Hiram College

Criteria: 2 CFR 500.512(a)(1) states that the audit, the data collection form, and the reporting package must be submitted within 30 calendar days after the auditee receives the auditors' report or nine months after the end of the audit period (whichever is earlier). Condition: The College did not timely submit the Single Audit Reporting Package for the period July 1, 2024 to May 31, 2025. Cause: During the period July 1, 2024 to May 31, 2025, the College experienced turnover in the accounting department that resulted in delays to the audit. Effect: The College could be subject to additional compliance reviews. Recommendation: We recommend the College implements policies and procedures to ensure the accounting records are prepared and reconciled in a timely manner to ensure the audit and submission of the data collection form are completed in a timely manner. Views of responsible officials: The College agrees with the finding. Refer to the Corrective Action Plan.

Criteria: In order for an institution to participate in any Title IV program, the institution must be financially responsible. One of the general standards for being considered financially responsible per 34 CFR section 668.171(b) is to obtain a composite score of at least 1.5. An institution that does not meet one or more of the general standards must comply with the alternative standards and requirements of financial responsibility under 34 CFR section 668.175. Condition: The College's composite score based upon the audited financial statements as of May 31, 2025 was less than 1.5. Cause: The College was impacted by multi-year operating losses and has borrowed from its endowment over multiple years to meet liquidity needs. As a result, at May 31, 2025, the College's composite score was negatively impacted. Effect: The College did not meet the definition of being financially responsible for the period ending May 31, 2025 under the general standards and, in turn, must comply with the alternative standards. Recommendation: The College is reviewing its operations to determine the best approach to maintain adequate levels of liquidity, in addition to improving its operating revenues. Views of responsible officials: The College agrees with the finding. Refer to the Corrective Action Plan.

Information on the Federal Program: Education Stabilization Fund, Higher Education Emergency Relief Fund ALN: 84.425F Criteria or Specific Requirement: The institution is responsible for posting institutional and student reports quarterly as well as filing an annual report in an accurate and timely manner (2 CFR Section 200.329(c)(1)). Condition: The institutional and student reports were not submitted timely and/or were not completed in accordance with HEERF reporting requirements. Questioned Costs: None- nonmonetary finding. Context: Based on testing all reports due during the period, all institutional reports were filed late and were not completed fully and accurately with the requirements. Effect: Due to misinterpreting reporting requirements and certain personnel changes, the College did not submit quarterly reports timely and accurately. Cause: The College misinterpreted the reporting requirements related to Higher Education Emergency Relief Funds as well as experienced staff turnover that led to the incompleteness and inaccuracies. Identification as a repeat finding, if applicable – N/A Recommendations: We recommend the College review all instructions issued by the United States Department of Education related to Higher Education Emergency Relief Fund reporting requirements to ensure compliance with reporting requirements and make any adjustments as needed. Views of responsible officials: Management will make necessary revisions to precious reporting. Management will complete and file all past due quarterly and annual a reports accurately and in compliance with all HEERF reporting requirements.

Criteria: 16 CFR 314.4 (b) - The Gramm-Leach-Bliley Act requires institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. Under the Gramm-Leach-Bliley Act, the institution is required to perform a risk assessment that addresses three required areas (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. The institution is then required to document a safeguard for each risk identified from the risk assessment performed. Condition: The College?s is not in compliance with the requirements of 16 CFR 314.4 (b). The College performed a risk assessment, however, they have not fully documented safeguards to every risk identified from the risk assessment. Cause: The College has not fully documented safeguards to each risk identified from the risk assessment. Effect: The College?s has not properly implemented safeguards to mitigate all of the identified risks over the College?s student financial aid information and therefore the College has not complied with requirements 16 CFR 314.4(b). Recommendations: The College should complete their review of its informational technology risk assessment and fully document a safeguard for every risk that was identified as a result of the risk assessment. Views of responsible officials: See views of responsible officials in the accompanying Corrective Action Plan.

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