EIN: 410693970
UEI: LVV9V64A8449
Audited by: CLIFTONLARSONALLEN LLP
Cognizant 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 March 31, 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 October 1, 2026 (25 days from today).
What is a management decision? →During our testing of the Direct Loan and Pell Grant programs, we selected a sample of 40 students to test for accuracy and timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted that 1 out of 40 students did not have their enrollment status timely reported. Additionally, we noted 1 out of 40 students had a discrepancy in Program-level enrollment status, where the University’s records did not match what was reported to NSLDS. Questioned Costs: None Context: During our testing, we noted the University did not have proper procedures in place to verify the reports sent to NSLDS are timely and accurate. Cause: The University processes and controls did not ensure that student status changes were properly reported to NSLDS. The effective date should reflect the student's last date of attendance and academically-related activity. In addition, students’ enrollment status should be certified every 60 days and the program begin date should be the first day attended at the University. Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, see finding 2024-001. 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 Official: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2025 – 001 Federal Agency: United States Department of Education Federal Program Name: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2024 to 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 682.610, states that institutions must report accurately the enrollment status of all students regardless of whether they receive aid from the institution. 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 of the Direct Loan and Pell Grant programs, we selected a sample of 40 students to test for accuracy and timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). During our testing, we noted that 1 out of 40 students did not have their enrollment status timely reported. Additionally, we noted 1 out of 40 students had a discrepancy in Program-level enrollment status, where the University’s records did not match what was reported to NSLDS. Questioned Costs: None Context: During our testing, we noted the University did not have proper procedures in place to verify the reports sent to NSLDS are timely and accurate. Cause: The University processes and controls did not ensure that student status changes were properly reported to NSLDS. The effective date should reflect the student's last date of attendance and academically-related activity. In addition, students’ enrollment status should be certified every 60 days and the program begin date should be the first day attended at the University. Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, see finding 2024-001. 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 Official: There is no disagreement with the audit finding.
2025-001 – National Student Loan Data System Reporting 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: Two issues caused delayed or inaccurate enrollment reporting. First, a student who advanced to a master’s program remained enrolled at the campus level, so the graduation-only file did not capture their program completion, making it appear as a withdrawal. Second, a late grade submission delayed degree awarding, therefore graduation status was not identified until later. The corrective action plan includes sending the Degree Verify file to the National Student Clearinghouse more frequently to ensure timely reporting of all awarded degrees, regardless of enrollment status. Additionally, we will develop a report to flag grade changes that may affect graduation status and trigger timely updates to ensure accurate and prompt reporting. Name(s) of the contact person(s) responsible for corrective action: Julie Annis: julie.annis@stthomas.edu, Yuko Kachinsky: yuko.kachinsky@stthomas.edu Planned completion date for corrective action plan: This first step of the action plan was implemented immediately upon discussion of the finding. The second step will be completed July 1, 2026.
2024-001
During our testing of credit balances resulting from federal funds, we noted that although the refunds were ultimately paid, 1 out of 40 credit balances tested were not refunded within the required 14-day period. Questioned Costs: None Context: Federal regulations require institutions to refund credit balances resulting from Title IV funds within 14 days of the balance being created. Timely refunds ensure compliance with U.S. Department of Education requirements and protect students from delays in receiving funds. Failure to meet this deadline can result in noncompliance and potential financial or administrative consequences. 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 the regulations. Repeat Finding: No. Recommendation: We recommend the University review and strengthen its policies and procedures to ensure that all student credit balances resulting from federal funds are refunded within the required 14- day period. Views of Responsible Official: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2025 – 002 Federal Agency: United States Department of Education Federal Program Name: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2024 to 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 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. Title IV, HEA credit balances 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 that although the refunds were ultimately paid, 1 out of 40 credit balances tested were not refunded within the required 14-day period. Questioned Costs: None Context: Federal regulations require institutions to refund credit balances resulting from Title IV funds within 14 days of the balance being created. Timely refunds ensure compliance with U.S. Department of Education requirements and protect students from delays in receiving funds. Failure to meet this deadline can result in noncompliance and potential financial or administrative consequences. 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 the regulations. Repeat Finding: No. Recommendation: We recommend the University review and strengthen its policies and procedures to ensure that all student credit balances resulting from federal funds are refunded within the required 14- day period. Views of Responsible Official: There is no disagreement with the audit finding.
