Valor Christian CollegeHigher Education

EIN: 271625785

UEI: JZ64U6ZQ9RX8

Audited by: Clark Schaefer Hackett

Oversight agency: 84 [Department of Education]

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Data as of August 28, 2026

Valor Christian College11 audit years21 findings3 repeat
11
Audit Years
21
Total Findings
3
Repeat Findings
$5.2M
Federal Awards Expended (FY 2025)

FY 2025-06-30

$5,237,512 federal awards expendedNo findings recorded this year

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 (32 days from today).

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FY 2024-06-30

$4,310,696 federal awards expended

FAC accepted this audit on March 31, 2025 — management decision was due October 1, 2025.

2024-001
Eligibility
OTHER MATTERS

We tested forty files, thirty-six of which were Federal Direct Loan recipients, and two students did not receive the full amount of their Federal Direct Subsidized Loans. We consider this finding to be a instance of noncompliance. Cause: The condition was caused by using an incorrect grade level for one student and by not maximizing full subsidized loan eligibility prior to packaging unsubsidized loans for the other student. Effect or Potential Effect: The result is students received unsubsidized loans prior to receiving full subsidized loans. Statistical sampling was not used when making sample selections. Questioned Costs : $0 Recommendation: We recommend the College reclassify $2,124 from unsubsidized to subsidized and increase controls over packaging direct loans. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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FINDING 2024-001: UNDERAWARDED FEDERAL DIRECT SUBSIDIZED LOANS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: SFA CLUSTER ALN: 84.268 FEDERAL AWARD YEAR: 2022-2023, 2023-2024 Compliance Requirement: Eligibility (E.) Criteria: A second year student can receive up to $4,500 in subsidized loans in one academic year (34 CFR 685.203). Condition: We tested forty files, thirty-six of which were Federal Direct Loan recipients, and two students did not receive the full amount of their Federal Direct Subsidized Loans. We consider this finding to be a instance of noncompliance. Cause: The condition was caused by using an incorrect grade level for one student and by not maximizing full subsidized loan eligibility prior to packaging unsubsidized loans for the other student. Effect or Potential Effect: The result is students received unsubsidized loans prior to receiving full subsidized loans. Statistical sampling was not used when making sample selections. Questioned Costs : $0 Recommendation: We recommend the College reclassify $2,124 from unsubsidized to subsidized and increase controls over packaging direct loans. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

FINDING 2024-001: UNDERAWARDED FEDERAL DIRECT SUBSIDIZED LOANS- the auditor tested forty files, thirty-six of which were Federal Direct Loan recipients, and two students did not receive the full amount of their Federal Direct Subsidized Loans. It is recommended the College reclassify $2,124 from unsubsidized to subsidized and increase controls over packaging direct loans. Comments on Finding and Recommendation(s): We concur with the finding and we believe that these account represent a unique situtation. Actions Taken or Planned: For A1, Valor was able to rectify the account because it was within the 180-day limit. We have implemented an internal audit process that takes place twice each semester to reconcile federal aid awarded with the appropriate aid based on enrollment status and grade level. For A-2, Value is unable to reallocate subsidized and unsubsidized awards for the second student as the 180-day limit has passed. The student was awarded the correct total amount of aid. Moving forward, Valor will generate an NSLDS report whenever a 258 ISIR code appears on the ISIR to ensure proper aid allocation.

About Eligibility →
2024-002
Special Tests & Provisions
OTHER MATTERS

We tested forty files, twenty-three of which had credit balances, and one credit balance was not paid in a timely manner. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by an oversight in the financial aid department. Effect or Potential Effect: As a result, the Institution was holding funds that needed to be returned to the student. Statistical sampling was not used when making sample selections. Questioned Costs : $0 Recommendation: We recommend the College increase controls over credit balances. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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FINDING 2024-002: UNTIMELY PAID CREDIT BALANCE FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: SFA CLUSTER ALN: 84.268 FEDERAL AWARD YEAR: 2023-2024 Compliance Requirement: Special Tests and Provisions - Disbursements (N.) Criteria: An institution must pay credit balances to students within fourteen days of the creation of such credit or within fourteen days of the date the institution performs the Return calculation for withdrawn students (34 CFR 668.164 and 668.165). Condition: We tested forty files, twenty-three of which had credit balances, and one credit balance was not paid in a timely manner. We consider this finding to be an instance of non-compliance. Cause: The condition was caused by an oversight in the financial aid department. Effect or Potential Effect: As a result, the Institution was holding funds that needed to be returned to the student. Statistical sampling was not used when making sample selections. Questioned Costs : $0 Recommendation: We recommend the College increase controls over credit balances. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

