EIN: 340714818
UEI: CN3MLXE78MT1
Audited by: Forvis Mazars, 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 December 19, 2025. 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 June 19, 2026 (77 days ago).
What is a management decision? →FAC accepted this audit on November 19, 2024 — management decision was due May 19, 2025.
FAC accepted this audit on February 9, 2024 — management decision was due August 9, 2024.
FAC accepted this audit on December 14, 2022 — management decision was due June 14, 2023.
FAC accepted this audit on December 12, 2021 — management decision was due June 12, 2022.
FAC accepted this audit on March 30, 2021 — management decision was due September 30, 2021.
The University did not maintain proper record keeping over the payroll function of its Federal Work Study Program. Audit procedures identified four instances out of a sample of 68 student workers whose wages were not paid at the contractually agreed-upon wage. Cause: Internal controls surrounding the University?s Federal Work Study Program are not properly designed in order to ensure that changes in student worker authorized wages are reflected in the student worker payroll records. Effect or potential effect: Student workers in the University?s Federal Work Study Program were not paid at the authorized wage. Two student workers tested were paid wages in excess of their authorized wage and two students tested were paid less than their authorized wage. Questioned Costs: There are no questioned costs. Context: The sample selected for testing is representative of the population. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the University enhance internal controls over changes in authorized student worker wages in the Federal Work Study Program. Views of Responsible Officials: Management concurs with this finding. See the University?s separate corrective action plan document.
Show full finding ▾Hide full finding ▴SECTION II - FINANCIAL STATEMENT FINDINGS This section identifies the significant deficiencies, material weaknesses, fraud, noncompliance with provisions of laws, regulations, contracts, grant agreements and abuse related to the financial statements for which Government Auditing Standards require reporting. See Section III - Federal Awards Findings and Questioned Costs for the full context of findings 2020-001, 2020-002 and 2020-003 which are both financial statement and federal award findings. SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 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 2020-001: Student Financial Assistance Cluster, Department of Education Programs Program Names: Federal Work Study Program CFDA Numbers: 84.033 Criteria or Specific Requirement: The University is responsible for establishing and maintaining internal control over the record keeping of the Federal Work Study Program including a payroll voucher containing sufficient information to support all payroll disbursements in accordance with 34 CFR 675.19. Condition: The University did not maintain proper record keeping over the payroll function of its Federal Work Study Program. Audit procedures identified four instances out of a sample of 68 student workers whose wages were not paid at the contractually agreed-upon wage. Cause: Internal controls surrounding the University?s Federal Work Study Program are not properly designed in order to ensure that changes in student worker authorized wages are reflected in the student worker payroll records. Effect or potential effect: Student workers in the University?s Federal Work Study Program were not paid at the authorized wage. Two student workers tested were paid wages in excess of their authorized wage and two students tested were paid less than their authorized wage. Questioned Costs: There are no questioned costs. Context: The sample selected for testing is representative of the population. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the University enhance internal controls over changes in authorized student worker wages in the Federal Work Study Program. Views of Responsible Officials: Management concurs with this finding. See the University?s separate corrective action plan document.
February 26, 2021 RE: Compliance Related Finding - Identifying Number 2020-001 Audit Finding 2020-001: The University did not maintain proper record keeping over the payroll function of its Federal Work Study Program. Audit procedures identified four instances out of a sample of 68 student workers whose wages were not paid at the contractually agreed-upon wage. Cause: Internal controls surrounding the University's Federal Work Study Program are not properly designed in order to ensure that changes in student worker authorized wages are reflected in the student worker payroll records. Corrective Action taken or planned: The university has taken several steps to address this finding. Creating a simplified student employment contract and automating the documentation and payroll voucher processing system. All current positions, using the prior contract process, will be individually reviewed for accuracy.
The University failed to report enrollment status changes to the NSLDS through the National Student Clearinghouse as required under 34 CFR 682.610 for two of 77 students tested. Cause: The delay in the reporting of student enrollment changes was a failure in the college?s processes and controls surrounding a specific subset of students. A system limitation existed that failed to capture enrollment changes for eligible dual citizens. 34 CFR section 668.33 states that to be eligible to receive Title IV, HEA program assistance, a student must (1) be a citizen or national of the United States; or (2) provide evidence from the U.S. Immigration and Naturalization Service that he or she (i) is a permanent resident of the United States; or (ii) is in the United States for other than a temporary purpose with the intention of becoming a citizen or permanent resident. 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 of 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 in a timely manner to the National Student Loan Data System as required under 34 CFR 682.610. 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 that the University implement a secondary review of the students requiring an enrollment status change to ensure that the enrollment changes are reported in a timely manner and that the population of enrollment changes is complete. We also recommend that the University 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 the University?s separate corrective action plan document.
