a Leave of Absence during the semester (“L”) or withdrew during the semester (“W”). Student Affairs has created a new code (“N”) to track students who inform the college of their intent to withdraw at the end of a given semester. At the end of each semester, Student Affairs provides the Registrar’s Office with a report of all students who informed the college of their intent to unenroll (“L”, “W”, and “N”). Using the report, the Registrar’s Office confirms that all students have been accurately exited with the appropriate exit date and exit reason prior to submitting the final “end of term” report to the National Student Clearinghouse. This new process was implemented beginning in the Fall 2025 semester. The corrective actions will be implemented by Dr. Kristen M. Amick, Registrar. Dr. Amick’s email address is: amickkm@westminster.edu.
FAC accepted this audit on November 11, 2024 — management decision was due May 11, 2025.
FAC accepted this audit on December 20, 2023 — management decision was due June 20, 2024.
FAC accepted this audit on November 9, 2022 — management decision was due May 9, 2023.
FAC accepted this audit on November 14, 2021 — management decision was due May 14, 2022.
The College failed to report enrollment status changes to the NSLDS through the National Student Clearinghouse as required under 34 CFR 668.32 for 4 of 60 students tested. Cause: The delay in the reporting of student enrollment changes was a failure in the College?s processes and controls surrounding review of the summer enrollment reporting information. The College did not include all student enrollment changes in the summer clearinghouse scheduled upload. Effect or Potential Effect: A student?s enrollment status determines eligibility for in-school status, deferment and grace periods, as well as for the payment interest subsidies to FFEL Program loan holders by ED. Enrollment reporting in a timely and accurate manner is critical for effective management of the program. Changes in enrollment status were not submitted on time to the National Student Loan Data System as required under 34 CFR 668.32. This potentially caused a late conversion of student loans into repayment status. Questioned Costs: There are no questioned costs. Context: The sample selected for testing is representative of the population. Identification as a Repeat Finding, if applicable: This is a repeat finding. Recommendation: We recommend the College implement a review over the summer enrollment change submission to the NSLDS. We also recommend that the College develop and document policies and procedures to ensure that all enrollment changes are reported accurately, completely and in a timely manner. Views of Responsible Officials and Planned Corrective Actions: Management concurs with this finding. See separate corrective action plan document.
Show full finding ▾Hide full finding ▴"Finding 2021-001: Student Financial Assistance Cluster, Department of Education Programs Program Names: Federal Direct Student Loans CFDA Numbers: 84.268 Criteria or Specific Requirement: 34 CFR section 685.309 states that once a change in student enrollment status has been received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the National Student Loan Data System (NSLDS) website. A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to Federal Family Education Loan Program (FFEL) loan holders by the Department of Education (ED). Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. 34 CFR 668.32 requires that an organization report student status changes within 60 days of graduation, withdrawal, or other roster status changes. Condition: The College failed to report enrollment status changes to the NSLDS through the National Student Clearinghouse as required under 34 CFR 668.32 for 4 of 60 students tested. Cause: The delay in the reporting of student enrollment changes was a failure in the College?s processes and controls surrounding review of the summer enrollment reporting information. The College did not include all student enrollment changes in the summer clearinghouse scheduled upload. Effect or Potential Effect: A student?s enrollment status determines eligibility for in-school status, deferment and grace periods, as well as for the payment interest subsidies to FFEL Program loan holders by ED. Enrollment reporting in a timely and accurate manner is critical for effective management of the program. Changes in enrollment status were not submitted on time to the National Student Loan Data System as required under 34 CFR 668.32. This potentially caused a late conversion of student loans into repayment status. Questioned Costs: There are no questioned costs. Context: The sample selected for testing is representative of the population. Identification as a Repeat Finding, if applicable: This is a repeat finding. Recommendation: We recommend the College implement a review over the summer enrollment change submission to the NSLDS. We also recommend that the College develop and document policies and procedures to ensure that all enrollment changes are reported accurately, completely and in a timely manner. Views of Responsible Officials and Planned Corrective Actions: Management concurs with this finding. See separate corrective action plan document.
The College's Vice President for Academic Affairs and Dean of the College concurred with the finding identified. The College has revised its policies and procedures as follows: The Registrar's Office staff will hold a standing bi-weekly meeting to review all changes in student enrollment status. At least every 30 days, the Registrar's Office will conduct an internal audit of changes of enrollment status and document that those changes have been made with the Clearinghouse. The College's Leave of Absence and Notice of Withdrawal Forms will be amended to included spaces to verify that the National Student Clearinghouse has been notified by the Registrar's Office of the change in enrollment status and when the change was made. The Registrar's Office will henceforth provide to the auditors in advance of each audit cycle a Change of Enrollment Status report that includes all significant dates associated with students' enrollment status.