FINDING 2024-002: UNTIMELY PAID CREDIT BALANCE- the auditor tested forty files, twenty-three of which had credit balances, and one credit balance was not paid in a timely manner. It is recommended the College increase controls over credit balances. Comments on Finding and Recommendation(s): We concur with the finding and we believe that htis a unique situtaiton be we can create a revised review process. Actions Taken or Plannded: To address discrepancies in the student refund check process and prevent late returns the Finance Office will implement a structured verification and tracing procedure. After the Financial Aid office approves the calcuation sheets for refunds, a POPULI report capturing all credit balances from the start of the term to the latest financial aid disbursement will be generated. Finance Office will cross-reference refunds in process to determine completeness.

About Special Tests and Provisions →

FY 2023-06-30

$2,997,050 federal awards expended

FAC accepted this audit on March 28, 2024 — management decision was due September 28, 2024.

2023-001
Special Tests & Provisions
MATERIAL WEAKNESSQUESTIONED COSTS

We tested twelve drop students and found three incorrect refund calculation. We consider this finding to be a material weakness. Cause: The condition was caused by using an incorrect amount of days in Step 2 of the Return to Title IV refund calculation for one student and by not fully returning inadvertent overpayments of loans for the other two students. Effect or Potential Effect: The result is the College refunded incorrect amounts. Statistical sampling was not used when making sample selections. Questioned Costs : $1,048 Recommendation: As $1,048 has since been refunded to the Department of Education, we recommend the Institution review the remaining refunds for accuracy and increase controls over refunds. There is no liability for the remaining $78, as this was caused by over-refunding loans. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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FINDING 2023-001: INCORRECT REFUND CALCULATIONS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: SFA CLUSTER ALN: 84.063, 84.268 FEDERAL AWARD YEAR: 2021-2022, 2022-2023 Compliance Requirement: Special Tests and Provisions - Return of Title IV Funds (N.) Criteria: An institution must use the Return to Title IV refund calculation (34 CFR 668.22). Condition: We tested twelve drop students and found three incorrect refund calculation. We consider this finding to be a material weakness. Cause: The condition was caused by using an incorrect amount of days in Step 2 of the Return to Title IV refund calculation for one student and by not fully returning inadvertent overpayments of loans for the other two students. Effect or Potential Effect: The result is the College refunded incorrect amounts. Statistical sampling was not used when making sample selections. Questioned Costs : $1,048 Recommendation: As $1,048 has since been refunded to the Department of Education, we recommend the Institution review the remaining refunds for accuracy and increase controls over refunds. There is no liability for the remaining $78, as this was caused by over-refunding loans. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

A: COMMENTS ON FINDING AND RECOMMENDATION(S): VALOR CHRISTIAN COLLEGE OCCURS WITH THE FINDING B: ACTIONS TAKEN OR PLANNED: VALOR COLLEGE WILL INCREASE CONTROLS OVER INADVERTENT OVERPAYMENTS CREATED WHEN A STUDENT WITHDRAWS WITHOUT NOTIFICATION AFTER THE FUNDS HAVE BEEN ORDERED BUT BEFORE THEY DISBURSE. VALOR COLLEGE HAS REFUNDED $1,048 DUE FOR THE INCORRECT REFUNDS. FOR THE R2T4, CAMPUS IVY HAS ADDED A SECOND LAYER OF REVIEW TO THE R2T4 PROCESS. THE CURRENT CAMPUS IVY POLICY IS TO REQUIRE THE CLIENT TO SUBMIT A REFUND REQUEST FORM FOR ANY INELIGIBLE FUNDS THAT WERE DISBURSED, ALONG WITH THE R2T4. IF THE STUDENT IS THEN DUE A PWD, THE FUNDS WOULD THEN BE RESCHEDULED BASED ON THE R2T4 AND OFFERED TO THE STUDENT. THIS WILL PREVENT THE RETENTION OF INELIGIBLE FUNDS.