Show full finding ▾Hide full finding ▴Finding 2020-002: 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 received, the institution must update for changes in student status, report the date that 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 682.610 requires that an organization report student status changes within 60 days of graduation, withdrawal or other roster status changes. Condition: The University failed to report enrollment status changes to the NSLDS through the National Student Clearinghouse as required under 34 CFR 682.610 for two of 77 students tested. Cause: The delay in the reporting of student enrollment changes was a failure in the college?s processes and controls surrounding a specific subset of students. A system limitation existed that failed to capture enrollment changes for eligible dual citizens. 34 CFR section 668.33 states that to be eligible to receive Title IV, HEA program assistance, a student must (1) be a citizen or national of the United States; or (2) provide evidence from the U.S. Immigration and Naturalization Service that he or she (i) is a permanent resident of the United States; or (ii) is in the United States for other than a temporary purpose with the intention of becoming a citizen or permanent resident. 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 of 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 in a timely manner to the National Student Loan Data System as required under 34 CFR 682.610. 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 that the University implement a secondary review of the students requiring an enrollment status change to ensure that the enrollment changes are reported in a timely manner and that the population of enrollment changes is complete. We also recommend that the University 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 the University?s separate corrective action plan document.
February 26, 2021 RE: Compliance Related Finding- Identifying Number 2020-002 Audit Finding 2020-002: The University failed to report enrollment status changes to the NSLDS through the National Student Clearinghouse as required under 34 CFR 682.610 for two of 77 students tested. Cause: Franciscan University of Steubenville uses Jenzabar Jl to create a submission file to report enrollment status changes to the National Student Clearinghouse. The Jenzabar system file generator omitted a very small subgroup of students who were identified as foreign citizens who were in fact dual citizens. Corrective Action taken or planned: The university has taken several steps to address this finding. The two students identified have been corrected and submitted to the National Student Clearinghouse. (we reported 13 days late) Working with our IT department the enrollment file generation process in our software (Jenzabar Jl) was modified so that it will include all students in our submission file regardless of citizenship status. The new output file with all students is now reported to the National Student Clearinghouse by the Registrar's office on a regular basis according to the established enrollment transmission schedule. The Director of Financial aid will audit the submission file against enrollments every 30 days to ensure that all enrollment status changes have been submitted.
The University did not have written documentation to demonstrate its compliance with the requirements of 16 CFR 314. Cause: The University has not yet formalized its student financial aid security program. Effect or potential effect: If the University has not performed a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) and documented safeguards for identified risks, there might be inadequate safeguards of student financial aid information. Questioned Costs: There are no questioned costs. Context: We were unable to verify whether the University had recently performed a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) and documented safeguards for identified risks, based on the University?s current operations and environment. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the University formally coordinate the information security program, perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b), and document safeguards for identified risks. Views of Responsible Officials: Management concurs with this finding. See the University?s separate corrective action plan document.
Show full finding ▾Hide full finding ▴Finding 2020-003: Student Financial Assistance Cluster, Department of Education Programs Program Names: Federal Supplemental Educational Opportunity Grant, Federal Work Study Program, Federal Perkins Loan Program, Federal Pell Grant Program, Federal Direct Student Loans, Teacher Education Assistance for College and Higher Education Grant CFDA Numbers: 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 Criteria or Specific Requirement: Under an institution?s Program Participation Agreement with ED and the Gramm-Leach-Bliley Act, institutions must protect student financial aid information, with particular attention to information provided to institutions by the ED or otherwise obtained in support of the administration of the federal student financial aid programs. (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)) Condition: The University did not have written documentation to demonstrate its compliance with the requirements of 16 CFR 314. Cause: The University has not yet formalized its student financial aid security program. Effect or potential effect: If the University has not performed a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) and documented safeguards for identified risks, there might be inadequate safeguards of student financial aid information. Questioned Costs: There are no questioned costs. Context: We were unable to verify whether the University had recently performed a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) and documented safeguards for identified risks, based on the University?s current operations and environment. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the University formally coordinate the information security program, perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b), and document safeguards for identified risks. Views of Responsible Officials: Management concurs with this finding. See the University?s separate corrective action plan document.
