EIN: 311048513
UEI: GSA_MIGRATION
Audited by: CAPINCROUSE LLP
Oversight agency: 84 [Department of Education]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on November 19, 2019. 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 May 19, 2020 (2299 days ago).
What is a management decision? →The College did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Cause: The College has not allocated sufficient resources to address the requirements of GLBA. Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.
Show full finding ▾Hide full finding ▴2019-001 Gramm-Leach-Bliley-Act Compliance (GLBA) Significant Deficiency DEPARTMENT OF EDUCATION CFDA #: SFA Cluster Federal Award Identification #: 18/19 Financial Aid Year Condition: The College did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Cause: The College has not allocated sufficient resources to address the requirements of GLBA. Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.
Finding Number: 2019-001 Gramm-Leach-Bliley-Act Compliance (GLBA) Planned Corrective Action: The College of Biblical Studies-Houston (CBS), merging entity effective July 1, 2019, was reviewed for compliance with this act and was found to be compliant based on current systems, processes, firewalls, data protections, in place. However, we intend to add employee training and safeguards along with our student system to be installed this year to more formally address and document our compliance. Further, we plan to perform a penetration test to document our strength against intrusions and failures. Person Responsible for Corrective Action Plan: Chief Operating Officer Anticipated Date of Completion: June 2020
Students were not always awarded federal direct loans properly based on their aggregate loan limits. Criteria: 34 CFR 685.203(d), (e) Questioned Costs: $673 Context: Out of 25 students tested, 2 students were awarded federal direct loans exceeding their subsidized or combined aggregate loan limit. The College corrected the errors and returned the funds as of May 31, 2019. Effect: Awarding loans in excess of eligibility Cause: Oversight by the College in determining the students? federal direct loan eligibility. The College did not adequately review eligibility based on ISIR comment codes that indicated a student was close to or at aggregate loan limits. Recommendation: We recommend the College put adequate procedures in place to properly award federal direct loans based on a student?s aggregate loan limits. Views of Responsible Officials: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.
Show full finding ▾Hide full finding ▴2019-002 Awarding Federal Direct Loans in Excess of Aggregate Loan Limits Significant Deficiency DEPARTMENT OF EDUCATION CFDA #: 84.268 Federal Award Identification #: 18/19 Financial Aid Year Condition: Students were not always awarded federal direct loans properly based on their aggregate loan limits. Criteria: 34 CFR 685.203(d), (e) Questioned Costs: $673 Context: Out of 25 students tested, 2 students were awarded federal direct loans exceeding their subsidized or combined aggregate loan limit. The College corrected the errors and returned the funds as of May 31, 2019. Effect: Awarding loans in excess of eligibility Cause: Oversight by the College in determining the students? federal direct loan eligibility. The College did not adequately review eligibility based on ISIR comment codes that indicated a student was close to or at aggregate loan limits. Recommendation: We recommend the College put adequate procedures in place to properly award federal direct loans based on a student?s aggregate loan limits. Views of Responsible Officials: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.
Finding Number: 2019-002 Awarding Federal Direct Loans in Excess of Aggregate Loan Limits Planned Corrective Action: The Financial Aid Department will continue to check with NSLDS to make sure aggregate loan limits are being met and students are not awarded excess loan funds. This will be done frequently to ensure that we are kept up to date for all our students. If we find that a student is close to their limit, we will contact the student and let them know. We will also indicate to the individual that they will soon no longer qualify for loans. Lastly, CBS utilizes a third party servicer to help monitor student budgets and assist in determining awards based on student cost of attendance and eligibility. Person Responsible for Corrective Action Plan: Assistant Director of Financial Aid Anticipated Date of Completion: July 1, 2019
FAC accepted this audit on September 18, 2018 — management decision was due March 18, 2019.
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Show full finding ▾Hide full finding ▴FAC accepted this audit on November 21, 2017 — management decision was due May 21, 2018.
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Show full finding ▾Hide full finding ▴FAC accepted this audit on November 13, 2016 — management decision was due May 13, 2017.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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