About Special Tests and Provisions →
2023-002
Special Tests & Provisions
MATERIAL WEAKNESSQUESTIONED COSTS

We tested twelve drop students and noted three late refunds. We consider this finding to be a material weakness. Cause: The condition was caused by a breakdown in controls over paying refunds. Effect or Potential Effect: The result is the College retained funds which should have been returned to the Department of Education. Statistical sampling was not used when making sample selections. Questioned Costs : $10,739 Recommendation: We recommend the College review the remaining refunds for timeliness, post a letter of credit to remain compliant and increase controls over refunds. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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FINDING 2023-002: LATE REFUNDS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: SFA CLUSTER ALN: 84.063, 84.268 FEDERAL AWARD YEAR: 2021-2022, 2022-2023 Compliance Requirement: Special Tests and Provisions - Return of Title IV Funds (N.) Criteria: The Department of Education requires that all refunds be made within 45 days of a student’s withdrawal (34 CFR 668.22, 685.306). Condition: We tested twelve drop students and noted three late refunds. We consider this finding to be a material weakness. Cause: The condition was caused by a breakdown in controls over paying refunds. Effect or Potential Effect: The result is the College retained funds which should have been returned to the Department of Education. Statistical sampling was not used when making sample selections. Questioned Costs : $10,739 Recommendation: We recommend the College review the remaining refunds for timeliness, post a letter of credit to remain compliant and increase controls over refunds. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

A: COMMENTS ON FINDING AND RECOMMENDATION(S): VALOR CHRISTIAN COLLEGE OCCURS WITH THE FINDING B: ACTIONS TAKEN OR PLANNED: VALOR COLLEGE HAS IMPLEMENTED A POLICY THAT WILL INCREASE AWARENESS OF STUDENTS WHO STOP ATTENDING THEIR COURSES. THEY POLICY CONTAINS TIGHTER RESTRICTIONS ON THE TRACKING OF ATTENDANCE AND WITHDRAWAL OF STUDENTS WHO FAIL TO PARTICIPATE. IN ADDITION, CAMPUS IVY HAS SCHEDULED A WEEKLY REVIEW OF RETURN OF TITLE IV FORMS TO ENSURE REFUNDS AND POST WITHDRAWAL DISBURSEMENTS ARE SCHEDULED IN A TIMELY MANNER.

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FY 2022-06-30

$3,793,276 federal awards expended

FAC accepted this audit on October 10, 2023 — management decision was due April 10, 2024.

2022-001
Activities Allowed or Unallowed
MATERIAL WEAKNESSQUESTIONED COSTS

The Institution charged unallowable costs to the Institution portion of the grant. We consider this finding to be a material weakness. Cause: The condition was caused by administrative oversight. Effect or Potential Effect: The result is that the Institution expended unallowable costs. Statistical sampling was not used when making sample selections. Questioned Costs: $73,594 Recommendation: We recommend the Institution strengthen its internal controls around the allowable. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan. See Schedule of Findings and Questioned Costs for chart/table.

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FINDING 2022-001: UNALLOWABLE QUESTIONED COSTS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HEERF CLUSTER ALN: 84.425 FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Activities Allowed and Unallowed (A.) Criteria: An Institution must demonstrate that costs incurred are allowable under the relevant statutory provisions. Allowable costs must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 C.F.R. part 200, subpart E. Condition: The Institution charged unallowable costs to the Institution portion of the grant. We consider this finding to be a material weakness. Cause: The condition was caused by administrative oversight. Effect or Potential Effect: The result is that the Institution expended unallowable costs. Statistical sampling was not used when making sample selections. Questioned Costs: $73,594 Recommendation: We recommend the Institution strengthen its internal controls around the allowable. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan. See Schedule of Findings and Questioned Costs for chart/table.

