EIN: 410693960
UEI: Z3NEG76HUKC1
Audited by: CliftonLarsonAllen LLP
Oversight agency: 84 [Department of Education]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 3, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by August 3, 2026 (33 days ago).
What is a management decision? →During our testing, we noted 2 instances out of 40 students tested where the enrollment status on the campus level and program level was correctly reported to NSLDS as withdrawal in December 2024; however, both students graduated in March 2025 and that enrollment status was not updated at the campus level or the program level. Questioned Costs: None Context: During our testing, it was noted there were two students whose enrollment status change was not updated accurately or timely. Cause: The University did not appropriately update the student's enrollment status when they changed to a graduate. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes accurately and timely. 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.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2024 through June 30, 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 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. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date as well as program enrollment effective date. This data must match the institutions' records. Condition: During our testing, we noted 2 instances out of 40 students tested where the enrollment status on the campus level and program level was correctly reported to NSLDS as withdrawal in December 2024; however, both students graduated in March 2025 and that enrollment status was not updated at the campus level or the program level. Questioned Costs: None Context: During our testing, it was noted there were two students whose enrollment status change was not updated accurately or timely. Cause: The University did not appropriately update the student's enrollment status when they changed to a graduate. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes accurately and timely. 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.
Student Financial Assistance – Assistance Listing No. Various 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 audit finding. Action taken in response to finding: Auditors identified two students for whom enrollment status on the campus level and program level was correctly reported to NSLDS as withdrawal in December 2024; however, both students graduated in March 2025 and that enrollment status was not updated at the campus level or the program level. We have a manual tracking procedure in place for students who complete missing coursework after their last term of enrollment that results in completion of their program. These two students were missed in that process. As a result of this finding, we have reviewed the procedure with the relevant staff and will continue to monitor the process, adding routine spot-checking of this tracking list. Names of the contact persons responsible for corrective action: Gwenn Sherburne, Registrar, and Lynette Wahl, Student Financial Aid Director Planned completion date for corrective action plan: October 31, 2025
FAC accepted this audit on November 8, 2024 — management decision was due May 8, 2025.
During our testing of credit balances resulting from federal funds, we noted 1 credit balance out of 40 tested where the credit balance was not refunded within the 14-day period. Questioned Costs: None Context: The student had a credit balance after spring term ended that was not refunded until the fall term. Cause: The University did not have proper procedures in place to ensure all credit balances are refunded within the 14-day period. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by Department of Education (ED) regulations. Repeat Finding: No Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2023 through June 30, 2024 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) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid 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: During our testing of credit balances resulting from federal funds, we noted 1 credit balance out of 40 tested where the credit balance was not refunded within the 14-day period. Questioned Costs: None Context: The student had a credit balance after spring term ended that was not refunded until the fall term. Cause: The University did not have proper procedures in place to ensure all credit balances are refunded within the 14-day period. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by Department of Education (ED) regulations. Repeat Finding: No Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Views of Responsible Officials: There is no disagreement with the audit finding.
Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Individual(s) responsible for processing refunds will review the current internal procedures for processing refunds and student account credits. They will also review the federal guidelines regarding Title IV funds available on fsapartners.ed.gov. After review, the Manager of student accounts will meet with this staff to ensure understanding of procedures and look for areas of improvement and opportunities for clarity. The Manager will also review current procedures to ensure documents are up-to-date and look for areas that require revision. Manager will review current reporting within the Workday system to ensure proper information is being pulled at time of running reports. Names of the contact persons responsible for corrective action: Sirena Huppert, Manager of Student Accounts Planned completion date for corrective action plan: January 1, 2025
FAC accepted this audit on February 13, 2024 — management decision was due August 13, 2024.
During our testing, we noted 5 out of the 40 students tested where the students' change in status was not reported in a timely manner. Questioned Costs: None Context: During our testing, it was noted the University identified the status changes while there was a cybersecurity breach with National Student Clearinghouse (NSC), their third-party servicer, so their enrollment reporting was not done timely. Cause: It was noted the University identified the status changes while there was a cybersecurity breach with National Student Clearinghouse (NSC) and so they ceased enrollment reporting during this period. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2023-002 National Student Loan Data System (NSLDS) Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 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(b), states schools must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date as well as program enrollment effective date. Changes to a students' status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: During our testing, we noted 5 out of the 40 students tested where the students' change in status was not reported in a timely manner. Questioned Costs: None Context: During our testing, it was noted the University identified the status changes while there was a cybersecurity breach with National Student Clearinghouse (NSC), their third-party servicer, so their enrollment reporting was not done timely. Cause: It was noted the University identified the status changes while there was a cybersecurity breach with National Student Clearinghouse (NSC) and so they ceased enrollment reporting during this period. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Views of Responsible Officials: There is no disagreement with the audit finding.
