Bradley University

EIN: 370661494

UEI: D3ZVNXBL1DJ7

Data as of August 23, 2026

Bradley University10 audit years14 findings4 repeat
10
Audit Years
14
Total Findings
4
Repeat Findings

FY 2025-05-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on December 11, 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 11, 2026 (74 days ago).

What is a management decision? →
2025-001
Reporting
REPEAT

While performing audit procedures, it was noted that 18 of the 40 instances in our sample did not report the effective date of the campus-level records correctly. There were also 2 instances where the sample selected did not report the effective date of the program-level records correctly. Questioned costs: None. Context: A control system to prevent and detect errors in the reporting process was not created to ensure all required reporting compliance was filed correctly. Cause: The University’s processes and controls did not ensure that student status changes were properly reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat finding: Yes, 2024-002 Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

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Full finding narrative

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program, 84.268 – Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2024 – May 31, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Errors must be corrected within 10 days. Condition: While performing audit procedures, it was noted that 18 of the 40 instances in our sample did not report the effective date of the campus-level records correctly. There were also 2 instances where the sample selected did not report the effective date of the program-level records correctly. Questioned costs: None. Context: A control system to prevent and detect errors in the reporting process was not created to ensure all required reporting compliance was filed correctly. Cause: The University’s processes and controls did not ensure that student status changes were properly reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat finding: Yes, 2024-002 Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

The Office of the Registrar will continue to submit enrollment data to the National Student Clearinghouse via the current schedule. The Office of the Registrar will investigate and resolve any errors returned by the National Student Clearinghouse. After the enrollment data is transferred from the NSC to NSLDS the Registrar's office will review the data in NSLDS for any discrepancies including cross-checking graduation files and complete withdrawals. Any inconsistencies will be discussed and timely resolved by the applicable units and officially updated in NSLDS and NSC respectively. The University will keep track of any changes manually made within the NSLDS or NSC database by university representatives, so that the student information system, NSC, and NSLDS records are in-sync.

Prior Finding References

2024-002

About Reporting →

FY 2024-05-31

FAC accepted this audit on November 25, 2024 — management decision was due May 25, 2025.

2024-001
Reporting

One student refund resulting from the Parent Plus loan was not refunded for 16 days. Questioned costs: None. Context: A control system to prevent and detect errors in the reporting process was not created to ensure all required compliance requirements were met. Cause: The student's refund was set to be sent out on but it fell on Labor day it didn't get sent out until after the 14 days. Effect: The University is not in compliance with Department of Education requirements that all credit balances be paid directly to the student as soon as possible, but no later than 14 days after the credit balance occurred. Repeat finding: No Recommendation: We recommend the University implement a process to ensure that any credit balances arising from federal student financial aid are made within the 14 day time limit imposed by the Department of Education. Views of responsible officials: There is no disagreement with the audit finding.

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Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.268 – Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2023 – May 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 675.16 states whenever an institution disburses FWS funds by crediting a student's account and the result is a credit balance, the institution must pay the credit balance directly to the student as soon as possible, but no later than 14 days after the credit balance occurred on the account. Condition: One student refund resulting from the Parent Plus loan was not refunded for 16 days. Questioned costs: None. Context: A control system to prevent and detect errors in the reporting process was not created to ensure all required compliance requirements were met. Cause: The student's refund was set to be sent out on but it fell on Labor day it didn't get sent out until after the 14 days. Effect: The University is not in compliance with Department of Education requirements that all credit balances be paid directly to the student as soon as possible, but no later than 14 days after the credit balance occurred. Repeat finding: No Recommendation: We recommend the University implement a process to ensure that any credit balances arising from federal student financial aid are made within the 14 day time limit imposed by the Department of Education. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

2024-001: Student Financial Assistance Cluster. Assistance Listing Number: 84.268 - Federal Direct Student Loans. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 675.16 states whenever an institution disburses FWS funds by crediting a student's account and the result is a credit balance, the institution must pay the credit balance directly to the student as soon as possible, but no later than 14 days after the credit balance occurred on the account. Cause: The student's refund was set to be sent out on but it fell on Labor day it didn't get sent out until after the 14 days. Effect: The University is not in compliance with Department of Education requirements that all credit balances be paid directly to the student as soon as possible, but no later than 14 days after the credit balance occurred. Recommendation: We recommend the University implement a process to ensure that any credit balances arising from federal student financial aid are made within the 14 day time limit imposed by the Department of Education. Views of responsible officials: There is no disagreement with the audit finding.