Corrective Action Plan

Comments on Findings and Recommendations. Finding 2022-001 Valor Christian College concurs with the finding and recommendations in the finding. Actions Taken or Planned: Finding 2022-001 - The Valor Christian College Finance Department and the Valor Christian College CFO will increase controls over the process to ensure that no recruitment advertising expenses are attributed to CARES ACT funds. The amount of originally attributed to advertising expenses has been reallocated to allowable items/expenses.

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2022-001
Activities Allowed or Unallowed
MATERIAL WEAKNESS

The Institution charged unallowable costs to the Institution portion of the grant. We consider this finding to be a material weakness. Cause: The condition was caused by administrative oversight. Effect or Potential Effect: The result is that the Institution expended unallowable costs. Statistical sampling was not used when making sample selections. Questioned Costs : $73,594 Recommendation: We recommend the Institution strengthen its internal controls around the allowable costs. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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UNALLOWABLE QUESTIONED COSTS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HEERF ALN: 84.425 FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Activities Allowed and Unallowed (A.) Criteria: An Institution must demonstrate that costs incurred are allowable under the relevant statutory provisions. Allowable costs must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 C.F.R. part 200, subpart E. Condition: The Institution charged unallowable costs to the Institution portion of the grant. We consider this finding to be a material weakness. Cause: The condition was caused by administrative oversight. Effect or Potential Effect: The result is that the Institution expended unallowable costs. Statistical sampling was not used when making sample selections. Questioned Costs : $73,594 Recommendation: We recommend the Institution strengthen its internal controls around the allowable costs. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

Comments on Findings and Recommendations: Valor Christian College concurs with the finding and recommendations in the finding. Actions Taken or Planned: The Valor Christian College Finance Department and the Valor Christian College CFO will increase controls over the process to ensure that no recruitment advertising expenses are attributed to CARES ACT funds. The amount of orginally atrributed advertising expenses has been reallocated to allowable items/expenses.

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2022-002
Procurement & Suspension/Debarment
MATERIAL WEAKNESS

The Institution failed to implement all of the required procurement policies noted above. We consider this finding to be a material weakness. Cause: The condition was caused by administrative oversight. Effect or Potential Effect: The result is that the Institution could be expending funds that do not meet the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Statistical sampling was not used when making sample selections. Questioned Costs: $0 Recommendation: We recommend the Institution develop and implement the required procurement policies. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan. See Schedule of Findings and Questioned Costs for chart/table.

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FINDING 2022-002: INSUFFICIENT PROCUREMENT POLICY FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HEERF CLUSTER ALN: 84.425 FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Procurement and Suspension and Debarment (I.) Criteria: An Institution must have procurement policies that comply with the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Condition: The Institution failed to implement all of the required procurement policies noted above. We consider this finding to be a material weakness. Cause: The condition was caused by administrative oversight. Effect or Potential Effect: The result is that the Institution could be expending funds that do not meet the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Statistical sampling was not used when making sample selections. Questioned Costs: $0 Recommendation: We recommend the Institution develop and implement the required procurement policies. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan. See Schedule of Findings and Questioned Costs for chart/table.

Corrective Action Plan

Comments on Findings and Recommendations: Finding 2022-002 - Valor Christian College concurs with the finding and recommendations in the finding. Actions Taken or Planned: Finding 2022-002 - The Valor Christian College Finance Department and the Valor Christian College CFO have rewritten the institutional procurement policy to meet or exceed the institutional procurement policy attributes checklist.

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2022-002
Procurement & Suspension/Debarment
MATERIAL WEAKNESS

The Institution failed to implement all of the required procurement policies noted above. We consider this finding to be a material weakness. Statistical sampling was not used when making sample selections. Cause: The condition was caused by administrative oversight. Effect or Potential Effect: The result is that the Institution could be expending funds that do not meet the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Recommendation: We recommend the Institution develop and implement the required procurement policies. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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INSUFFICIENT PROCUREMENT POLICY FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HEERF ALN: 84.425 FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Procurement and Suspension and Debarment (I.) Criteria: An Institution must have procurement policies that comply with the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Condition: The Institution failed to implement all of the required procurement policies noted above. We consider this finding to be a material weakness. Statistical sampling was not used when making sample selections. Cause: The condition was caused by administrative oversight. Effect or Potential Effect: The result is that the Institution could be expending funds that do not meet the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Recommendation: We recommend the Institution develop and implement the required procurement policies. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

Comments on Findings and Recommendations: Valor Christian College concurs with the finding and recommendations in the finding. Actions Taken or Planned: The Valor Christian College Finance Department and the Valor Christian College CFO have rewritten the institutional procurement policy to meet or exceed the institutional procurement policy attributes checklist.