Department of Education 2023-002 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the auditfinding. Action taken in response to finding: Auditors identified five students where the change in enrollment status was not reported in a timely manner. It was noted that we identified the status changes while there was a cybersecurity breach within the file transfer system used by the National Student Clearinghouse (NSC), our third-party servicer. As a result, our reporting was delayed. We received notice of the incident from the NSC on June 16, 2023. Our next planned transmission was scheduled for June 28. We postponed our regular reporting schedule for one week while we reset our secure FTP password with NSC, initialized our account in their updated system, and while our ITS security officer evaluated the risk. We ended up submitting the file to the NSC on July 5. As a result of this incident, we remain vigilant for external factors that may impact our reporting schedule. We will address them as quickly as possible to avoid reporting delays. Names of the contact persons responsible for corrective action: Gwenn Sherburne, Registrar Planned completion date for corrective action plan: By first reporting date for 2023-2024 academic year in early September 2023.
During our testing, we noted 5 out of the 40 students tested where the students' change in status was not reported in a timely manner. Questioned Costs: None Context: During our testing, it was noted the University identified the status changes while there was a cybersecurity breach with National Student Clearinghouse (NSC), their third-party servicer, so their enrollment reporting was not done timely. Cause: It was noted the University identified the status changes while there was a cybersecurity breach with National Student Clearinghouse (NSC) and so they ceased enrollment reporting during this period. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2023-002 National Student Loan Data System (NSLDS) Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 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(b), states schools must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date as well as program enrollment effective date. Changes to a students' status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: During our testing, we noted 5 out of the 40 students tested where the students' change in status was not reported in a timely manner. Questioned Costs: None Context: During our testing, it was noted the University identified the status changes while there was a cybersecurity breach with National Student Clearinghouse (NSC), their third-party servicer, so their enrollment reporting was not done timely. Cause: It was noted the University identified the status changes while there was a cybersecurity breach with National Student Clearinghouse (NSC) and so they ceased enrollment reporting during this period. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Views of Responsible Officials: There is no disagreement with the audit finding.
Department of Education 2023-002 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the auditfinding. Action taken in response to finding: Auditors identified five students where the change in enrollment status was not reported in a timely manner. It was noted that we identified the status changes while there was a cybersecurity breach within the file transfer system used by the National Student Clearinghouse (NSC), our third-party servicer. As a result, our reporting was delayed. We received notice of the incident from the NSC on June 16, 2023. Our next planned transmission was scheduled for June 28. We postponed our regular reporting schedule for one week while we reset our secure FTP password with NSC, initialized our account in their updated system, and while our ITS security officer evaluated the risk. We ended up submitting the file to the NSC on July 5. As a result of this incident, we remain vigilant for external factors that may impact our reporting schedule. We will address them as quickly as possible to avoid reporting delays. Names of the contact persons responsible for corrective action: Gwenn Sherburne, Registrar Planned completion date for corrective action plan: By first reporting date for 2023-2024 academic year in early September 2023.
FAC accepted this audit on February 26, 2024 — management decision was due August 26, 2024.
During our testing, we noted 5 out of the 40 students tested where the students' change in status was not reported in a timely manner. Questioned Costs: None Context: During our testing, it was noted the University identified the status changes while there was a cybersecurity breach with National Student Clearinghouse (NSC), their third-party servicer, so their enrollment reporting was not done timely. Cause: It was noted the University identified the status changes while there was a cybersecurity breach with National Student Clearinghouse (NSC) and so they ceased enrollment reporting during this period. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2023-002 National Student Loan Data System (NSLDS) Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 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(b), states schools must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date as well as program enrollment effective date. Changes to a students' status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: During our testing, we noted 5 out of the 40 students tested where the students' change in status was not reported in a timely manner. Questioned Costs: None Context: During our testing, it was noted the University identified the status changes while there was a cybersecurity breach with National Student Clearinghouse (NSC), their third-party servicer, so their enrollment reporting was not done timely. Cause: It was noted the University identified the status changes while there was a cybersecurity breach with National Student Clearinghouse (NSC) and so they ceased enrollment reporting during this period. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Views of Responsible Officials: There is no disagreement with the audit finding.