2025-002 Title IV Credit Balances Recommendation: We recommend the University review and strengthen its policies and procedures to ensure that all student credit balances resulting from federal funds are refunded within the required 14-day period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The finding occurred due to the student’s status for collection purposes of pre-pay for the upcoming term. This hold prevented the refund from occurring because the hold is not able to distinguish between funds paid in advance to satisfy the prepay requirement and funds paid by financial aid where a refund is required. The corrective action involves the creation of a report for the Business Office which will be reviewed by Business Office staff which indicates students with a prepay hold and a credit balance. If the credit balance is due to financial aid, the refund will be issued on time. Name(s) of the contact person(s) responsible for corrective action: Stephanie Carlson: srcarlson@stthomas.edu Planned completion date for corrective action plan: This corrective action has been implemented effective immediately.
During our testing, we noted an instance where the University had compiled all the necessary documentation to support a professional judgement that was granted to a student during the 2024-25 school year, but the professional judgement documentation lacked formal review procedures as prescribed by the University’s policies and procedures. Questioned Costs: None Context: The University did not have proper internal controls in place during the 2024-25 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The University had turnover during the year, and this duty had not been reassigned at the time of this professional judgement. Effect: The University is not in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: No. Recommendation: We recommend the University review and formalize its procedures to ensure that internal controls are in place to identify and correct any inconsistencies throughout the year. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2025 – 003 Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2024 to June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or Specific Requirement: The 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing, we noted an instance where the University had compiled all the necessary documentation to support a professional judgement that was granted to a student during the 2024-25 school year, but the professional judgement documentation lacked formal review procedures as prescribed by the University’s policies and procedures. Questioned Costs: None Context: The University did not have proper internal controls in place during the 2024-25 academic year to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Cause: The University had turnover during the year, and this duty had not been reassigned at the time of this professional judgement. Effect: The University is not in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Repeat Finding: No. Recommendation: We recommend the University review and formalize its procedures to ensure that internal controls are in place to identify and correct any inconsistencies throughout the year. Views of Responsible Officials: There is no disagreement with the audit finding.
2025-003 Internal Control – Professional Judgements Recommendation: We recommend the University review and formalize its procedures to ensure that internal controls are in place to identify and correct any inconsistencies throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: While we do not believe these steps are required in regulation, we do understand that this is a best practice that has been recommended by CLA in the past. The corrective action that will be taken is to identify a staff member who is able to add this responsibility to their current list of responsibilities. We do not feel that a full review of all PJ adjustments can be accomplished, however, we will implement a process to randomly select PJ files from each counselor responsible for processing them on a monthly basis to check for documentation and errors. Name(s) of the contact person(s) responsible for corrective action: Paula Benson: paula.benson@stthomas.edu Planned completion date for corrective action plan: July 1, 2026
We tested five vendors paid over $25,000 during fiscal year 2025. Three of the five tested did not have any documentation to support that the University verified the vendor was not suspended or debarred at the time of executing the agreement. The University stated they completed this review however there was no documentation to support the completion of this step prior to entering into a covered transaction. Per review of the suspension and debarment list at the time of testing, we noted the vendor was neither suspended nor debarred. Questioned Costs: None Context: For three of the transactions selected for testing, the University was unable to provide documentation to support the date suspension and debarment checks were verified. Cause: The absence of formal documentation suggests that either the check was not performed or was performed but not properly documented. Effect: Failure to document suspension and debarment checks could result in noncompliance with federal regulations and institutional policy, increasing the risk of disallowed costs and potential reputational or financial consequences. Repeat Finding: Yes, see finding 2024-003. Recommendation: We recommend the University evaluate its procedures and policies around suspension and debarment to ensure that checks are both performed and formally documented prior to entering into the covered transaction. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2025 – 004 Federal Agency: United States Department of Defense Federal Program Name: Research & Development Cluster Assistance Listing Number: 12.431 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or Specific Requirement: Per 2 CFR 200.213, non-federal entities are prohibited from contracting with or making subawards to parties that are suspended, debarred, or otherwise excluded from participation in federal programs. Verification must be performed through SAM.gov, a written certification, or inclusion of the appropriate clause in the agreement. Condition: We tested five vendors paid over $25,000 during fiscal year 2025. Three of the five tested did not have any documentation to support that the University verified the vendor was not suspended or debarred at the time of executing the agreement. The University stated they completed this review however there was no documentation to support the completion of this step prior to entering into a covered transaction. Per review of the suspension and debarment list at the time of testing, we noted the vendor was neither suspended nor debarred. Questioned Costs: None Context: For three of the transactions selected for testing, the University was unable to provide documentation to support the date suspension and debarment checks were verified. Cause: The absence of formal documentation suggests that either the check was not performed or was performed but not properly documented. Effect: Failure to document suspension and debarment checks could result in noncompliance with federal regulations and institutional policy, increasing the risk of disallowed costs and potential reputational or financial consequences. Repeat Finding: Yes, see finding 2024-003. Recommendation: We recommend the University evaluate its procedures and policies around suspension and debarment to ensure that checks are both performed and formally documented prior to entering into the covered transaction. Views of Responsible Officials: There is no disagreement with the audit finding.
2025-004 Suspension & Debarment Recommendation: We recommend the University evaluate its procedures and policies around suspension and debarment to ensure that checks are both performed and formally documented prior to entering into the covered transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The university has adjusted its process for suspension and debarment reviews to include proper documentation of the steps taken and will make that documentation available for review by external auditors. This corrective action was completed upon the finding in the summer of 2025. Name(s) of the contact person(s) responsible for corrective action: Becky Groen: groe9984@stthomas.edu Planned completion date for corrective action plan: This corrective action has been completed. If the Department of Education or Department of Defense has questions regarding this schedule, please call Becky Groen at 651-962-6142.
2024-003
FAC accepted this audit on March 28, 2025 — management decision was due September 28, 2025.
During our testing, we noted 1 of 40 students enrollment status and enrollment effective date per institution's record did not match what was reported to NSLDS. Questioned Costs: None Context: During our testing, we noted the University did not have proper procedures in place to verify the reports sent to NSLDS are accurate. Cause: The University processes and controls did not ensure that student status changes were accurately reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the University review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of Responsible Official: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2028 – 001 – National Student Loan Database System Reporting Federal Agency: United States Department of Education Federal Program Name: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2023 to 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 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. In addition, regulations require the status include an accurate effective date. Regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted 1 of 40 students enrollment status and enrollment effective date per institution's record did not match what was reported to NSLDS. Questioned Costs: None Context: During our testing, we noted the University did not have proper procedures in place to verify the reports sent to NSLDS are accurate. Cause: The University processes and controls did not ensure that student status changes were accurately reported to NSLDS. The effective date should be the student's last date of attendance and academically-related activity. Effect: The NSLDS system is not updated with the correct student information, which can cause a student to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the University review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of Responsible Official: There is no disagreement with the audit finding.
Recommendation: CLA recommends the University review its reporting procedures to ensure the students' statuses are accurately 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: By reviewing the ordering of internal processes and procedures St. Thomas determined two internal processes ran out of order causing incorrect reporting. Procedural documentation has been updated and training provided to ensure this error is not repeated. Name(s) of the contact person(s) responsible for corrective action: Yuko Kachinsky: yuko.kachinsky@stthomas.edu Planned completion date for corrective action plan: A process error was identified and corrected in August 2024.