2020-001
FAC accepted this audit on April 12, 2021 — management decision was due October 12, 2021.
The College failed to report enrollment status changes to the NSLDS through the National Student Clearinghouse as required under 34 CFR 668.32 for 4 of 60 students tested. Cause: The delay in the reporting of student enrollment changes was a failure in the College?s processes and controls surrounding review of the summer enrollment reporting information. The College did not include all student enrollment changes in the summer clearinghouse scheduled upload. Effect or Potential Effect: A student?s enrollment status determines eligibility for in-school status, deferment and grace periods, as well as for the payment interest subsidies to FFEL Program loan holders by ED. Enrollment reporting in a timely and accurate manner is critical for effective management of the program. Changes in enrollment status were not submitted on time to the National Student Loan Data System as required under 34 CFR 668.32. This potentially caused a late conversion of student loans into repayment status. Questioned Costs: There are no questioned costs. Context: The sample selected for testing is representative of the population. Identification as a Repeat Finding, if applicable: This is a repeat finding. Recommendation: We recommend the College implement a review over the summer enrollment change submission to the NSLDS. We also recommend that the College develop and document policies and procedures to ensure that all enrollment changes are reported accurately, completely and in a timely manner. Views of Responsible Officials and Planned Corrective Actions: Management concurs with this finding. See separate corrective action plan document.
Show full finding ▾Hide full finding ▴Finding 2020-001: Student Financial Assistance Cluster, Department of Education Programs Program Names: Federal Direct Student Loans CFDA Numbers: 84.268 Criteria or Specific Requirement: 34 CFR section 685.309 states that once a change in student enrollment status has been received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the National Student Loan Data System (NSLDS) website. A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to Federal Family Education Loan Program (FFEL) loan holders by the Department of Education (ED). Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. 34 CFR 668.32 requires that an organization report student status changes within 60 days of graduation, withdrawal, or other roster status changes. Condition: The College failed to report enrollment status changes to the NSLDS through the National Student Clearinghouse as required under 34 CFR 668.32 for 4 of 60 students tested. Cause: The delay in the reporting of student enrollment changes was a failure in the College?s processes and controls surrounding review of the summer enrollment reporting information. The College did not include all student enrollment changes in the summer clearinghouse scheduled upload. Effect or Potential Effect: A student?s enrollment status determines eligibility for in-school status, deferment and grace periods, as well as for the payment interest subsidies to FFEL Program loan holders by ED. Enrollment reporting in a timely and accurate manner is critical for effective management of the program. Changes in enrollment status were not submitted on time to the National Student Loan Data System as required under 34 CFR 668.32. This potentially caused a late conversion of student loans into repayment status. Questioned Costs: There are no questioned costs. Context: The sample selected for testing is representative of the population. Identification as a Repeat Finding, if applicable: This is a repeat finding. Recommendation: We recommend the College implement a review over the summer enrollment change submission to the NSLDS. We also recommend that the College develop and document policies and procedures to ensure that all enrollment changes are reported accurately, completely and in a timely manner. Views of Responsible Officials and Planned Corrective Actions: Management concurs with this finding. See separate corrective action plan document.
The College's Vice President for Academic Affairs and Dean of the College concurred with the finding identified. The College has adjusted its scheduled enrollment submissions to the National Student Clearinghouse so that all student enrollment changes are reported within the required reporting periods. Also, any backdated withdrawals that occur after a semester ends will be individually submitted to the National Student Clearinghouse in order to meet the 60-day reporting requirement.
2019-001
FAC accepted this audit on November 13, 2019 — management decision was due May 13, 2020.
The College failed to report enrollment status changes to the NSLDS through the National Student Clearinghouse as required under 34 CFR 668.32 for 2 of 60 students tested. Cause: The delay in the reporting of student enrollment changes was a failure in the College?s processes and controls surrounding summer enrollment reporting. The College did not have an enrollment reporting scheduled or completed from the May graduate reporting change submission to the Fall 2019 reporting submissions. Effect or Potential effect: A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment interest subsidies to FFEL Program loan holders by ED. Enrollment reporting in a timely and accurate manner is critical for effective management of the program. Changes in enrollment status were not submitted on time to the National Student Loan Data System as required under 34 CFR 668.32. This potentially caused a late conversion of student loans into repayment status. Questioned Costs: There are no questioned costs. Context: The sample selected for testing is representative of the population. Identification as a Repeat Finding, if applicable: This is not a repeat finding. Recommendation: We recommend the College implement a summer enrollment change submission to the NSLDS. We also recommend that the College develop and document policies and procedures to ensure that all enrollment changes are reported accurately, completely and in a timely manner. Views of Responsible Officials and Planned Corrective Actions: Management concurs with this finding. See separate corrective action plan document.