Department of Education 2023-002 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the auditfinding. Action taken in response to finding: Auditors identified five students where the change in enrollment status was not reported in a timely manner. It was noted that we identified the status changes while there was a cybersecurity breach within the file transfer system used by the National Student Clearinghouse (NSC), our third-party servicer. As a result, our reporting was delayed. We received notice of the incident from the NSC on June 16, 2023. Our next planned transmission was scheduled for June 28. We postponed our regular reporting schedule for one week while we reset our secure FTP password with NSC, initialized our account in their updated system, and while our ITS security officer evaluated the risk. We ended up submitting the file to the NSC on July 5. As a result of this incident, we remain vigilant for external factors that may impact our reporting schedule. We will address them as quickly as possible to avoid reporting delays. Names of the contact persons responsible for corrective action: Gwenn Sherburne, Registrar Planned completion date for corrective action plan: By first reporting date for 2023-2024 academic year in early September 2023.
During our testing, we noted 5 out of the 40 students tested where the students' change in status was not reported in a timely manner. Questioned Costs: None Context: During our testing, it was noted the University identified the status changes while there was a cybersecurity breach with National Student Clearinghouse (NSC), their third-party servicer, so their enrollment reporting was not done timely. Cause: It was noted the University identified the status changes while there was a cybersecurity breach with National Student Clearinghouse (NSC) and so they ceased enrollment reporting during this period. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2023-002 National Student Loan Data System (NSLDS) Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 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(b), states schools must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date as well as program enrollment effective date. Changes to a students' status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: During our testing, we noted 5 out of the 40 students tested where the students' change in status was not reported in a timely manner. Questioned Costs: None Context: During our testing, it was noted the University identified the status changes while there was a cybersecurity breach with National Student Clearinghouse (NSC), their third-party servicer, so their enrollment reporting was not done timely. Cause: It was noted the University identified the status changes while there was a cybersecurity breach with National Student Clearinghouse (NSC) and so they ceased enrollment reporting during this period. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Views of Responsible Officials: There is no disagreement with the audit finding.
Department of Education 2023-002 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the auditfinding. Action taken in response to finding: Auditors identified five students where the change in enrollment status was not reported in a timely manner. It was noted that we identified the status changes while there was a cybersecurity breach within the file transfer system used by the National Student Clearinghouse (NSC), our third-party servicer. As a result, our reporting was delayed. We received notice of the incident from the NSC on June 16, 2023. Our next planned transmission was scheduled for June 28. We postponed our regular reporting schedule for one week while we reset our secure FTP password with NSC, initialized our account in their updated system, and while our ITS security officer evaluated the risk. We ended up submitting the file to the NSC on July 5. As a result of this incident, we remain vigilant for external factors that may impact our reporting schedule. We will address them as quickly as possible to avoid reporting delays. Names of the contact persons responsible for corrective action: Gwenn Sherburne, Registrar Planned completion date for corrective action plan: By first reporting date for 2023-2024 academic year in early September 2023.
FAC accepted this audit on November 28, 2022 — management decision was due May 28, 2023.