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2024-002
Reporting
REPEAT

While performing audit procedures, it was noted that 33 of the 40 students in our sample were not reported correctly to NSLDS. 4 of these students were not reported by the University within 60 days of their status change, and 1 student's enrollment was not verified every 60 days during the fiscal year. There were also 14 instances during 2024 where the roster was submitted with errors that were not corrected within 10 days. Questioned costs: None. Context: A control system to prevent and detect errors in the reporting process was not created to ensure all required reporting compliance was filed timely. Cause: The University’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The errors were caused by National Student Clearinghouse's communication with NSLDS, as a result of the modernization of NSLDS in 2022. The University was told the errors would be fixed and there was nothing more they needed to do. The errors were not fixed. Repeat finding: Yes, 2023-002 Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

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Full finding narrative

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program, 84.268 – Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2023 – May 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Errors must be corrected within 10 days. Condition: While performing audit procedures, it was noted that 33 of the 40 students in our sample were not reported correctly to NSLDS. 4 of these students were not reported by the University within 60 days of their status change, and 1 student's enrollment was not verified every 60 days during the fiscal year. There were also 14 instances during 2024 where the roster was submitted with errors that were not corrected within 10 days. Questioned costs: None. Context: A control system to prevent and detect errors in the reporting process was not created to ensure all required reporting compliance was filed timely. Cause: The University’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The errors were caused by National Student Clearinghouse's communication with NSLDS, as a result of the modernization of NSLDS in 2022. The University was told the errors would be fixed and there was nothing more they needed to do. The errors were not fixed. Repeat finding: Yes, 2023-002 Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

2024-002: U.S. Department of Education. Assistance Listing Numbers: 84.063 - Federal Pell Grant Program, 84.268 - Federal Direct Student Loans. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Errors must be corrected within 10 days. Cause: The University’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The errors were caused by National Student Clearinghouse's communication with NSLDS, as a result of the modernization of NSLDS in 2022. The University was told the errors would be fixed and there was nothing more they needed to do. The errors were not fixed. Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

Prior Finding References

2023-002

About Reporting →
2024-003
Reporting

During our testing of the University’s information technology, we noted the University did not maintain a comprehensive written security program that included the minimum required elements. The University does perform all procedures required by the Gramm-Leach-Bliley Act, however, these procedures are not formally documented. Questioned costs: None Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools 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. Cause: The University has continued to make progress in updating the University’s written security program to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the University work to update the written security program to ensure compliance with all the standards. Views of responsible officials: There is no disagreement with the audit finding.

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Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program) Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2023 – May 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the University to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the University’s information technology, we noted the University did not maintain a comprehensive written security program that included the minimum required elements. The University does perform all procedures required by the Gramm-Leach-Bliley Act, however, these procedures are not formally documented. Questioned costs: None Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools 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. Cause: The University has continued to make progress in updating the University’s written security program to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the University work to update the written security program to ensure compliance with all the standards. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

2024-003: U.S. Department of Education. Assistance Listing Number: 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program). Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the University to establish and maintain effective internal controls over Federal awards. Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools 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. Cause: The University has continued to make progress in updating the University’s written security program to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Recommendation: We recommend the University work to update the written security program to ensure compliance with all the standards. Views of responsible officials: There is no disagreement with the audit finding.

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FY 2023-05-31

FAC accepted this audit on February 28, 2024 — management decision was due August 28, 2024.

