EIN: 350868073
UEI: MJWEKJMGD7R9
Audited by: Crowe LLP
Oversight agency: 84 [Department of Education]
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Data as of August 31, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 12, 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 12, 2026 (20 days ago).
What is a management decision? →FAC accepted this audit on January 9, 2025 — management decision was due July 9, 2025.
FAC accepted this audit on January 18, 2024 — management decision was due July 18, 2024.
FAC accepted this audit on February 7, 2023 — management decision was due August 7, 2023.
FAC accepted this audit on February 17, 2022 — management decision was due August 17, 2022.
FAC accepted this audit on January 5, 2021 — management decision was due July 5, 2021.
FAC accepted this audit on November 19, 2019 — management decision was due May 19, 2020.
Earlham did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: Earlham has not documented its security assessment. Effect: Earlham has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Cause: Earlham College has not allocated sufficient resources to address the requirements of GLBA. Recommendation: We recommend Earlham 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 #: 84.268, 84.063, 84.007, 84.033 and 84.038-Student Financial Assistance Cluster Federal Award Identification #: 2018-2019 Financial Aid Year Condition: Earlham did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: Earlham has not documented its security assessment. Effect: Earlham has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Cause: Earlham College has not allocated sufficient resources to address the requirements of GLBA. Recommendation: We recommend Earlham 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: Earlham agrees with the need to comply with the necessary provisions of GLBA and recognizes the importance of implementing the formal requirements outlined in GLBA, including the Safeguards Rule. The College, with assistance from an outside consultant, is in the process of developing, implementing, and maintaining a written information security program; designating the employee(s) responsible for coordinating the program; identifying and assessing the risks to student information; designing and implementing an information safeguards program; selecting appropriate service providers that are capable of maintaining appropriate safeguards; and periodically evaluating and updating our security program. Person Responsible for Corrective Action Plan: Vice President for Finance and Administration Anticipated Date of Completion: We expect to have made significant progress towards meeting all requirements by June 30, 2020.
FAC accepted this audit on November 10, 2018 — management decision was due May 10, 2019.
FAC accepted this audit on October 17, 2017 — management decision was due April 17, 2018.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on October 4, 2016 — management decision was due April 4, 2017.
GSA_MIGRATION
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GSA_MIGRATION
2015-001
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