Show full finding ▾Hide full finding ▴Finding 2019-001: Student Financial Assistance Cluster, Department of Education Programs Program Names: Federal Direct Student Loans CFDA Numbers: 84.268 Criteria or Specific Requirement: 34 CFR section 685.309 states that once a change in student enrollment status has been received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the National Student Loan Data System (NSLDS) website. A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to Federal Family Education Loan Program (FFEL) loan holders by the Department of Education (ED). Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. 34 CFR 668.32 requires that an organization report student status changes within 60 days of graduation, withdrawal, or other roster status changes. Condition: The College failed to report enrollment status changes to the NSLDS through the National Student Clearinghouse as required under 34 CFR 668.32 for 2 of 60 students tested. Cause: The delay in the reporting of student enrollment changes was a failure in the College?s processes and controls surrounding summer enrollment reporting. The College did not have an enrollment reporting scheduled or completed from the May graduate reporting change submission to the Fall 2019 reporting submissions. Effect or Potential effect: A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment interest subsidies to FFEL Program loan holders by ED. Enrollment reporting in a timely and accurate manner is critical for effective management of the program. Changes in enrollment status were not submitted on time to the National Student Loan Data System as required under 34 CFR 668.32. This potentially caused a late conversion of student loans into repayment status. Questioned Costs: There are no questioned costs. Context: The sample selected for testing is representative of the population. Identification as a Repeat Finding, if applicable: This is not a repeat finding. Recommendation: We recommend the College implement a summer enrollment change submission to the NSLDS. We also recommend that the College develop and document policies and procedures to ensure that all enrollment changes are reported accurately, completely and in a timely manner. Views of Responsible Officials and Planned Corrective Actions: Management concurs with this finding. See separate corrective action plan document.
The College's Vice President for Academic Affairs concurred with the finding identified. The College plans to submit additional enrollment changes during Summer of 2020. The College has enrolled in a summer submission in order to ensure that the College properly reports to the NSLDS every 60 days.
The College did not have written documentation to demonstrate its compliance with the requirements of 16 CFR 314. Cause: The exceptions noted were a result of the updated compliance requirement; the College is actively looking to become compliant with the applicable guidance. Effect or Potential effect: Without a designated individual to coordinate the information security program, a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b), and documented safeguards for identified risks, there may be inadequate safeguards of student financial aid information. Questioned Costs: There are no questioned costs. Context: The IT review performed. Identification as a Repeat Finding, if applicable: This is not a repeat finding. Recommendation: We recommend the College be in compliance with the guidance in the Compliance Supplement, as well as other federal statutes. We also recommend that the College management take responsibility for and be proactive in ensuring this compliance in applicable regulations. Views of Responsible Officials and Planned Corrective Actions: Management concurs with this finding. See separate corrective action plan document.
Show full finding ▾Hide full finding ▴Finding 2019-002: Student Financial Assistance - Cluster, Department of Education Programs Program Names: 84.007 - Federal Supplemental Educational Opportunity Grants, 84.033 - Federal Work-Study Program, 84.038 - Federal Perkins Loan, 84.063 - Federal Pell Grant Program, 84.268 - Federal Direct Student Loans, 84.379 - Teacher Education Assistance for College and Higher Education Grants (TEACH Grants) Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314). The audit finding was based on 16 CFR 314.4: (b) Identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risks in each relevant area of your operations, including: (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures. Condition: The College did not have written documentation to demonstrate its compliance with the requirements of 16 CFR 314. Cause: The exceptions noted were a result of the updated compliance requirement; the College is actively looking to become compliant with the applicable guidance. Effect or Potential effect: Without a designated individual to coordinate the information security program, a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b), and documented safeguards for identified risks, there may be inadequate safeguards of student financial aid information. Questioned Costs: There are no questioned costs. Context: The IT review performed. Identification as a Repeat Finding, if applicable: This is not a repeat finding. Recommendation: We recommend the College be in compliance with the guidance in the Compliance Supplement, as well as other federal statutes. We also recommend that the College management take responsibility for and be proactive in ensuring this compliance in applicable regulations. Views of Responsible Officials and Planned Corrective Actions: Management concurs with this finding. See separate corrective action plan document.
The College's Chief Information Officer concurred with the finding identified. The College will appoint an individual to coordinate the information security program and the College will perform a risk assessment that addresses the required areas and the College will document a safeguard for each risk identified through the risk assessment process.
FAC accepted this audit on November 12, 2018 — management decision was due May 12, 2019.
FAC accepted this audit on November 8, 2017 — management decision was due May 8, 2018.
FAC accepted this audit on November 22, 2016 — management decision was due May 22, 2017.
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