During our testing, we noted that the change in Vice President (VP) of Finance was not reported timely to the Department of Education. Questioned costs: None Context: During our testing, we noted the VP of Finance had a change in position and it was not updated within 10 days. Cause: The VP of Finance left in August 2021 and there was no replacement until June 2022. The removal of the position was not done to add a temporary VP of Finance until the permanent replacement began. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the University review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2022-001 Eligibility and Certification Approval Report (ECAR) Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the University. Condition: During our testing, we noted that the change in Vice President (VP) of Finance was not reported timely to the Department of Education. Questioned costs: None Context: During our testing, we noted the VP of Finance had a change in position and it was not updated within 10 days. Cause: The VP of Finance left in August 2021 and there was no replacement until June 2022. The removal of the position was not done to add a temporary VP of Finance until the permanent replacement began. Effect: The University is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the University review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
2022-001 Student Financial Assistance ? Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Hamline has started a Corrective Action Plan by more clearly communicating the requirements of the timely reporting to the partnering departments or Finance, Provost, President?s Office and Student Accounts. The Corrective Action Plan will require the Student Accounts area to report to Institutional Effectiveness Office and Financial Aid Office any updates to third party servicers. The Provost Office will responsible for reporting to Institutional Effectiveness Office and Financial Aid Office any additions or changes regarding academic program or educational locations. The President?s Office will be responsible for reporting to Institutional Effectiveness Office and Financial Aid Office any changes in leadership or board members. All changes need to be reported immediately to Institutional Effectiveness Office and Financial Aid Office to ensure the ECAR is updated within the 10-reporting requirement. Additionally, IE and Financial Aid will annually review the ECAR at the end of June to correspond to the new fiscal year board of trustees that is effective on July 1 every year. Names of the contact persons responsible for corrective action: Sally Gerlach, Assistant Director of Institutional Effectiveness and Lynette Wahl, Senior Director of Financial Aid and Enrollment Planned completion date for corrective action plan: October 11, 2022
FAC accepted this audit on March 29, 2022 — management decision was due September 29, 2022.
During our testing, we noted for 1 out of the 40 students tested, the program enrollment effective date did not match the program enrollment effective date per the University?s records. We noted for 5 out of the 40 students tested, the enrollment effective date did not match the enrollment effective date per the University?s records. Lastly, we noted for 1 out of 40 students tested, the enrollment was not verified every 60 days. Questioned Costs: None Context: During our testing, it was noted the University did not have proper procedures in place to verify the reports sent from Banner to NSLDS are including accurate information and being updated timely. Cause: The University?s processes and controls did not ensure that student program enrollment effective dates and campus enrollment effective dates were accurately reported to NSLDS as well as enrollment was certified every 60 days. Effect: The University did not comply with Department of Education?s regulations regarding enrollment reporting. Repeat Finding: Yes, 2020-001 Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid CFDA Number: Student Financial Aid Cluster Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, 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. Condition: During our testing, we noted for 1 out of the 40 students tested, the program enrollment effective date did not match the program enrollment effective date per the University?s records. We noted for 5 out of the 40 students tested, the enrollment effective date did not match the enrollment effective date per the University?s records. Lastly, we noted for 1 out of 40 students tested, the enrollment was not verified every 60 days. Questioned Costs: None Context: During our testing, it was noted the University did not have proper procedures in place to verify the reports sent from Banner to NSLDS are including accurate information and being updated timely. Cause: The University?s processes and controls did not ensure that student program enrollment effective dates and campus enrollment effective dates were accurately reported to NSLDS as well as enrollment was certified every 60 days. Effect: The University did not comply with Department of Education?s regulations regarding enrollment reporting. Repeat Finding: Yes, 2020-001 Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Views of responsible officials: There is no disagreement with the audit finding.
United States Department of Education Hamline University of Minnesota respectfully submits the following corrective action plan for the year ended June 30, 2021. Audit period: July 01, 2020 to June 30, 2021 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no financial statement findings in the prior year. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS United States Department of Education Student Financial Aid Cluster Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Auditors identified a small number of students whose graduation date at the program-level was after the end date of a student?s final semester of attendance. We received notice of the previous year's audit finding halfway through the current year being audited. Because of this, some issues happened prior to our being able to fully implement the Corrective Action Plan. Therefore, the plan remains the same. The campus-level date for these students was correct. The Registration and Records office did three things to ensure that the graduation dates reported to the National Student Clearinghouse (NSC) match at the campus and program level, and are not after the end date of a student?s final semester of attendance. First, we updated our standard conferral dates to match the last date of the academic period for fall, winter and summer. Our standard conferral date for spring semester remains Commencement Day. Second, staff now search each NSC enrollment file for campus- and program-level graduation dates that fall after the end date of the student?s enrollment period being reported and update them to match the end of the term. Finally, staff have been trained to use the last date of attendance as the graduation date at both the campus and program levels when manually updating a student?s enrollment record on the NSC website. Starting Fall 2021 we will be using a new Student Information System (Workday). We are in communication with our technical consultants to ensure the NSC reporting through Workday addresses this issue and reports information correctly. Names of the contact persons responsible for corrective action: Gwenn Sherburne, Registrar Planned completion date for corrective action plan: By first reporting date for 2021-2022 academic year in early September 2021.
