EIN: 381393841
UEI: JTGMMMLAU6D4
Audited by: CapinCrouse LLC
Oversight agency: 84 [Department of Education]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 9, 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 9, 2026 (81 days ago).
What is a management decision? →FAC accepted this audit on January 17, 2025 — management decision was due July 17, 2025.
When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid accurately or timely. Criteria: 34 CFR 668.22 and 34 CFR 690.63 Questioned Costs: $8,683 Context: Out of 23 students tested, 4 students had returns totaling $7,626 ranging from 18 to 123 days late. 1 student had $1,429 of federal direct loans returned but then incorrectly disbursed back to the student. These funds were returned back to the Department of Education in September 2024, 247 days late. 1 student had an R2T4 calculated but the unearned funds totaling $5,912 have not yet been returned. 6 students had miscalculations due to Pell not being recalculated for classes the student didn’t begin attendance prior to the R2T4 calculation which resulted in $1,342 of Pell under returned and $463 of federal direct loans (FDL) over returned. 4 students had miscalculations due to incorrect break days used resulting in $9 of Pell and $197 of FDL over returned. Cause: Complexity of R2T4 calculations. Break days not properly factored into the calculation. Pell not properly recalculated prior to the R2T4 calculation for classes students didn't begin attendance in. Effect: Noncompliance with R2T4 regulations Identification as repeat finding, if applicable: 2023-004 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review standard and modular students’ R2T4 calendars, calculations and returns to help ensure that internal controls over such processes can operate effectively and achieve compliance. We further recommend the University adjust procedures to identify whether any Pell recalculations are required to be completed first before the R2T4 calculation is completed. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063, 84.268, and 84.007 Federal Award Identification #: 2023-2024 Award Year Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid accurately or timely. Criteria: 34 CFR 668.22 and 34 CFR 690.63 Questioned Costs: $8,683 Context: Out of 23 students tested, 4 students had returns totaling $7,626 ranging from 18 to 123 days late. 1 student had $1,429 of federal direct loans returned but then incorrectly disbursed back to the student. These funds were returned back to the Department of Education in September 2024, 247 days late. 1 student had an R2T4 calculated but the unearned funds totaling $5,912 have not yet been returned. 6 students had miscalculations due to Pell not being recalculated for classes the student didn’t begin attendance prior to the R2T4 calculation which resulted in $1,342 of Pell under returned and $463 of federal direct loans (FDL) over returned. 4 students had miscalculations due to incorrect break days used resulting in $9 of Pell and $197 of FDL over returned. Cause: Complexity of R2T4 calculations. Break days not properly factored into the calculation. Pell not properly recalculated prior to the R2T4 calculation for classes students didn't begin attendance in. Effect: Noncompliance with R2T4 regulations Identification as repeat finding, if applicable: 2023-004 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review standard and modular students’ R2T4 calendars, calculations and returns to help ensure that internal controls over such processes can operate effectively and achieve compliance. We further recommend the University adjust procedures to identify whether any Pell recalculations are required to be completed first before the R2T4 calculation is completed. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Planned Corrective Action: See Below Cleary University identified compliance gaps in its Return of Title IV Funds (R2T4) reporting processes during the 2023-2024 award year. These issues stemmed from a lack of timely enforcement of procedures and misinterpretation of R2T4 regulatory requirements, necessitating immediate corrective action and leadership changes. The Financial Aid Director was dismissed, and an experienced Assistant Vice President (AVP) of Financial Aid was hired to oversee compliance and ensure accurate implementation of federal regulations. Additional Financial Aid Data Specialists were hired to improve system efficiency and accuracy. An R2T4 Task force was established, meeting weekly to review Last Day of Attendance (LDA) data, monitor student drop processes, and ensure timely R2T4 calculations and funds returned. A structured process for R2T4 calculations was put in place, with cross-referencing from the Records Department, maintaining through documentation, and improving tracking and reporting. Cleary University has taken significant steps to address the issues and ensure compliance with R2T4 regulations. The revised process, implemented in July 2024, aims to prevent future delays and findings. Weekly checks and ongoing training will ensure that R2T4 processing is accurate, timely, and fully complaint with federal requirements, with a target processing completion of 20 days. Person Responsible for Corrective Action Plan: JoAnn Ross, Vice President of Financial Aid Anticipated Date of Completion: December 18, 2024
2023-004
The NSLDS enrollment status was not properly reported for some students, primarily those who withdrew from the University. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 77 students tested, 5 students who withdrew were still being reported as enrolled to NSLDS. 2 students were reported as “no record found” but both had federal direct loans disbursed during the year. Cause: The registrar's office was not completing timely reconciliations of enrollment statuses throughout the year. Effect: The incorrect reporting impacts the student's loan grace period, in school deferment eligibility, beginning loans payments, appropriate interest charges, etc. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the University put a system in place to ensure that students who withdraw either officially or unofficially during a term be checked for proper reporting to NSLDS as part of the R2T4 process. We also recommend that the University is periodically completing reconciliations of enrollment statuses and completing spot checks of enrollment statuses to NSLDS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2023-2024 Award Year Condition: The NSLDS enrollment status was not properly reported for some students, primarily those who withdrew from the University. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 77 students tested, 5 students who withdrew were still being reported as enrolled to NSLDS. 2 students were reported as “no record found” but both had federal direct loans disbursed during the year. Cause: The registrar's office was not completing timely reconciliations of enrollment statuses throughout the year. Effect: The incorrect reporting impacts the student's loan grace period, in school deferment eligibility, beginning loans payments, appropriate interest charges, etc. Identification as repeat finding, if applicable: N/A Recommendation: We recommend the University put a system in place to ensure that students who withdraw either officially or unofficially during a term be checked for proper reporting to NSLDS as part of the R2T4 process. We also recommend that the University is periodically completing reconciliations of enrollment statuses and completing spot checks of enrollment statuses to NSLDS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: A new Registrar was hired in late May of 2024. A new process was implemented for the Fall semester of 2024 to ensure timely and accurate processing of official and unofficial withdrawals. Outcome: All student withdrawal requests both official and unofficial are processed daily and tracked in a shared workbook. This allows information about each individual withdrawal request to be captured and available for both the Business Office and Financial Aid. Date of Determination, Last Date of Attendance, Processed Date, withdrawal type, withdrawal reason, and credits impacted are all captured in the workbook to aid with R2T4 calculations. This workbook also serves as a document that can be audited in real-time to ensure accuracy of each student’s record. A Standard Operating Procedure was developed and used to train the team members effective on 8/12/2024. Person Responsible for Corrective Action Plan: Tonya Troka, University Registrar & Assistant Provost Anticipated Date of Completion: Completed and implemented for Fall 2024 Semester
The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The University has made progress from the prior year on GLBA compliance. The University has one remaining area left to implement relating to sufficient vendor management policies and reviews. Cause: The University has prioritized resources to address and document compliance with multi-factor authentication and risk assessment evaluation before implementing the vendor management requirements of GLBA. Effect: The University has not adequately addressed all the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Yes, 2023-003 Recommendation: We recommend the University allocate sufficient resources to address all remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 Student Financial Assistance Cluster Federal Award Identification #: 2023-2024 Award Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The University has made progress from the prior year on GLBA compliance. The University has one remaining area left to implement relating to sufficient vendor management policies and reviews. Cause: The University has prioritized resources to address and document compliance with multi-factor authentication and risk assessment evaluation before implementing the vendor management requirements of GLBA. Effect: The University has not adequately addressed all the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Yes, 2023-003 Recommendation: We recommend the University allocate sufficient resources to address all remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: To address the GLBA finding regarding sufficient vendor management policies and reviews, we are actively enhancing our oversight process by collecting security attestations (SOC or HECVAT) from all vendors. These attestations are being evaluated and translated into our newly developed risk matrix, which aligns with our broader risk management framework. This approach allows us to systematically assess each vendor's security posture and assign corresponding risk levels, ensuring compliance with GLBA requirements and supporting informed decision-making in vendor relationships Person Responsible for Corrective Action Plan: Eric Riddering, Chief Information Officer Anticipated Date of Completion: June 30, 2025
2023-003
FAC accepted this audit on February 15, 2024 — management decision was due August 15, 2024.