March 3, 2021 RE: Compliance Related Finding - Identifying Number 2020-003 Audit Finding 2020-003: Under an institution's Program Participation Agreement with ED and the Gramm-Leach-Bliley Act, institutions must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B( d)(2)) Corrective Actions Taken or Planned: The University currently utilizes KnowBe4 to provide annual employee information security training as well as simulated phishing tests that are conducted regularly. Additionally, the University engaged the services of an information security firm to conduct a penetration test in August 2019 and has remediated several of the findings in the subsequent report. The University has engaged the services of a qualified information security consultant to conduct a more comprehensive IT security audit. That process is ongoing. Included in the audit is a a cybersecurity risk assessment, industry standard controls gap assessment, and internal/external penetration testing. Also included with the audit is a risk assessment to include at minimum the three required areas of 16 CFR 314.4(b) - employee training and management; information systems; and detection, prevention, and response to attacks/intrusions or other system failures. The University is committed to addressing any deficiencies found during the audit process and making necessary changes to the information technology infrastructure, staff, policies, and/or procedures required to ensure compliance with 16 CFR 314.4(b).
FAC accepted this audit on November 18, 2019 — management decision was due May 18, 2020.
The University failed to report enrollment status changes to the NSLDS through the National Student Clearinghouse as required under 34 CFR 682.610 for one 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 a specific subset of students. A system limitation existed that failed to capture enrollment changes for eligible noncitizens. 34 CFR section 668.33 states that to be eligible to receive title IV, HEA program assistance, a student must (1) be a citizen or national of the United States; or (2) provide evidence from the U.S. Immigration anent resident of the United State; or (ii) is in the United States for other than a temporary purpose with the intention of becoming a citizen or permanent resident. SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (CONTINUED) Finding 2019-001: (Continued) 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 682.610. This potentially caused a late conversion of student loans into repayment status.
Show full finding ▾Hide full finding ▴SECTION II - FINANCIAL STATEMENT FINDINGS This section identifies the significant deficiencies, material weaknesses, fraud, noncompliance with provisions of laws, regulations, contracts, grant agreements and abuse related to the financial statements for which Government Auditing Standards require reporting. See Section III - Federal Awards Findings and Questioned Costs for the full context of finding 2019-001, which is both a financial statement and federal award finding. SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 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 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 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 682.610 requires that an organization report student status changes within 60 days of graduation, withdrawal or other roster status changes. Condition: The University failed to report enrollment status changes to the NSLDS through the National Student Clearinghouse as required under 34 CFR 682.610 for one 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 a specific subset of students. A system limitation existed that failed to capture enrollment changes for eligible noncitizens. 34 CFR section 668.33 states that to be eligible to receive title IV, HEA program assistance, a student must (1) be a citizen or national of the United States; or (2) provide evidence from the U.S. Immigration anent resident of the United State; or (ii) is in the United States for other than a temporary purpose with the intention of becoming a citizen or permanent resident. SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (CONTINUED) Finding 2019-001: (Continued) 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 682.610. This potentially caused a late conversion of student loans into repayment status.
Corrective Actions Taken or Planned: The Auditor asserts that the University did not notify in a timely manner enrollment status changes to National Student Clearinghouse (NSC) and that this constitutes a failure to notify in a timely manner under 34 CFR 682.610. The University provides assurances that all notifications have been made and agrees with the auditor's recommendation with respect to this finding. The University has taken several steps to address this finding. First, the University has set in place that the Financial Aid office will send a list of all eligible international students (as verified via the FAFSA application process) to the registrar who will then submit them to the NSC for enrollment changes. Second, the University is working with the software company that the registrar uses to identify modifications that can be implemented to ensure that all eligible students are identified appropriately in order to be submitted to NSC.
FAC accepted this audit on December 19, 2018 — management decision was due June 19, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on November 12, 2017 — management decision was due May 12, 2018.
FAC accepted this audit on November 9, 2016 — management decision was due May 9, 2017.
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