2023-001
Special Tests & Provisions

Nineteen checks related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of May 31, 2023. Questioned costs: None. Context: A total of 173 checks outstanding over 240 days at year-end were individually reviewed to determine if they were related to a student refund of Title IV funds. Cause: Management was not aware of the requirement to return checks that are not cashed within 240 days. Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department Repeat finding: No Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of responsible officials: There is no disagreement with the audit finding.

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2023 – 001 Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants, 84.038 – Federal Perkins Loans, 84.063 – Federal Pell Grant Program, 84.268 – Federal Direct Student Loans, 84.379 – Teacher Education Assistance for College and Higher Education Grants, 93.364 – Nursing Student Loan Program Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2022 – May 31, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. Condition: Nineteen checks related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of May 31, 2023. Questioned costs: None. Context: A total of 173 checks outstanding over 240 days at year-end were individually reviewed to determine if they were related to a student refund of Title IV funds. Cause: Management was not aware of the requirement to return checks that are not cashed within 240 days. Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department Repeat finding: No Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

2023-001 Student Financial Assistance Cluster- Assistance Listing Number: 84.007, 84.038, 84.063, 84.268, 84.379, 93.364 Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action taken in response to finding: The Financial Services Division of the University (FSD) has implemented a new process to better track the status of student refund checks. After the first week of the month, all outstanding checks from the prior month are investigated in order to identify student refund checks that were the result of Title IV funds (e.g. January outstanding checks are reviewed after the first week of February). A representative from FSD will contact the borrower within 45 days of the original issuance date via email to inform them that the check remains outstanding and provide them with the option to EFT the funds directly to the student or void the check and reduce the borrowing with the Department of Education. The original check will remain valid for the 90 days stated on the face of the check. After 90 days, no additional communication will be made to the borrower. The check will be voided and borrowing will be updated with the Department of Education after 90 days of the original issuance, but prior to the 240 days allowed by the Department of Education. In additional to establishing a process to handle any future refund checks, the University.is also in contact with the Department of Education to provide process clarity on how to return funds related to refund checks for years where the financial aid year has been closed. Name of the contact person responsible for corrective action: Mark Young, Assistant Controller Planned completion date for corrective action plan: 2/29/2024

About Special Tests and Provisions →
2023-002
Reporting

While performing audit procedures, it was noted that 2 students in our sample of forty (40) were not reported correctly to NSLDS. One student was reported as a graduate on April 16, 2023 but the degree was not conferred until May 13, 2023. A second student was reported as Graduated within Program Level NSLDS records but was in fact a withdrawn student. Questioned costs: None. Context: A control system to prevent and detect errors in the reporting process was not created to ensure all required reporting compliance was filed timely. Cause: The University’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat finding: No Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

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2023 – 002 Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program, 84.268 – Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2022 – May 31, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition: While performing audit procedures, it was noted that 2 students in our sample of forty (40) were not reported correctly to NSLDS. One student was reported as a graduate on April 16, 2023 but the degree was not conferred until May 13, 2023. A second student was reported as Graduated within Program Level NSLDS records but was in fact a withdrawn student. Questioned costs: None. Context: A control system to prevent and detect errors in the reporting process was not created to ensure all required reporting compliance was filed timely. Cause: The University’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat finding: No Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

2023-002 Student Financial Assistance Cluster- Assistance Listing Number: 84.063, 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that students' statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action taken in response to finding: The Office of the Registrar will continue to submit enrollment data to the National Student Clearinghouse via the current schedule. The Office of the Registrar will investigate and resolve any errors returned by the National Student Clearinghouse. After the enrollment data is transferred from the NSC to NSLDS a University representative will review the data in NSLDS for any discrepancies including cross-checking graduation files and complete withdrawals. Any inconsistencies will be discussed and timely resolved by the applicable units and officially updated in NSLDS and NSC respectively. The University will keep track of any changes manually made within the NSLDS or NSC database by university representatives, so that the student information system, NSC, and NSLDS records are in-sync. Name of the contact person responsible for corrective action: Dennis Koch, Associate Vice President of Financial Services Planned completion date for corrective action plan: 3/15/2024 If the Department of Education has questions regarding this plan, please call Dennis Koch at 309-667-3119.