The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The University has not documented each component of GLBA as required. This includes documenting an information security program, documenting the security risk assessment and safeguards, including general threats, implementing multi-factor authentication on all systems containing personally identifiable information (PII), implementing continuous monitoring, such as penetration testing and vulnerability scanning, implementing sufficient vendor management policies and reviews, and providing a written, annual report to the board covering all required areas. Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033-Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The University has not documented each component of GLBA as required. This includes documenting an information security program, documenting the security risk assessment and safeguards, including general threats, implementing multi-factor authentication on all systems containing personally identifiable information (PII), implementing continuous monitoring, such as penetration testing and vulnerability scanning, implementing sufficient vendor management policies and reviews, and providing a written, annual report to the board covering all required areas. Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: Cleary understands that GLBA requires universities and other institutions to create controls concerning the handling of data in conformance with best practices in cybersecurity. We realize that it is vital for us to be fully compliant to safeguard our institution's and our students' sensitive information, and we have put in place a robust set of activities and services. The GLBA requires us to implement administrative, technical, and physical safeguards to protect the security and confidentiality of non-public personal information (NPI). Some of these requirements have been addressed in the past fiscal year, and the rest are currently being implemented in this fiscal year. Person Responsible for Corrective Action Plan: Eric Riddering, Director of Information Technology Anticipated Date of Completion: October 2024
When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid accurately or timely. Criteria: 34 CFR 668.22 and 34 CFR 690.63 Questioned Costs: $11,226 Context: Out of 25 students tested, three modular students who did not meet the exemption rules for modular students, resulted in late returns and incorrect Pell recalculations. Pell should have been recalculated for failure to begin attendance in all classes awarded and those funds returned prior to completing the R2T4. This resulted in under returns totaling $3,709 of Pell, $300 of FSEOG and $1,831 of Federal Direct loans (FDL). The exceptions were corrected during the audit in November 2023. Two students in a distance education modular program did not have documented academic engagement to establish attendance in each module, therefore not meeting an exemption and should have an R2T4 completed. This resulted in a late return of $1,159 for Pell and $2,001 for FDL. These exceptions were corrected during the audit in November 2023. A return was never made for another traditional student who did not participate past 60% of the semester resulting in a late return of $837 for Pell. This exception was corrected during the audit in November 2023. One modular student had the incorrect amount returned due to an incorrect R2T4 calculation resulting in an under-return of $1,374 of Pell and $15 of FDL. This exception was corrected during the audit in November 2023. Two other students had the correct amount returned however they were returned after the 45 day return window. The returns totaling $7,589 were late between 154-199 days. Cause: This was an oversight by the University. Students in modular programs who withdrew either officially or unofficially did not meet an exemption but no R2T4 was completed. Pell was not recalculated for classes that students did not begin attendance in. Effect: Noncompliance with new R2T4 regulations regarding withdrawals from modular programs, return of Title IV funds were not performed timely and incorrect amounts of federal funding were returned. Identification as repeat finding, if applicable: 2022-004 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review standard and modular students R2T4 calculations and returns to help ensure that internal controls over such processes can operate effectively and achieve compliance. As part of this process, we also recommend reviewing students with Title IV aid that have no passing grades in a module or term for potential unofficial withdraws and document determination as to whether or not an R2T4 is required. We further recommend the University adjust procedures to identify whether any Pell recalculations are required to be completed first before the R2T4 calculation is completed. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063, 84.263 and 84.007 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid accurately or timely. Criteria: 34 CFR 668.22 and 34 CFR 690.63 Questioned Costs: $11,226 Context: Out of 25 students tested, three modular students who did not meet the exemption rules for modular students, resulted in late returns and incorrect Pell recalculations. Pell should have been recalculated for failure to begin attendance in all classes awarded and those funds returned prior to completing the R2T4. This resulted in under returns totaling $3,709 of Pell, $300 of FSEOG and $1,831 of Federal Direct loans (FDL). The exceptions were corrected during the audit in November 2023. Two students in a distance education modular program did not have documented academic engagement to establish attendance in each module, therefore not meeting an exemption and should have an R2T4 completed. This resulted in a late return of $1,159 for Pell and $2,001 for FDL. These exceptions were corrected during the audit in November 2023. A return was never made for another traditional student who did not participate past 60% of the semester resulting in a late return of $837 for Pell. This exception was corrected during the audit in November 2023. One modular student had the incorrect amount returned due to an incorrect R2T4 calculation resulting in an under-return of $1,374 of Pell and $15 of FDL. This exception was corrected during the audit in November 2023. Two other students had the correct amount returned however they were returned after the 45 day return window. The returns totaling $7,589 were late between 154-199 days. Cause: This was an oversight by the University. Students in modular programs who withdrew either officially or unofficially did not meet an exemption but no R2T4 was completed. Pell was not recalculated for classes that students did not begin attendance in. Effect: Noncompliance with new R2T4 regulations regarding withdrawals from modular programs, return of Title IV funds were not performed timely and incorrect amounts of federal funding were returned. Identification as repeat finding, if applicable: 2022-004 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review standard and modular students R2T4 calculations and returns to help ensure that internal controls over such processes can operate effectively and achieve compliance. As part of this process, we also recommend reviewing students with Title IV aid that have no passing grades in a module or term for potential unofficial withdraws and document determination as to whether or not an R2T4 is required. We further recommend the University adjust procedures to identify whether any Pell recalculations are required to be completed first before the R2T4 calculation is completed. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Planned Corrective Action: The University understands and concurs with the incorrect and untimely return of some Title IV funds. In response, the University has taken three (3) immediate steps to address this deficiency in the future. First, the institution has added financial aid staff with significant expertise and experience in the administration of the R2T4 process to periodically review standard and modular students R2T4 to ensure accurate, timely and compliant returns and reporting. Second, the University has identified policy and procedure improvements that align with best practice approaches to R2T4 administration in support of Pell recalculations and accurate return of funds. Finally, the institution has identified professional development opportunities for all financial aid, and associated personnel, to improve theoretical and practical awareness and implementation of the return process i.e., conference/webinar participation, in-house training workshops and discussions, identified liaison/unit champion roles, etc. Person Responsible for Corrective Action Plan: Michael Mathis, Director of Financial Aid Anticipated Date of Completion: January 2024