2020-001
During our testing, we noted for 2 out of the vendors tested, there were not documented suspension and debarment procedures. Questioned Costs: None Context: The University does not have procedures in place to verify vendors had not been suspended or debarred. Cause: A recommendation was issued during the fiscal year 2020 audit regarding suspension and debarment procedures; however, this was issued in May 2021 due to single audit compliance supplement delays. The University reviewed the procedures at this time and had implemented a corrective action moving forward. The University did not go back and review any previous expenses and vendors that were already incurred, which were a part of our testing for fiscal year 2021. Effect: The University could enter into a covered transaction with a vendor who is suspended or debarred. Repeat Finding: No Recommendation: We recommend the University document suspension and debarment procedures going forward for any vendors with federal expenditures over $25,000. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Funds CFDA Number: 84.425 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or Specific Requirement: Per Uniform Guidance 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: During our testing, we noted for 2 out of the vendors tested, there were not documented suspension and debarment procedures. Questioned Costs: None Context: The University does not have procedures in place to verify vendors had not been suspended or debarred. Cause: A recommendation was issued during the fiscal year 2020 audit regarding suspension and debarment procedures; however, this was issued in May 2021 due to single audit compliance supplement delays. The University reviewed the procedures at this time and had implemented a corrective action moving forward. The University did not go back and review any previous expenses and vendors that were already incurred, which were a part of our testing for fiscal year 2021. Effect: The University could enter into a covered transaction with a vendor who is suspended or debarred. Repeat Finding: No Recommendation: We recommend the University document suspension and debarment procedures going forward for any vendors with federal expenditures over $25,000. Views of responsible officials: There is no disagreement with the audit finding.
Higher Education Emergency Relief Funds Recommendation: We recommend the University document suspension and debarment procedures going forward for any vendors with federal expenditures over $25,000. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Auditors identified the need for procedure updates related to documenting suspension and disbarment vendor reviews. We received notice after the current fiscal year's expenses had already been incurred. We created a plan and process for the future but did not go back and review existing expenses. Hamline staff have now reviewed vendors paid with federal funds on the sam.gov excluded list and have determined that none of the vendors are on the list. This documentation is held in the vendor file in the Workday system. Moving forward, this process will continue to be in place for all vendor contract expenses paid with federal funds greater than $25,000. Names of the contact persons responsible for corrective action: Michelle Hegarty Planned completion date for corrective action plan: January 21, 2022
FAC accepted this audit on May 16, 2021 — management decision was due November 16, 2021.
During our testing, we noted for 1 out of the 40 students tested, the program enrollment effective date did not match the program enrollment effective date per the University?s records. Questioned Costs: None Context: During our testing, it was noted the University did not have proper procedures in place to verify the reports sent from Banner to NSLDS are including accurate information. Cause: The University?s processes and controls did not ensure that student program enrollment effective dates were accurately reported to NSLDS. Effect: The University did not comply with Department of Education?s regulations regarding enrollment reporting. Repeat Finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the program enrollment effective date reported to NSLDS is aligning with the University?s last date of attendance. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2020-001 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid CFDA Number: Student Financial Aid Cluster Award Period: July 1, 2019 to June 30, 2020 Type of Finding: -Significant Deficiency in Internal Control Over Compliance -Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. Condition: During our testing, we noted for 1 out of the 40 students tested, the program enrollment effective date did not match the program enrollment effective date per the University?s records. Questioned Costs: None Context: During our testing, it was noted the University did not have proper procedures in place to verify the reports sent from Banner to NSLDS are including accurate information. Cause: The University?s processes and controls did not ensure that student program enrollment effective dates were accurately reported to NSLDS. Effect: The University did not comply with Department of Education?s regulations regarding enrollment reporting. Repeat Finding: No Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the program enrollment effective date reported to NSLDS is aligning with the University?s last date of attendance. Views of responsible officials: There is no disagreement with the audit finding.