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FY 2022-05-31

FAC accepted this audit on February 23, 2023 — management decision was due August 23, 2023.

2022-001
Reporting

During testing of disbursements made to students under Higher Education Emergency Relief Fund (HEERF) program, we noted that all checks written to students were signed by the former CFO who was not employed during the audit period tested. Criteria or specific requirement: A fundamental concept in a good system for internal control includes ensuring personnel with authorization to financial assets of an entity are periodically reviewed to ensure authorized individuals are accurate and appropriate. Effect: There is a potential for unauthorized disbursements to be made based on a former employee signature being used for disbursement checks. Cause: Controls in place around terminated employees did not include removing signing authority and responsibilities of the individual. Repeat Finding: No. Recommendation: We recommend the University enhance termination procedures to include a control to ensure employees lose authorized signer rights for the University upon termination. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has subsequently updated authorized users and the signature to the current CFO.

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Type of Finding: ? Significant Deficiency in Internal Control over Financial Reporting Condition: During testing of disbursements made to students under Higher Education Emergency Relief Fund (HEERF) program, we noted that all checks written to students were signed by the former CFO who was not employed during the audit period tested. Criteria or specific requirement: A fundamental concept in a good system for internal control includes ensuring personnel with authorization to financial assets of an entity are periodically reviewed to ensure authorized individuals are accurate and appropriate. Effect: There is a potential for unauthorized disbursements to be made based on a former employee signature being used for disbursement checks. Cause: Controls in place around terminated employees did not include removing signing authority and responsibilities of the individual. Repeat Finding: No. Recommendation: We recommend the University enhance termination procedures to include a control to ensure employees lose authorized signer rights for the University upon termination. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. Management has subsequently updated authorized users and the signature to the current CFO.

Corrective Action Plan

2022-001 Terminated employee with check signing authority Recommendation: We recommend the University enhance termination procedures to include a control to ensure employees lose authorized signer rights upon termination. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action taken in response to finding: Management has updated authorized users and the signature plate to Sheryl Cox, CFO. Name of the contact person responsible for corrective action: Dennis Koch, Assistant Vice President of Financial Services Planned completion date for corrective action plan: Completed

About Reporting →
2022-002
Reporting
REPEAT

While the University did ultimately complete and submit the required reporting, it was not submitted by the specified timeliness in all instances. During our testing of quarterly reports posted to the University's website for the student portion, we noted 2 of 2 required quarterly report postings was submitted after the required due dates. Questioned costs: None. Context: It was noted that the University did not have a proper procedure in place for monitoring that required information was reported timely. Cause: There were time constraints due to the circumstances surrounding the HEERF funding. Procedures are in place to meet all future reporting deadlines. Effect: The University did not comply with the Department of Education regulations for timely quarterly reporting of specified information for (HEERF I, II, III) (a)(1), (a)(3) and (a)(4) Student Aid and Institutional Portion funds. Repeat finding: Yes Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting requirements to ensure accurate and timely reporting. Views of responsible officials: There is no disagreement with the audit finding. The University has subsequently complied with the guidelines and submitted all reporting requirements