2022-004
Detailed reconciliations between COD and the University student information system were not performed. Criteria: 34CFR 668.164(a) Questioned Costs: $0 Context: Of the three months of reconciliations that were tested, it was noted that the reconciliations between COD and the University student information system were performed on a batch basis and were not on a student-by-student basis. Cause: Oversight by the University. The reconciliations of University records to COD were not completed on a student-by-student basis. Effect: Potential differences between the system and COD resulting in inaccurate student Title IV records. Identification as repeat finding, if applicable: 2022-006 Recommendation: We recommend that the University implement procedures to monthly reconcile FDL and Pell disbursements to individual student accounts with disbursements reported to COD. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴DEPARTMENT OF EDUCATION ALN #: 84.063 and 84.263 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Detailed reconciliations between COD and the University student information system were not performed. Criteria: 34CFR 668.164(a) Questioned Costs: $0 Context: Of the three months of reconciliations that were tested, it was noted that the reconciliations between COD and the University student information system were performed on a batch basis and were not on a student-by-student basis. Cause: Oversight by the University. The reconciliations of University records to COD were not completed on a student-by-student basis. Effect: Potential differences between the system and COD resulting in inaccurate student Title IV records. Identification as repeat finding, if applicable: 2022-006 Recommendation: We recommend that the University implement procedures to monthly reconcile FDL and Pell disbursements to individual student accounts with disbursements reported to COD. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Detailed Reconciliations Between Common Origination and Disbursement (COD) and University Records Planned Corrective Action: The University understands and concurs with the auditors finding to the lack of a detailed reconciliation between the Common Origination and Disbursement (COD) and University Records. While Cleary was reconciling monthly totals between the COD and University Records; it was brought to our attention during the audit that it needed to be in greater detail. Going forward, the plan of action will be that on a monthly basis; reports will be generated from the COD (Loan and Pell Disbursement Detail Reports) and compared to the Student Information System (SIS). This will be completed monthly on a student-by-student detailed basis. This will be completed by the Financial Aid Department with the assistance of the Business Office to ensure that accuracy. A copy of the monthly reconciliation will be saved in our Month End Folder; for Leadership to review at any time. Person Responsible for Corrective Action Plan: Michael Mathis, Director of Financial Aid Anticipated Date of Completion: January 2024
2022-006
FAC accepted this audit on May 4, 2023 — management decision was due November 4, 2023.
2022-003 ? Subsidized Loans Awarded to Student without Financial Need Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The University is responsible for ensuring only students with financial need receive direct subsidized loans. Condition. The University provided a direct subsidized loan to a student without financial need. Cause. This condition appears to have been caused by management not reviewing the student's information prior to processing financial aid. Effect. As a result of this condition, the University did not fully comply with student financial aid eligibility requirements. Questioned Costs. The amount of known questioned costs identified is below the required reporting threshold of $25,000. Recommendation. We recommend that management review their current practices and policies for reviewing student information to provide the correct type of financial aid to students. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴2022-003 ? Subsidized Loans Awarded to Student without Financial Need Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The University is responsible for ensuring only students with financial need receive direct subsidized loans. Condition. The University provided a direct subsidized loan to a student without financial need. Cause. This condition appears to have been caused by management not reviewing the student's information prior to processing financial aid. Effect. As a result of this condition, the University did not fully comply with student financial aid eligibility requirements. Questioned Costs. The amount of known questioned costs identified is below the required reporting threshold of $25,000. Recommendation. We recommend that management review their current practices and policies for reviewing student information to provide the correct type of financial aid to students. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-003 ? Subsidized Loans Awarded to Student without Financial Need Auditor Description of Condition and Effect. The University provided a direct subsidized loan to a student without financial need. As a result of this condition, the University did not fully comply with student financial aid eligibility requirements. Auditor Recommendation. We recommend that management review their current practices and policies for reviewing student information to provide the correct type of financial aid to students. Corrective Action. The one instance noted in this finding for $1,361 was discovered in 2022-23 and the only one of its kind that Management is aware of. Once the University became aware of it, the student was notified, and the correction was made in Common Origination and Disbursement in the 2021-22 fiscal year. New qualified staff has been added to the Business Office and new student accounts software was implemented in Spring of 2022 that reviews need and grade level and awards loans properly. Responsible Person. Alan Drimmer Anticipated Completion Date: 11/16/2022
2022-004 ? Late Return of Title IV Funds Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The University is responsible for returning the Title IV funds no later than 45 business days (or within 30 days for students that never began attendance) after the date the University determined that the student withdrew. Condition. The University returned Title IV funds of $28 after the prescribed 45 day window for one student tested out of a population of one. Cause. This condition appears to have been caused by a lack oversight of outstanding Title IV funds. Effect. As a result of this condition, the University did not fully comply with the special tests and provisions requirements. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that management review their current practices and policies for reviewing Title IV funds associated with students who withdraw. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴2022-004 ? Late Return of Title IV Funds Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The University is responsible for returning the Title IV funds no later than 45 business days (or within 30 days for students that never began attendance) after the date the University determined that the student withdrew. Condition. The University returned Title IV funds of $28 after the prescribed 45 day window for one student tested out of a population of one. Cause. This condition appears to have been caused by a lack oversight of outstanding Title IV funds. Effect. As a result of this condition, the University did not fully comply with the special tests and provisions requirements. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that management review their current practices and policies for reviewing Title IV funds associated with students who withdraw. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-004 ? Late Return of Title IV Funds Auditor Description of Condition and Effect. The University returned Title IV funds of $28 after the prescribed 45 day window for one student tested out of a population of one. As a result of this condition, the University did not fully comply with the special tests and provisions requirements. Auditor Recommendation. We recommend that management review their current practices and policies for reviewing Title IV funds associated with students who withdraw. Corrective Action: The University recognizes the error of not returning this $28 in a timely manner. At the time, the University had only one individual, the senior financial aid advisor, with this responsibility and the staff member had a serious personal emergency which caused the delay. We have now implemented a new procedure and provided cross training to other staff members who can now return federal funds. Responsible Person. Alan Drimmer Anticipated Completion Date: 10/24/2022