About Procurement and Suspension and Debarment →

FY 2022-06-30

$3,639,656 federal awards expended

FAC accepted this audit on February 15, 2023 — management decision was due August 15, 2023.

2022-001
Activities Allowed or Unallowed
MATERIAL WEAKNESSQUESTIONED COSTS

The Institution charged unallowable costs to the Institution portion of the grant. We consider this finding to be a material weakness. Cause: The condition was caused by administrative oversight. Effect or Potential Effect: The result is that the Institution expended unallowable costs. Statistical sampling was not used when making sample selections. Questioned Costs: $73,594 Recommendation: We recommend the Institution strengthen its internal controls around the allowable. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan. See Schedule of Findings and Questioned Costs for chart/table.

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FINDING 2022-001: UNALLOWABLE QUESTIONED COSTS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HEERF CLUSTER ALN: 84.425 FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Activities Allowed and Unallowed (A.) Criteria: An Institution must demonstrate that costs incurred are allowable under the relevant statutory provisions. Allowable costs must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 C.F.R. part 200, subpart E. Condition: The Institution charged unallowable costs to the Institution portion of the grant. We consider this finding to be a material weakness. Cause: The condition was caused by administrative oversight. Effect or Potential Effect: The result is that the Institution expended unallowable costs. Statistical sampling was not used when making sample selections. Questioned Costs: $73,594 Recommendation: We recommend the Institution strengthen its internal controls around the allowable. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan. See Schedule of Findings and Questioned Costs for chart/table.

Corrective Action Plan

Comments on Findings and Recommendations. Finding 2022-001 Valor Christian College concurs with the finding and recommendations in the finding. Actions Taken or Planned: Finding 2022-001 - The Valor Christian College Finance Department and the Valor Christian College CFO will increase controls over the process to ensure that no recruitment advertising expenses are attributed to CARES ACT funds. The amount of originally attributed to advertising expenses has been reallocated to allowable items/expenses.

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2022-001
Activities Allowed or Unallowed
MATERIAL WEAKNESS

The Institution charged unallowable costs to the Institution portion of the grant. We consider this finding to be a material weakness. Cause: The condition was caused by administrative oversight. Effect or Potential Effect: The result is that the Institution expended unallowable costs. Statistical sampling was not used when making sample selections. Questioned Costs : $73,594 Recommendation: We recommend the Institution strengthen its internal controls around the allowable costs. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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UNALLOWABLE QUESTIONED COSTS FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HEERF ALN: 84.425 FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Activities Allowed and Unallowed (A.) Criteria: An Institution must demonstrate that costs incurred are allowable under the relevant statutory provisions. Allowable costs must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 C.F.R. part 200, subpart E. Condition: The Institution charged unallowable costs to the Institution portion of the grant. We consider this finding to be a material weakness. Cause: The condition was caused by administrative oversight. Effect or Potential Effect: The result is that the Institution expended unallowable costs. Statistical sampling was not used when making sample selections. Questioned Costs : $73,594 Recommendation: We recommend the Institution strengthen its internal controls around the allowable costs. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

Comments on Findings and Recommendations: Valor Christian College concurs with the finding and recommendations in the finding. Actions Taken or Planned: The Valor Christian College Finance Department and the Valor Christian College CFO will increase controls over the process to ensure that no recruitment advertising expenses are attributed to CARES ACT funds. The amount of orginally atrributed advertising expenses has been reallocated to allowable items/expenses.