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Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Fund (HEERF) Assistance Listing Number: 84.425E and 84.425F Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2021 ? May 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Federal Register 86 FR 26213 states that institutions must promptly and timely post detailed accounting of the use and expenditure of the (HEERF I, II, III) (a)(1) and (a)(4) Student Aid Portion funds in a format and location that is easily accessible to the public. The information is required to be updated no later than 10 days after the end of each calendar quarter (September 30, December 31, March 31, and June 30). The OMB Control Number 1840-0849 form states that institutions must promptly and timely post the completed budget and expenditure reporting form for (HEERF I, II, III) (a)(1) and (a)(3) Institutional Portion funds on the institution's primary website. The initial reporting is submitted to Institution's website within 30 days of signing Certification Agreement. Institution websites are to be updated every 45 days after initial submission. This was changed to quarterly on August 31, 2020. The information was required to be updated no later than 10 days after the end of each calendar quarter (September 30, December 31, March 31, and June 30). Condition: While the University did ultimately complete and submit the required reporting, it was not submitted by the specified timeliness in all instances. During our testing of quarterly reports posted to the University's website for the student portion, we noted 2 of 2 required quarterly report postings was submitted after the required due dates. Questioned costs: None. Context: It was noted that the University did not have a proper procedure in place for monitoring that required information was reported timely. Cause: There were time constraints due to the circumstances surrounding the HEERF funding. Procedures are in place to meet all future reporting deadlines. Effect: The University did not comply with the Department of Education regulations for timely quarterly reporting of specified information for (HEERF I, II, III) (a)(1), (a)(3) and (a)(4) Student Aid and Institutional Portion funds. Repeat finding: Yes Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting requirements to ensure accurate and timely reporting. Views of responsible officials: There is no disagreement with the audit finding. The University has subsequently complied with the guidelines and submitted all reporting requirements

Corrective Action Plan

2022-002 Higher Education Emergency Relief Fund ? Assistance Listing Number: 84.425E and 84.425F Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting requirements to ensure accurate and timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action taken in response to finding: Staff time constraints caused the finding. Reporting responsibilities have been reassigned to available staff. The University has subsequently complied with the guidelines and submitted all reporting requirements. Procedures are in place to meet all future reporting deadlines. Name of the contact person responsible for corrective action: Dennis Koch, Assistant Vice President of Financial Services Planned completion date for corrective action plan: Completed

Prior Finding References

2021-002

About Reporting →

FY 2021-05-31

FAC accepted this audit on March 25, 2022 — management decision was due September 25, 2022.

2021-001
Reporting

While the University did ultimately complete and submit the required reporting, it was not submitted by the specified timeliness in all instances. During our testing of quarterly reports posted to the University's website for the student portion, we noted 2 of 4 required quarterly report postings was submitted after the required due dates. Furthermore, the intermediate 45-day update of CARES Act Reporting was posted 18 days late, resulting in noncompliance with the reporting requirement. Questioned costs: None. Context: It was noted that the University did not have a proper procedure in place for monitoring that required information was reported timely. Cause: There were time constraints due to the circumstances surrounding the HEERF funding. Procedures are in place to meet all future reporting deadlines. Effect: The University did not comply with the Department of Education regulations for timely quarterly reporting of specified information for (HEERF I, II, III) (a)(1), (a)(3) and (a)(4) Student Aid and Institutional Portion funds. Repeat finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting requirements to ensure accurate and timely reporting. Views of responsible officials: There is no disagreement with the audit finding. The University has subsequently complied with the guidelines and submitted all reporting requirements.

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2021-001 Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Fund (HEERF) Assistance Listing Number: 84.425E and 84.425F Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2020 ? May 31, 2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Federal Register 86 FR 26213 states that institutions must promptly and timely post detailed accounting of the use and expenditure of the (HEERF I, II, III) (a)(1) and (a)(4) Student Aid Portion funds in a format and location that is easily accessible to the public. The information is required to be updated no later than 10 days after the end of each calendar quarter (September 30, December 31, March 31, and June 30). The OMB Control Number 1840-0849 form states that institutions must promptly and timely post the completed budget and expenditure reporting form for (HEERF I, II, III) (a)(1) and (a)(3) Institutional Portion funds on the institution's primary website. The initial reporting is submitted to Institution's website within 30 days of signing Certification Agreement. Institution websites are to be updated every 45 days after initial submission. This was changed to quarterly on August 31, 2020. The information was required to be updated no later than 10 days after the end of each calendar quarter (September 30, December 31, March 31, and June 30). Condition: While the University did ultimately complete and submit the required reporting, it was not submitted by the specified timeliness in all instances. During our testing of quarterly reports posted to the University's website for the student portion, we noted 2 of 4 required quarterly report postings was submitted after the required due dates. Furthermore, the intermediate 45-day update of CARES Act Reporting was posted 18 days late, resulting in noncompliance with the reporting requirement. Questioned costs: None. Context: It was noted that the University did not have a proper procedure in place for monitoring that required information was reported timely. Cause: There were time constraints due to the circumstances surrounding the HEERF funding. Procedures are in place to meet all future reporting deadlines. Effect: The University did not comply with the Department of Education regulations for timely quarterly reporting of specified information for (HEERF I, II, III) (a)(1), (a)(3) and (a)(4) Student Aid and Institutional Portion funds. Repeat finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting requirements to ensure accurate and timely reporting. Views of responsible officials: There is no disagreement with the audit finding. The University has subsequently complied with the guidelines and submitted all reporting requirements.