2022-005 ? Timeliness of Student Status Changes Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The Uniform Guidance Compliance Supplement provides guidance that a University should report status changes to the National Student Loan Data System (NSLDS) within 30 days whenever a student's attendance changes, unless a roster will be submitted within 60 days. Condition. We noted that four students out of a testing population of 17 were not reported timely to NSLDS. Cause. This condition appears to have been caused by staff at the University not submitting reports to the NSLDS in regular intervals. Effect. As a result of this condition, the University reported four students whose status was reduced from full-time to three-quarter time to the NSLDS after the 60 day deadline. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that the College implement procedures to report status changes for all students on a timely basis and to maintain documented procedures for enrollment reporting to prevent untimely reporting in the future. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴2022-005 ? Timeliness of Student Status Changes Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The Uniform Guidance Compliance Supplement provides guidance that a University should report status changes to the National Student Loan Data System (NSLDS) within 30 days whenever a student's attendance changes, unless a roster will be submitted within 60 days. Condition. We noted that four students out of a testing population of 17 were not reported timely to NSLDS. Cause. This condition appears to have been caused by staff at the University not submitting reports to the NSLDS in regular intervals. Effect. As a result of this condition, the University reported four students whose status was reduced from full-time to three-quarter time to the NSLDS after the 60 day deadline. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that the College implement procedures to report status changes for all students on a timely basis and to maintain documented procedures for enrollment reporting to prevent untimely reporting in the future. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-005 ? Timeliness of Student Status Changes Auditor Description of Condition and Effect. We noted that four students out of a testing population of 17 were not reported timely to NSLDS. As a result of this condition, the University reported four students whose status was reduced from full-time to three-quarter time to the NSLDS after the 60 day deadline. Auditor Recommendation. We recommend that the College implement procedures to report status changes for all students on a timely basis and to maintain documented procedures for enrollment reporting to prevent untimely reporting in the future. Corrective Action: The University acknowledges the error. There is now a monthly procedure in place to report student status changes to the NSLDS documented in Standard Operating Procedures. Responsible Person. Alan Drimmer Anticipated Completion Date: 1/15/2023
2022-006 ? Review of Reconciliations Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The Uniform Guidance Compliance Supplement provides guidance that the University is required each month to reconcile the School Account Statements data file provided by the Common Origination & Disbursement (COD) to the University's financial records. Condition. We noted a variance for Pell disbursements between the University's financial records and the COD. Cause. This condition appears to have been caused by cash refunds not being considered and reconciliations not being subject to independent review. Effect. As a result of this condition, the University initially overstated Pell disbursements on its SEFA by $44,941 and an adjustment was required to be made. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that the University implement procedures to review monthly reconciliations for accuracy. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴2022-006 ? Review of Reconciliations Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Aid Cluster; CFDA Numbers 84.007, 84.033, 84.063, 84.268. Criteria. The Uniform Guidance Compliance Supplement provides guidance that the University is required each month to reconcile the School Account Statements data file provided by the Common Origination & Disbursement (COD) to the University's financial records. Condition. We noted a variance for Pell disbursements between the University's financial records and the COD. Cause. This condition appears to have been caused by cash refunds not being considered and reconciliations not being subject to independent review. Effect. As a result of this condition, the University initially overstated Pell disbursements on its SEFA by $44,941 and an adjustment was required to be made. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Recommendation. We recommend that the University implement procedures to review monthly reconciliations for accuracy. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-006 ? Review of Reconciliations Auditor Description of Condition and Effect. We noted a variance for Pell disbursements between the University's financial records and the COD. As a result of this condition, the University initially overstated Pell disbursements on its SEFA by $44,941 and an adjustment was required to be made. Auditor Recommendation. We recommend that the University implement procedures to review monthly reconciliations for accuracy. Corrective Action: The University had a change in senior financial management and along with that broader access to G5 which in turn has allowed for additional procedures for monthly reconciliation of federal awards to the internal accounting system. We believe this will prevent this type of error from occurring in the future. Responsible Person. Alan Drimmer Anticipated Completion Date: 3/15/2023
2022-007 ? Higher Education Emergency Relief Funds Earmarking Requirements Finding Type. Material Noncompliance/Material Weakness in Internal Control over Compliance (Earmarking/Allowable Costs/Cost Principles). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. The University is required to use Higher Education Emergency Relief Funds (HEERF) in accordance with the applicable law under which the funds were appropriated. At least 50% of HEERF I funds, appropriated under the Coronavirus Aid, Relief, and Economic Security Act (CARES), must be reserved to provide students with emergency financial aid grants. Under HEERF II, appropriated under the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), the University must provide at least the same amount of funding in financial aid grants to students as was required under its student aid portion of HEERF I. HEERF III, appropriated under the American Rescue Plan, requires a portion of funds must be used to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines and conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student. The student portion of HEERF awards must be used to provide students with emergency financial aid grants. Condition. The University had excess funds after disbursing to students from the student portion of HEERF III emergency financial aid grants. Management discharged outstanding student balances using the excess student portion of HEERF III. Management advised students the funds could be applied to outstanding balances; however, students were not given the option to receive a cash payment in lieu of being applied to outstanding balances. Management also did not maintain detail records tracking how HEERF funds were spent across HEERF I, HEERF II, and HEERF III. Cause. This condition appears to have been caused by management lacking the appropriate knowledge and understanding of the grant requirements. Additionally, there was not appropriate oversight of accounting personnel involved in the grant management to ensure the appropriate level of detailed recordkeeping was being performed. Effect. As a result of this condition, the student portion of HEERF III was used for a purpose other than to provide emergency financial aid grants to students. The University partially discharged the existing student balance of 31 students amounting to $88,958. The University did not spend the required cumulative minimum of the student portion on allowable costs. Questioned Costs. $88,958 in questioned costs have been identified. Recommendation. We recommend management and accounting personnel with involvement in federal funding attend grant specific trainings and that the University maintain detailed records to allow the proper tracking of federal expenditures on a grant level basis. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴2022-007 ? Higher Education Emergency Relief Funds Earmarking Requirements Finding Type. Material Noncompliance/Material Weakness in Internal Control over Compliance (Earmarking/Allowable Costs/Cost Principles). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. The University is required to use Higher Education Emergency Relief Funds (HEERF) in accordance with the applicable law under which the funds were appropriated. At least 50% of HEERF I funds, appropriated under the Coronavirus Aid, Relief, and Economic Security Act (CARES), must be reserved to provide students with emergency financial aid grants. Under HEERF II, appropriated under the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), the University must provide at least the same amount of funding in financial aid grants to students as was required under its student aid portion of HEERF I. HEERF III, appropriated under the American Rescue Plan, requires a portion of funds must be used to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines and conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student. The student portion of HEERF awards must be used to provide students with emergency financial aid grants. Condition. The University had excess funds after disbursing to students from the student portion of HEERF III emergency financial aid grants. Management discharged outstanding student balances using the excess student portion of HEERF III. Management advised students the funds could be applied to outstanding balances; however, students were not given the option to receive a cash payment in lieu of being applied to outstanding balances. Management also did not maintain detail records tracking how HEERF funds were spent across HEERF I, HEERF II, and HEERF III. Cause. This condition appears to have been caused by management lacking the appropriate knowledge and understanding of the grant requirements. Additionally, there was not appropriate oversight of accounting personnel involved in the grant management to ensure the appropriate level of detailed recordkeeping was being performed. Effect. As a result of this condition, the student portion of HEERF III was used for a purpose other than to provide emergency financial aid grants to students. The University partially discharged the existing student balance of 31 students amounting to $88,958. The University did not spend the required cumulative minimum of the student portion on allowable costs. Questioned Costs. $88,958 in questioned costs have been identified. Recommendation. We recommend management and accounting personnel with involvement in federal funding attend grant specific trainings and that the University maintain detailed records to allow the proper tracking of federal expenditures on a grant level basis. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-007 ? Higher Education Emergency Relief Funds Earmarking Requirements Auditor Description of Condition and Effect. The University had excess funds after disbursing to students from the student portion of HEERF III emergency financial aid grants. Management discharged outstanding student balances using the excess student portion of HEERF III. Management advised students the funds could be applied to outstanding balances; however, students were not given the option to receive a cash payment in lieu of being applied to outstanding balances. Management also did not maintain detail records tracking how HEERF funds were spent across HEERF I, HEERF II, and HEERF III. As a result of this condition, the student portion of HEERF III was used for a purpose other than to provide emergency financial aid grants to students. The University partially discharged the existing student balance of 31 students amounting to $88,958. The University did not spend the required cumulative minimum of the student portion on allowable costs. Auditor Recommendation. We recommend management and accounting personnel with involvement in federal funding attend grant specific trainings and that the University maintain detailed records to allow the proper tracking of federal expenditures on a grant level basis. "Corrective Action: The University better understands the tracking requirements and the University will ensure any future funds are tracked appropriately based on the grant guidelines. Specifically with respect to HEERF III disbursements, Cleary agrees with the finding. After disbursing HEERF III funds to each student, some students had remaining outstanding balances. Management was concerned for a subset of 31 students who still had large remaining balances and were in danger of having that balance sent to a collection agency. So the remaining funds available were applied to the balances of those students. In other communications to students, the University had in the past offered students the option of applying the funds to their accounts or taking the amount in cash. Due to an oversight, the University did not offer that option to students in this circumstance. The University should have presented students with the option of receiving the HEERF funds in cash rather than having it applied to their student account. The University is in the process of drafting a communication to each of the 31 individual students affected, making them aware that Cleary applied HEERF funds to their outstanding student balances but should have offered a cash payment option. The letter will state that Cleary can issue cash disbursements if the student contacts the Student Accounts office. The communication also makes it clear to students that this will create a balance due on their current student account that must be satisfied before they can re-register for classes. In addition, Business Office and Financial Aid staff involved in federal funding will attend grant-specific training on an annual basis." Responsible Person. Alan Drimmer Anticipated Completion Date: 4/20/2023
2022-008 ? Purchases Made Outside of the University's Procurement Process Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension, and Debarment). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. The University is required to make purchases in accordance with its procurement policy. Per the University's procurement policy, the University must receive quotes from at least three different sources, and files must be maintained for all quotes, for medium to large purchases ($10,000 to $150,000). Condition. Of the four disbursements tested from the institutional portion, two instances were noted where the University made medium to large purchases amounting to $72,802 where management did not maintain supporting documentation for each quote received. Cause. This condition appears to have been caused by management not following the University's internal policies, and supporting documentation not being maintained by management. Effect. As a result of this condition, the University did not follow its procurement policy. Questioned Costs. No costs have been questioned as a result of this finding inasmuch no unallowable costs have been identified. Recommendation. We recommend management train employees on the University's policies and procedures. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴2022-008 ? Purchases Made Outside of the University's Procurement Process Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension, and Debarment). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. The University is required to make purchases in accordance with its procurement policy. Per the University's procurement policy, the University must receive quotes from at least three different sources, and files must be maintained for all quotes, for medium to large purchases ($10,000 to $150,000). Condition. Of the four disbursements tested from the institutional portion, two instances were noted where the University made medium to large purchases amounting to $72,802 where management did not maintain supporting documentation for each quote received. Cause. This condition appears to have been caused by management not following the University's internal policies, and supporting documentation not being maintained by management. Effect. As a result of this condition, the University did not follow its procurement policy. Questioned Costs. No costs have been questioned as a result of this finding inasmuch no unallowable costs have been identified. Recommendation. We recommend management train employees on the University's policies and procedures. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-008 ? Purchases Made Outside of the University's Procurement Process Auditor Description of Condition and Effect. Of the four disbursements tested from the institutional portion, two instances were noted where the University made medium to large purchases amounting to $72,802, and management did not maintain records evidencing each quote received. As a result of this condition, the University did not follow its procurement policy. Auditor Recommendation. We recommend management train employees on the University's policies and procedures. Corrective Action. The University has renewed training on its Procurement Policy. The University should always follow its Procurement Policy. In this case, the University did not have a procurement policy in place in May 2020 when the contract was signed. However, a written procurement policy has been implemented subsequent to the contract being signed. Responsible Person. Alan Drimmer Anticipated Completion Date: 7/31/2022
2022-009 ? Inaccurate Higher Education Emergency Relief Funds Special Reporting Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. Recipients of federal funds under HEERF I, HEERF II and HEERF III are required to submit public reporting on the Student Aid Portion and Institutional Portion quarterly and annually, as specified in the grant agreement and/or the ED compliance supplement which must be both timely and accurate. Condition. Management did not accurately track expenditures or maintain detailed enough records which caused inaccurate student and institutional amounts being reported on the University's website. In July 2021, a lump sum amount was recorded to the books and records for an amount equal to the University's HEERF III institutional grant award ($584,212), and actual amounts expended were not monitored. Cause. This condition appears to have been caused by management not maintaining detailed records and a lack of understanding of grant requirements. Effect. As a result of this condition, the University did not fully comply with the requirements of the HEERF grants. Questioned Costs. No costs are required to be questioned as a result of this finding, as the reports did not serve as a basis for cost-reimbursement. Recommendation. We recommend that management review the compliance requirements of each grant when received to ensure compliance with such requirements. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴2022-009 ? Inaccurate Higher Education Emergency Relief Funds Special Reporting Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. Recipients of federal funds under HEERF I, HEERF II and HEERF III are required to submit public reporting on the Student Aid Portion and Institutional Portion quarterly and annually, as specified in the grant agreement and/or the ED compliance supplement which must be both timely and accurate. Condition. Management did not accurately track expenditures or maintain detailed enough records which caused inaccurate student and institutional amounts being reported on the University's website. In July 2021, a lump sum amount was recorded to the books and records for an amount equal to the University's HEERF III institutional grant award ($584,212), and actual amounts expended were not monitored. Cause. This condition appears to have been caused by management not maintaining detailed records and a lack of understanding of grant requirements. Effect. As a result of this condition, the University did not fully comply with the requirements of the HEERF grants. Questioned Costs. No costs are required to be questioned as a result of this finding, as the reports did not serve as a basis for cost-reimbursement. Recommendation. We recommend that management review the compliance requirements of each grant when received to ensure compliance with such requirements. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-009 ? Inaccurate Higher Education Emergency Relief Funds Reporting Auditor Description of Condition and Effect. Management did not accurately track expenditures or maintain detailed enough records which caused inaccurate student and institutional amounts being reported on the University's website. In July 2021, a lump sum amount was recorded to the books and records for an amount equal to the University's HEERF III institutional grant award ($584,212), and actual amounts expended were not monitored. As a result of this condition, the University did not fully comply with the requirements of the HEERF grants. Auditor Recommendation. We recommend that management review the compliance requirements of each grant when received to ensure compliance with such requirements. Corrective Action: The University understands that the HEERF funds should have been recorded as revenue and expense items even if all the funds were being given directly to students. This procedure has been documented in our Standard Operating Procedures and the error will not occur again. Responsible Person. Alan Drimmer Anticipated Completion Date: 10/31/2022
2022-010 ? Incorrect Tuition Amount used to Calculate Award/Student did not Receive Emergency Financial Aid Grant Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Cash Managment). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. The University is required to disburse funds from the student portion within 15 days and the institutional portion within three days of the drawdown from G5 or in accordance with the University's cash management policy if more restrictive than the prescribed guidance. Condition. Management prepared a manual spreadsheet to calculate student emergency aid grants based on outstanding student balances. Of the 40 students tested, two students were identified where the incorrect outstanding balance was used to calculate the student emergency aid grant, and one student was identified who was awarded emergency aid, however, the award was not paid to the student. Cause. This condition appears to have been caused by a lack of oversight of accounting personnel and reconciliations not being subject to independent review. Effect. As a result of this condition, the University overdrew funds from G5 in the total amount of $800 and failed to pay award to a student in the amount of $500. Questioned Costs. No costs have been questioned as a result of this finding inasmuch no unallowable costs have been identified. Recommendation. We recommend that the University implement procedures to review reconciliations for accuracy. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴2022-010 ? Incorrect Tuition Amount used to Calculate Award/Student did not Receive Emergency Financial Aid Grant Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Cash Managment). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F. Criteria. The University is required to disburse funds from the student portion within 15 days and the institutional portion within three days of the drawdown from G5 or in accordance with the University's cash management policy if more restrictive than the prescribed guidance. Condition. Management prepared a manual spreadsheet to calculate student emergency aid grants based on outstanding student balances. Of the 40 students tested, two students were identified where the incorrect outstanding balance was used to calculate the student emergency aid grant, and one student was identified who was awarded emergency aid, however, the award was not paid to the student. Cause. This condition appears to have been caused by a lack of oversight of accounting personnel and reconciliations not being subject to independent review. Effect. As a result of this condition, the University overdrew funds from G5 in the total amount of $800 and failed to pay award to a student in the amount of $500. Questioned Costs. No costs have been questioned as a result of this finding inasmuch no unallowable costs have been identified. Recommendation. We recommend that the University implement procedures to review reconciliations for accuracy. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-010 ? Incorrect Tuition Amount used to Calculate Award/Student did not Receive Emergency Financial Aid Grant Auditor Description of Condition and Effect. Management prepared a manual spreadsheet to calculate student emergency aid grants based on outstanding student balances. Of the 40 students tested, two students were identified where the incorrect outstanding balance was used to calculate the student emergency aid grant, and one student was identified who was awarded emergency aid, however, the award was not paid to the student. As a result of this condition, the University overdrew funds from G5 in the total amount of $800 and failed to pay award to a student in the amount of $500. Auditor Recommendation. We recommend that the University implement procedures to review reconciliations for accuracy. Corrective Action: The University acknowledges this was an oversight and has put a new procedure in place that will identify this type of error and correct it sooner. Responsible Person. Alan Drimmer Anticipated Completion Date: 4/12/2023