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2022-002
Procurement & Suspension/Debarment
MATERIAL WEAKNESS

The Institution failed to implement all of the required procurement policies noted above. We consider this finding to be a material weakness. Cause: The condition was caused by administrative oversight. Effect or Potential Effect: The result is that the Institution could be expending funds that do not meet the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Statistical sampling was not used when making sample selections. Questioned Costs: $0 Recommendation: We recommend the Institution develop and implement the required procurement policies. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan. See Schedule of Findings and Questioned Costs for chart/table.

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FINDING 2022-002: INSUFFICIENT PROCUREMENT POLICY FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HEERF CLUSTER ALN: 84.425 FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Procurement and Suspension and Debarment (I.) Criteria: An Institution must have procurement policies that comply with the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Condition: The Institution failed to implement all of the required procurement policies noted above. We consider this finding to be a material weakness. Cause: The condition was caused by administrative oversight. Effect or Potential Effect: The result is that the Institution could be expending funds that do not meet the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Statistical sampling was not used when making sample selections. Questioned Costs: $0 Recommendation: We recommend the Institution develop and implement the required procurement policies. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan. See Schedule of Findings and Questioned Costs for chart/table.

Corrective Action Plan

Comments on Findings and Recommendations: Finding 2022-002 - Valor Christian College concurs with the finding and recommendations in the finding. Actions Taken or Planned: Finding 2022-002 - The Valor Christian College Finance Department and the Valor Christian College CFO have rewritten the institutional procurement policy to meet or exceed the institutional procurement policy attributes checklist.

About Procurement and Suspension and Debarment →
2022-002
Procurement & Suspension/Debarment
MATERIAL WEAKNESS

The Institution failed to implement all of the required procurement policies noted above. We consider this finding to be a material weakness. Statistical sampling was not used when making sample selections. Cause: The condition was caused by administrative oversight. Effect or Potential Effect: The result is that the Institution could be expending funds that do not meet the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Recommendation: We recommend the Institution develop and implement the required procurement policies. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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INSUFFICIENT PROCUREMENT POLICY FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: HEERF ALN: 84.425 FEDERAL AWARD YEAR: 2021-2022 Compliance Requirement: Procurement and Suspension and Debarment (I.) Criteria: An Institution must have procurement policies that comply with the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Condition: The Institution failed to implement all of the required procurement policies noted above. We consider this finding to be a material weakness. Statistical sampling was not used when making sample selections. Cause: The condition was caused by administrative oversight. Effect or Potential Effect: The result is that the Institution could be expending funds that do not meet the compliance requirements included in 2 C.F.R. 200.318 through 200.326. Recommendation: We recommend the Institution develop and implement the required procurement policies. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

Comments on Findings and Recommendations: Valor Christian College concurs with the finding and recommendations in the finding. Actions Taken or Planned: The Valor Christian College Finance Department and the Valor Christian College CFO have rewritten the institutional procurement policy to meet or exceed the institutional procurement policy attributes checklist.

About Procurement and Suspension and Debarment →

FY 2021-06-30

LOW-RISK AUDITEE$2,972,663 federal awards expended

FAC accepted this audit on October 6, 2022 — management decision was due April 6, 2023.

2021-001
Eligibility
QUESTIONED COSTSOTHER MATTERS

We tested thirty-seven files, twenty-seven of which were Pell Grant recipients, and one student received a Pell grant in excess of his allowed amount. The student was eligible for $3,447, but received $3,521. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the student received ineligible Pell monies. Statistical sampling was not used when making sample selections. Questioned Costs: $74 Recommendation: We recommend the College refund $74 to the Federal Grant Program and increase controls over Pell Grants. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan. See table in the schedule of findings and questioned costs

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FINDING 2021-001: OVERAWARDED PELL GRANT FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: SFA CLUSTER CFDA#: 84.063 FEDERAL AWARD YEAR: 2020-2021 Compliance Requirement: Eligibility (E.) Criteria: The amount of a student's Federal Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62). Condition: We tested thirty-seven files, twenty-seven of which were Pell Grant recipients, and one student received a Pell grant in excess of his allowed amount. The student was eligible for $3,447, but received $3,521. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the student received ineligible Pell monies. Statistical sampling was not used when making sample selections. Questioned Costs: $74 Recommendation: We recommend the College refund $74 to the Federal Grant Program and increase controls over Pell Grants. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan. See table in the schedule of findings and questioned costs