Corrective Action Plan

U.S. Department of Education Bradley University respectfully submits the following corrective action plan for the year ended May 31, 2021. Audit period: June 1, 2019 ? May 31, 2021 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no findings in the current year that require a corrective action plan. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2021-001 Higher Education Emergency Relief Fund ? Assistance Listing Number: 84.425E and 84.425F Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting requirements to ensure accurate and timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action taken in response to finding: There were time constraints due to the start of the new semester which caused the finding. The University has subsequently complied with the guidelines and submitted all reporting requirements. Procedures are in place to meet all future reporting deadlines. Name of the contact person responsible for corrective action: Dennis Koch, Assistant Vice President of Financial Services Planned completion date for corrective action plan: Completed If the Department of Education has questions regarding this plan, please call Dennis Koch at 309-667-3119.

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FY 2020-05-31

FAC accepted this audit on June 21, 2021 — management decision was due December 21, 2021.

2020-001
Eligibility

Through our testing of 40 students whose accounts had a credit balance resulting from federal funds during the year, we noted that one student did not have the credit balance refunded within the 14 day period. Questioned costs: None. Context: During our testing, it was noted that the University was not reviewing credit balances on student accounts for credit balances caused by federal funds. Cause: Student was claimed by the University before they selected type of refund they wanted for credit balance in account. This caused student to be overlooked during refund process. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by DOE regulations. Repeat Finding: No Recommendation: We recommend the University implement a process to ensure any credit balances resulting from Federal Student Financial Aid are returned directly to the student within the 14-day time frame imposed by the U.S. Department of Education. Views of responsible officials: There is no disagreement with the audit finding.

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2020 ? 001 Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster CFDA Number: 84.SFA Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2019 ? May 31, 2020 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(e) states, "Whenever an institution disburses title IV, HEA program funds by crediting a student's account and the total amount of all title IV, HEA program funds credited exceeds the amount of tuition and fees, room and board, and other authorized charges the institution assessed the student, the institution must pay the resulting credit balance directly to the student or parent as soon as possible but? (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: Through our testing of 40 students whose accounts had a credit balance resulting from federal funds during the year, we noted that one student did not have the credit balance refunded within the 14 day period. Questioned costs: None. Context: During our testing, it was noted that the University was not reviewing credit balances on student accounts for credit balances caused by federal funds. Cause: Student was claimed by the University before they selected type of refund they wanted for credit balance in account. This caused student to be overlooked during refund process. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by DOE regulations. Repeat Finding: No Recommendation: We recommend the University implement a process to ensure any credit balances resulting from Federal Student Financial Aid are returned directly to the student within the 14-day time frame imposed by the U.S. Department of Education. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