2022-011 ? Institutional Higher Education Emergency Relief Funds III Student Outreach Requirement Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Earmarking). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Number 84.425F. Criteria. The University is required to use a portion of Higher Education Emergency Relief Funds III (HEERF) institutional funds to (a) implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the HEA. The University must also document how the amount of the HEERF grant spent on these two required activites was reasonable and necessary given the unique needs and circumstances of the University. Condition. The University did not use a portion of the institutional HEERF III grant to conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the HEA. The University also did not document how the amount of the HEERF grant spent on these two required activities was reasonable and necessary given the unique circumstances of the University. Cause. This condition appears to have been caused by management lacking the appropriate knowledge and understanding of the grant requirements. Additionally, there was not appropriate oversight of accounting personnel involved in the grant management to ensure grant requirements were being satisfied. Effect. As a result of this condition, the University did not fully comply with the requirements of the HEERF III grant. Questioned Costs. No costs have been questioned as a result of this finding inasmuch no unallowable costs have been identified. Recommendation. We recommend that management review the compliance requirements of each grant when received to ensure compliance with such requirements. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴2022-011 ? Institutional Higher Education Emergency Relief Funds III Student Outreach Requirement Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Earmarking). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Number 84.425F. Criteria. The University is required to use a portion of Higher Education Emergency Relief Funds III (HEERF) institutional funds to (a) implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the HEA. The University must also document how the amount of the HEERF grant spent on these two required activites was reasonable and necessary given the unique needs and circumstances of the University. Condition. The University did not use a portion of the institutional HEERF III grant to conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the HEA. The University also did not document how the amount of the HEERF grant spent on these two required activities was reasonable and necessary given the unique circumstances of the University. Cause. This condition appears to have been caused by management lacking the appropriate knowledge and understanding of the grant requirements. Additionally, there was not appropriate oversight of accounting personnel involved in the grant management to ensure grant requirements were being satisfied. Effect. As a result of this condition, the University did not fully comply with the requirements of the HEERF III grant. Questioned Costs. No costs have been questioned as a result of this finding inasmuch no unallowable costs have been identified. Recommendation. We recommend that management review the compliance requirements of each grant when received to ensure compliance with such requirements. View of Responsible Officials. Management agrees with the finding. See corrective action plan.
2022-011 ? Institutional Higher Education Emergency Relief Funds III Student Outreach Requirement Auditor Description of Condition and Effect. The University did not use a portion of the institutional HEERF III grant to conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the HEA. The University also did not document how the amount of the HEERF grant spent on these two required activities was reasonable and necessary given the unique circumstances of the University. As a result of this condition, the University did not fully comply with the requirements of the HEERF III grant. Auditor Recommendation. We recommend that management review the compliance requirements of each grant when received to ensure compliance with such requirements. Corrective Action. The University will review the compliance requirements of each grant when received to ensure compliance with such requirements. The University will more properly track staff time in a detailed fashion in any similar circumstances in the future. Responsible Person. Alan Drimmer Anticipated Completion Date: 4/28/2023
FAC accepted this audit on September 29, 2022 — management decision was due March 29, 2023.
2021-001 ? Omissions in HEERF Reporting Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F and 84.425N. Criteria. Recipients of federal funds under HEERF I, HEERF II and HEERF III are required to submit public reporting on the Student Aid Portion and Institutional Portion quarterly and annually, as specified in the grant agreement and/or the ED compliance supplement. Condition. The University is required for its HEERF Grant program to file a quarterly report. During the year, the University failed to submit the required report for the Institutional Portion, including FIPSE, for at least one quarter. Cause. This condition appears to have been caused by a lack of knowledge of applicable federal compliance requirements for HEERF. Effect. As a result of this condition, the University did not fully comply with the requirements of the HEERF grants. Questioned Costs. No costs are required to be questioned as a result of this finding, as the reports did not serve as a basis for cost-reimbursement. Recommendation. We recommend that management review the compliance requirements of each grant when received to ensure compliance with such requirements. View of Responsible Officials. The University understood the requirements of the HEERF grant funding. It was an oversight to miss one quarter of reporting on our website page that lists all other quarterly reports. The reporting will be in accordance with the guidelines going forward.
Show full finding ▾Hide full finding ▴2021-001 ? Omissions in HEERF Reporting Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F and 84.425N. Criteria. Recipients of federal funds under HEERF I, HEERF II and HEERF III are required to submit public reporting on the Student Aid Portion and Institutional Portion quarterly and annually, as specified in the grant agreement and/or the ED compliance supplement. Condition. The University is required for its HEERF Grant program to file a quarterly report. During the year, the University failed to submit the required report for the Institutional Portion, including FIPSE, for at least one quarter. Cause. This condition appears to have been caused by a lack of knowledge of applicable federal compliance requirements for HEERF. Effect. As a result of this condition, the University did not fully comply with the requirements of the HEERF grants. Questioned Costs. No costs are required to be questioned as a result of this finding, as the reports did not serve as a basis for cost-reimbursement. Recommendation. We recommend that management review the compliance requirements of each grant when received to ensure compliance with such requirements. View of Responsible Officials. The University understood the requirements of the HEERF grant funding. It was an oversight to miss one quarter of reporting on our website page that lists all other quarterly reports. The reporting will be in accordance with the guidelines going forward.