United States Department of Education Hamline University of Minnesota respectfully submits the following corrective action plan for the year ended June 30, 2020. Audit period: July 01, 2019 to June 30, 2020 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no financial statement findings in the prior year. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS United States Department of Education 2019-001 Student Financial Aid Cluster Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the program enrollment effective date reported to NSLDS is aligning with the University?s last date of attendance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Auditors identified a small number of students whose graduation date at the program-level was after the end date of a student?s final semester of attendance. The campus-level date for these students was correct. The Registration and Records office did three things to ensure that the graduation dates reported to the National Student Clearinghouse (NSC) match at the campus and program level, and are not after the end date of a student?s final semester of attendance. First, we updated our standard conferral dates to match the last date of the academic period for fall, winter and summer. Our standard conferral date for spring semester remains Commencement Day. Second, staff now search each NSC enrollment file for campus- and program-level graduation dates that fall after the end date of the student?s enrollment period being reported and update them to match the end of the term. Finally, staff have been trained to use the last date of attendance as the graduation date at both the campus and program levels when manually updating a student?s enrollment record on the NSC website. Starting Fall 2021 we will be using a new Student Information System (Workday). We are in communication with our technical consultants to ensure the NSC reporting through Workday addresses this issue and reports information correctly. Names of the contact persons responsible for corrective action: Gwenn Sherburne, Registrar Planned completion date for corrective action plan: By first reporting date for 2020-2021 academic year in early September 2020. If the United States Department of Education has questions regarding this plan, please call Lynette Wahl at 651-523-2933.
FAC accepted this audit on November 13, 2019 — management decision was due May 13, 2020.
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. Questioned costs: None Context: During our audit procedures, it was noted that the University did not perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks. Cause: The organization uses a third-party IT service provider for IT related tasks and relied on that service provider to ensure all compliance requirements are met. However, the organization should have an individual designated internally to assure compliance with the requirements of the Gramm-Leach-Bliley Act. The organization did not perform an IT risk assessment tailored specifically to the organization, identify risks, or address risks identified as required by the Gramm-Leach-Bliley Act. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the University engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal agency: Department of Education Federal program title: Student Financial Aid Cluster CFDA Numbers: 84.063, 84.007, 84.033 Award Period: July 1, 2018 through June 30, 2019 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). Condition: 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. Questioned costs: None Context: During our audit procedures, it was noted that the University did not perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks. Cause: The organization uses a third-party IT service provider for IT related tasks and relied on that service provider to ensure all compliance requirements are met. However, the organization should have an individual designated internally to assure compliance with the requirements of the Gramm-Leach-Bliley Act. The organization did not perform an IT risk assessment tailored specifically to the organization, identify risks, or address risks identified as required by the Gramm-Leach-Bliley Act. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the University engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: There is no disagreement with the audit finding.
HAMLINE OF MINNESOTA CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2019 United States Department of Education Hamline University of Minnesota respectfully submits the following corrective action plan for the year ended June 30, 2019. Audit period: July 01, 2018 to June 30, 2019 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no financial statement findings in the prior year. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS United States Department of Education 2019-001 Student Financial Aid Cluster Recommendation: We recommend that the University engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Institute of Higher Education (IHE) designate for coordinating the information security program has been identified. Within 30 days of findings notification, internal review of GLBA controls currently in place will be completed by senior Information Technology Services (ITS) staff. Within 90 days of findings notification, IHE GLBA risk assessment of Student Financial Aid Cluster will be performed by and external 3rd Party Firm. Within 120 days of findings notification, safeguards for any identified risks stemming from the security assessment will be documented and validated quarterly until complete and fully instituted. Names of the contact persons responsible for corrective action: David Chun, Associate Vice President for ITS/Chief Information Officer, and Anthony Schroeder, Director of Infrastructure Services. Planned completion date for corrective action plan: Corrective actions will be staged in phases with quarterly updates. Expect to be completed no later than current year, quarter 2. ed States Department of Education has questions regarding this plan, please call Lori Standafer at 651-523-2671.
FAC accepted this audit on October 22, 2018 — management decision was due April 22, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on November 13, 2017 — management decision was due May 13, 2018.
FAC accepted this audit on December 1, 2016 — management decision was due June 1, 2017.
GSA_MIGRATION
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GSA_MIGRATION
2015-001
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