Corrective Action Plan

A. Comments on Findings and Recommendations: Finding 2021-001. Valor Christian College and the Financial Aid Department have determined that this finding is an isolated occurrence. The incident occurred during an internal transition of Campus Ivy Valor College's Financial Aid Third-Party Servicer to a new internal servicer to Campus Ivy and was overlooked. Campus Ivy has since implemented a new procedure to prevent this type of event from occurring. Campus Ivy's new procedure will consist of a weekly review of corrected ISIR's. If/when an ISIR correction is identified that affects the student's EFC, the Financial Aid Department will be notified in the form of a document request for a new funding estimate to correct the amount of aid awarded. The funds identified in the finding have been returned to the Department of Education as of 03/16/2022.

About Eligibility →

FY 2020-06-30

LOW-RISK AUDITEE$2,624,192 federal awards expended

FAC accepted this audit on June 15, 2021 — management decision was due December 15, 2021.

2020-001
Special Tests & Provisions
REPEAT OF 2019-002QUESTIONED COSTSOTHER MATTERS

We tested nine drop students in our sample and noted one late refund. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2019-002. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the College retained funds which should have been returned to the Department of Education. Statistical sampling was not used when making sample selections. Recommendation: We recommend the College increase controls over paying refunds. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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FINDING 2020-001: LATE REFUND FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: SFA CLUSTER CFDA#: 84.268 FEDERAL AWARD YEAR: 2019-2020 Compliance Requirement: Special Tests and Provisions (N.) - Return of Title IV Funds Criteria: The Department of Education requires that all refunds be made within 45 days of a student?s withdrawal (34 CFR 668.22, 685.306). Condition: We tested nine drop students in our sample and noted one late refund. We consider this finding to be an instance of non-compliance and is a repeat finding shown in Section IV of this report as prior year Finding 2019-002. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the College retained funds which should have been returned to the Department of Education. Statistical sampling was not used when making sample selections. Recommendation: We recommend the College increase controls over paying refunds. Views of Responsible Officials: The College agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

A. Comments on Findings and Recommendations: Finding 2020-001.Valor Christian College concurs with the finding and recommendations in the finding. B. Actions Taken or Planned: Finding 2020-001. Valor Christian College and the Financial Aid Department will increase controls over the refund process to ensure that no funds are retained beyond the 45-day time frame. The responsibility for the monitoring of student attendance recorded by the professors, will be assigned to a staff member who reports to the VPAA/Provost of Valor Christian College. The staff member will be responsible for contacting students and obtaining a response from students who missed two consecutive weeks of courses and for notifying the VPAA/Provost and the Financial Aid Office when any student misses two consecutive weeks of courses and does not provide assurance in writing of the student's intent to continue in the student's courses and fails to re-engage in the student's courses by the end of the next week. The Financial Aid Office will report to the VPAA/Provost on the completion of Return of Title IV calculations within 30 days and to return any funds that need to be returned within the 45 day time-frame.

Prior Finding References

2019-002

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FY 2019-06-30

LOW-RISK AUDITEE$2,683,209 federal awards expended

FAC accepted this audit on January 28, 2020 — management decision was due July 28, 2020.

2019-001
Eligibility
QUESTIONED COSTSOTHER MATTERS

We tested forty files and one student did not receive the full amount of her Federal Direct Subsidized Loans. Cause: The condition was caused by not properly accounting for transfer credits. Effect: The result is student received an unsubsidized loan prior to receiving a full subsidized loan. Statistical sampling was not used when making sample selections. (See Schedule of Findings and Questioned Costs for chart/table) Recommendation: We recommend the Institution increase controls over packaging loans. There is no action required for the $1,000 underaward, as this is no longer a current student. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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FINDING 2019-001: UNDER AWARDED FEDERAL DIRECT SUBSIDIZED LOAN FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL DIRECT LOAN PROGRAM CFDA#: 84.268 FEDERAL AWARD YEAR: 2018-2019 Criteria: A second year student can receive up to $4,500 in subsidized loans in one academic year (34 CFR 685.203). Condition: We tested forty files and one student did not receive the full amount of her Federal Direct Subsidized Loans. Cause: The condition was caused by not properly accounting for transfer credits. Effect: The result is student received an unsubsidized loan prior to receiving a full subsidized loan. Statistical sampling was not used when making sample selections. (See Schedule of Findings and Questioned Costs for chart/table) Recommendation: We recommend the Institution increase controls over packaging loans. There is no action required for the $1,000 underaward, as this is no longer a current student. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