U.S. Department of Education Bradley University respectfully submits the following corrective action plan for the year ended May 31, 2020. Audit period: June 1, 2019 ? May 31, 2020 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no findings in the current year that require a corrective action plan. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2020-001 Student Financial Aid Cluster ? CFDA No. 84.SFA Recommendation: We recommend the University implement a process to ensure any credit balances resulting from Federal Student Financial Aid are returned directly to the student within the 14-day time frame imposed by the U.S. Department of Education. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has reviewed policies and procedures regarding Federal Student Financial Aid credit balances. The University will review student accounts for credit balances weekly to ensure credit balances are distributed to students in accordance with the 14-day time frame imposed by the U.S. Department of Education. The University has also taken steps to add additional weekly dates for refunds to be processed to ensure compliance with the 14-day time frame imposed by the U.S. Department of Education. Name(s) of the contact person(s) responsible for corrective action: Ryan Schmidgall, Assistant Controller Planned completion date for corrective action plan: 8/31/2020 If the U.S. Department of Education has questions regarding this plan, please call Deb Jackson at 309-677-3085.

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FY 2019-05-31

FAC accepted this audit on October 29, 2019 — management decision was due April 29, 2020.

2019-001
Eligibility

Through our testing of eight student timesheets for students who received federal funds during 2018-2019, one student did not have a properly approved timesheet for the period September 9 ? 18, 2018. Questioned costs: None. Context: During our testing, it was noted that in one instance in our sample the University did not review and approve the timesheet of a student receiving federal work study monies. Cause: Review by supervisor was missed before payroll was processed. Effect: The University did not approve timesheet of student under federal mandate for students receiving federal work study monies. Repeat Finding: No Recommendation: We recommend the University reinforce the process in place to ensure that all students receiving federal work study money have timesheets which are properly reviewed and signed off to evidence approval. Views of responsible officials: There is no disagreement with the audit finding.

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2019 ? 001 Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster CFDA Number: 84.SFA Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: June 1, 2018 ? May 31, 2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 675.19(b) states, ?The institution must also establish and maintain program and fiscal records that include a certification by the student?s supervisor, an official of the institution or off-campus agency that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day.? Condition: Through our testing of eight student timesheets for students who received federal funds during 2018-2019, one student did not have a properly approved timesheet for the period September 9 ? 18, 2018. Questioned costs: None. Context: During our testing, it was noted that in one instance in our sample the University did not review and approve the timesheet of a student receiving federal work study monies. Cause: Review by supervisor was missed before payroll was processed. Effect: The University did not approve timesheet of student under federal mandate for students receiving federal work study monies. Repeat Finding: No Recommendation: We recommend the University reinforce the process in place to ensure that all students receiving federal work study money have timesheets which are properly reviewed and signed off to evidence approval. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

U.S. Department of Education Bradley University respectfully submits the following corrective action plan for the year ended May 31, 2019. Audit period: June 1, 2018 ? May 31, 2019 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no findings in the current year that require a corrective action plan. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2019-001 Student Financial Aid Cluster ? CFDA No. 84.SFA Recommendation: We recommend the University implement a process to ensure that all students receiving federal work study money have proper sign off and approval before payroll is processed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has reviewed policies and procedures regarding Federal Student Financial Aid work study recipient?s timesheet approval. Effective immediately, the Payroll Office will verify that all electronic timesheets submitted for payment have the appropriate manager approval. If a manager is nonresponsive or fails to approve the electronic student time sheet within the required time period, the Payroll Office will contact the manager?s immediate supervisor or respective Dean?s Office or Vice President?s Office to obtain the required authorization for electronic Student Payroll time sheet approval. Name(s) of the contact person(s) responsible for corrective action: Marianne Rees, Director of Payroll Planned completion date for corrective action plan: 09/06/2019 If the U.S. Department of Education has questions regarding this plan, please call Deb Jackson at 309-677-3085.

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FY 2018-05-31

FAC accepted this audit on November 1, 2018 — management decision was due May 1, 2019.

2018-001
Other

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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FY 2016-05-31

FAC accepted this audit on November 29, 2016 — management decision was due May 29, 2017.

2016-001
Special Tests & Provisions
QUESTIONED COSTS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2016-002
Special Tests & Provisions
REPEAT

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2015-002

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