2021-001 ? Omissions in HEERF Reporting Auditor Description of Condition and Effect. The University is required for its HEERF Grant program to file a quarterly report. During the year, the University failed to submit the required report for the Institutional Portion, including FIPSE, for at least one quarter. As a result of this condition, the University did not fully comply with the requirements of the HEERF grants. Auditor Recommendation. We recommend that management review the compliance requirements of each grant when received to ensure compliance with such requirements. Corrective Action. The University understood the requirements of the HEERF grant funding. It was an oversight to miss one quarter of reporting on our website page that lists all other quarterly reports. The reporting will be in accordance with the guidelines going forward. Responsible Person. Shelly Holanda and Megan Temby Anticipated Completion Date: 7/1/2021
2021-002 ? Cash Management Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Cash Management). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F, 84.425N. Criteria. The University is responsible for ensuring that the amount of cash requested as reimbursement is for the actual amount of expenditures incurred and that those expenditures incurred are reported accurately in federal financial reports as required by the grant. Furthermore, the University must abide by its cash management policy which states all awards are spent by the University prior to requesting funding from the federal agency. Condition. The University took an advanced draw of grant funds in the amount of $127,203 prior to incurring eligible expenses. The University's cash management policy requires draws to be taken on a reimbursement basis. Cause. This condition appears to have been caused by management not maintaining detailed records of eligible expenses incurred to which each drawdown was to be applied prior to initiating a draw. The University also has new staff members who lack the knowledge of the applicable federal compliance requirements. Effect. As a result of this condition, the University did not fully comply with its cash management policy. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Excess funds drawn will need to be applied to eligible costs in the following fiscal year, or returned to the grantor agency. Recommendation. We recommend that management review their current practices and policies for drawing down aid from the Federal Government and devising a plan to handle cash management in accordance with its internal policies. View of Responsible Officials. The University inadvertently drew down funds on 6/30/2021 rather than 7/1/2021, the date the funds were disbursed. The University will draw any future grant funds for expenses in the correct fiscal year.
Show full finding ▾Hide full finding ▴2021-002 ? Cash Management Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Cash Management). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Numbers 84.425E, 84.425F, 84.425N. Criteria. The University is responsible for ensuring that the amount of cash requested as reimbursement is for the actual amount of expenditures incurred and that those expenditures incurred are reported accurately in federal financial reports as required by the grant. Furthermore, the University must abide by its cash management policy which states all awards are spent by the University prior to requesting funding from the federal agency. Condition. The University took an advanced draw of grant funds in the amount of $127,203 prior to incurring eligible expenses. The University's cash management policy requires draws to be taken on a reimbursement basis. Cause. This condition appears to have been caused by management not maintaining detailed records of eligible expenses incurred to which each drawdown was to be applied prior to initiating a draw. The University also has new staff members who lack the knowledge of the applicable federal compliance requirements. Effect. As a result of this condition, the University did not fully comply with its cash management policy. Questioned Costs. No costs have been questioned as a result of this finding inasmuch as no unallowable costs have been identified. Excess funds drawn will need to be applied to eligible costs in the following fiscal year, or returned to the grantor agency. Recommendation. We recommend that management review their current practices and policies for drawing down aid from the Federal Government and devising a plan to handle cash management in accordance with its internal policies. View of Responsible Officials. The University inadvertently drew down funds on 6/30/2021 rather than 7/1/2021, the date the funds were disbursed. The University will draw any future grant funds for expenses in the correct fiscal year.
2021-002 ? Cash Management Auditor Description of Condition and Effect. The University took an advanced draw of grant funds in the amount of $127,203 prior to incurring eligible expenses. The University's cash management policy requires draws to be taken on a reimbursement basis. As a result of this condition, the University did not fully comply with its cash management policy. Auditor Recommendation. We recommend that management review their current practices and policies for drawing down aid from the Federal Government and devising a plan to handle cash management in accordance with its internal policies. Corrective Action. The University inadvertently drew down funds on 6/30/2021 rather than 7/1/2021, the date the funds were disbursed. The university will draw down funds when expenses occur as documented within our cash management policy. Responsible Person. Shelly Holanda Anticipated Completion Date: 7/1/2021
FAC accepted this audit on June 29, 2021 — management decision was due December 29, 2021.
FAC accepted this audit on March 18, 2020 — management decision was due September 18, 2020.
We observed one student whose status changed during the Winter 2019 semester that was not certified by the University until 304 days after the status effective date. Cause: This student appeared to have been missed in the NSLDS uploads. Effect: As a result of this condition, the University did not fully comply with certain compliance requirements of these grants. Further, the University is exposed to an increased risk that similar errors could occur in the future and not be detected and corrected by management. Questioned Costs: No costs have been questioned as a result of this finding inasmuch as no disallowed costs were identified. Recommendation: We recommend that the University implement crosstraining and/or additional monitoring of student status changes to ensure all changes are being certified appropriately. View of Responsible Officials: Management agrees with this finding and has prepared a corrective action plan.
Show full finding ▾Hide full finding ▴2019-001 ? Status Change Certification Finding Type: Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (special tests and provisions). Program: Student Financial Assistance Cluster; U.S. Department of Education ("ED"); CFDA Numbers 84.007, 84.033, 84.063 and 84.268. Criteria: The OMB Compliance Supplement states that the University must certify to NSLDS students that have withdrawn or graduated within 30 days of the status effective date. Condition: We observed one student whose status changed during the Winter 2019 semester that was not certified by the University until 304 days after the status effective date. Cause: This student appeared to have been missed in the NSLDS uploads. Effect: As a result of this condition, the University did not fully comply with certain compliance requirements of these grants. Further, the University is exposed to an increased risk that similar errors could occur in the future and not be detected and corrected by management. Questioned Costs: No costs have been questioned as a result of this finding inasmuch as no disallowed costs were identified. Recommendation: We recommend that the University implement crosstraining and/or additional monitoring of student status changes to ensure all changes are being certified appropriately. View of Responsible Officials: Management agrees with this finding and has prepared a corrective action plan.
2019-001 ? Status Change Certification Finding Type: Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance. Responsible Persons for Corrective Action ? Registrar and Senior Financial Aid Coordinators Corrective Action Plan: The Office of Financial Aid is committed to working with the Registrar?s office to create an audit process to manually check files sent to the National Student Clearinghouse on a batch process. Furthermore, creation of an internal indicator to flag students pursuing a degree on the same level as previously received degrees. This would allow several departments to activate the flag for these students and ensure proper follow-up and reporting to the National Student Clearinghouse. This would allow issues to be quickly and efficiently identified that possibly could have created a duplicate record by a student who is working on a lateral degree and not a higher level than the degree received upon graduation. View of Responsible Officials ? Cleary University acknowledges and agrees with the auditor?s findings and are in the process of implementing changes described above to address this finding.
FAC accepted this audit on December 9, 2018 — management decision was due June 9, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on October 30, 2017 — management decision was due April 30, 2018.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on November 21, 2016 — management decision was due May 21, 2017.
GSA_MIGRATION
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