A. Comments on Findings and Recommendations: Valor Christian College concurs with the findings and recommendations in the finding. B. Actions Taken or Planned: The Valor Christian College Financial Aid Department will increase controls over the process to ensure that students whose grade level increases during verification are awarded at the amount for the increased grade level.

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2019-002
Special Tests & Provisions
QUESTIONED COSTSOTHER MATTERS

We tested thirteen drop students in our sample and noted one late refund. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the Institution retained funds which should have been returned to the Department of Education. Statistical sampling was not used when making sample selections. (See Schedule of Findings and Questioned Costs for chart/table) Recommendation: We recommend the Institution increase controls over paying refunds. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

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FINDING 2019-002: LATE REFUND FEDERAL AGENCY: U.S. DEPARTMENT OF EDUCATION PROGRAM NAME: FEDERAL PELL GRANT PROGRAM CFDA#: 84.063 FEDERAL AWARD YEAR: 2018-2019 Criteria: The Department of Education requires that all refunds be made within 45 days of a student?s withdrawal (34 CFR 668.22, 685.306). Condition: We tested thirteen drop students in our sample and noted one late refund. Cause: The condition was caused by an oversight in the financial aid department. Effect: The result is the Institution retained funds which should have been returned to the Department of Education. Statistical sampling was not used when making sample selections. (See Schedule of Findings and Questioned Costs for chart/table) Recommendation: We recommend the Institution increase controls over paying refunds. Views of Responsible Officials: The Institution agrees with the Single Audit Finding and a response is included in the Corrective Action Plan.

Corrective Action Plan

A. Comments on Findings and Recommendations: Valor Christian College concurs with the findings and recommendations in the finding. B. Actions Taken or Planned: The Valor Christian College Financial Aid Department will increase controls over the refund process to ensure that no funds are retained beyond the 45-day time frame.

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FY 2018-06-30

LOW-RISK AUDITEE$2,259,408 federal awards expended

FAC accepted this audit on March 7, 2019 — management decision was due September 7, 2019.

2018-001
Activities Allowed or Unallowed / Cash Management / Eligibility / Matching, Level of Effort, Earmarking / Program Income / Reporting / Special Tests & Provisions
QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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2018-002
Activities Allowed or Unallowed / Cash Management / Eligibility / Matching, Level of Effort, Earmarking / Program Income / Reporting / Special Tests & Provisions
QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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2018-003
Activities Allowed or Unallowed / Cash Management / Eligibility / Matching, Level of Effort, Earmarking / Program Income / Reporting / Special Tests & Provisions
REPEAT OF 2017-002QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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2018-004
Activities Allowed or Unallowed / Cash Management / Eligibility / Matching, Level of Effort, Earmarking / Program Income / Reporting / Special Tests & Provisions
REPEAT OF 2017-003QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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FY 2017-06-30

$1,906,883 federal awards expended

FAC accepted this audit on January 14, 2018 — management decision was due July 14, 2018.

2017-001
Activities Allowed or Unallowed / Cash Management / Eligibility / Matching, Level of Effort, Earmarking / Program Income / Reporting / Special Tests & Provisions
QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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2017-002
Activities Allowed or Unallowed / Cash Management / Eligibility / Matching, Level of Effort, Earmarking / Program Income / Reporting / Special Tests & Provisions
QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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2017-003
Activities Allowed or Unallowed / Cash Management / Eligibility / Matching, Level of Effort, Earmarking / Program Income / Reporting / Special Tests & Provisions
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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FY 2016-06-30

$1,428,902 federal awards expended

FAC accepted this audit on November 10, 2016 — management decision was due May 10, 2017.

2016-001
Eligibility
QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2016-002
Eligibility
QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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