During our testing, the University reported that they had not completed the required FFATA reporting for any of the subawards made during the year ended June 30, 2024 nor subsequent to year end. Questioned Costs: None Context: During our testing, it was noted the University did not have proper procedures in place for ensuring completion of the FFATA reporting for subawards and sub awardee executive compensation as required in the federal fund notice of awards. Cause: UST was not aware of the timing of the FFATA reporting requirements and did not have a process in place to ensure that required reporting had been completed within the time allowed. Effect: By not completing the required FFATA reporting, the University is not in compliance with the terms of the award. This did not result in any disallowed costs. Repeat Finding: No. Recommendation: We recommend the University implements a process place to ensure the required reporting is completed in the timeline allowed by the granting agency and to complete any missed or late reporting as required. Views of Responsible Official: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴2024 – 002 – Federal Funding Accountability and Transparency Act of 2006 (FFATA) Reporting Federal Agency: United States Department of Education Federal Program Name: Teacher Quality Partnership Program Assistance Listing Number: 84.336 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 2 CFR Part 170, as required by the Federal Funding Accountability and Transparency Act of 2006, states organizations which make subawards of federal funding with obligations of $25,000 or greater must complete FFATA reporting of executive compensation to the federal agency no later than the end of the month following the month in which the subaward obligation was made. Condition: During our testing, the University reported that they had not completed the required FFATA reporting for any of the subawards made during the year ended June 30, 2024 nor subsequent to year end. Questioned Costs: None Context: During our testing, it was noted the University did not have proper procedures in place for ensuring completion of the FFATA reporting for subawards and sub awardee executive compensation as required in the federal fund notice of awards. Cause: UST was not aware of the timing of the FFATA reporting requirements and did not have a process in place to ensure that required reporting had been completed within the time allowed. Effect: By not completing the required FFATA reporting, the University is not in compliance with the terms of the award. This did not result in any disallowed costs. Repeat Finding: No. Recommendation: We recommend the University implements a process place to ensure the required reporting is completed in the timeline allowed by the granting agency and to complete any missed or late reporting as required. Views of Responsible Official: There is no disagreement with the audit finding.
Recommendation: CLA recommends the University implements a process place to ensure the required reporting is completed in the timeline allowed by the granting agency and to complete any missed or late reporting as required. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: St. Thomas identified the applicable FFATA reporting requirements and assigned responsibility to the appropriate party. Name(s) of the contact person(s) responsible for corrective action: Sarah Ervin, sarah.ervin@stthomas.edu Planned completion date for corrective action plan: The additional reporting requirement has been added to the accounting department’s list of responsibilities beginning in January 2025.
We tested five subrecipients paid over $25,000. One of the five tested did not have any documentation to support that the University verified the subrecipient was not suspended or debarred at the time of executing the subaward agreement. The University stated they completed this review however there was no documentation to support the completion of this step prior to entering into a covered transaction. Per review of the suspension and debarment list at the time of testing, we noted the subrecipient was neither suspended nor debarred. Questioned Costs: None Context: During testing, it was noted there was no documentation retained to ensure the SAM verification was done prior to executing the subaward agreement. In addition, there was no documentation of a second review to ensure the subrecipient was not suspended or debarred. Cause: The control system to prevent payment to a suspended and debarred vendor was not in place. Effect: The University could have entered into a covered transaction with a subrecipient who is suspended or debarred. Repeat Finding: No. Recommendation: We recommend the University review its existing policies to ensure it is up to date with federal regulations. We also recommend documenting the subrecipient was checked on the SAM.gov website prior to executing the subaward agreement. A secondary review should be performed prior to payment. This second review should be documented and retained to support the suspension and debarment requirements were followed and completed before entering into a covered transaction. Views of Responsible Officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: United States Department of Education Federal Program Name: Teacher Quality Partnership Program Assistance Listing Number: 84.336 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or Specific Requirement: Under the Uniform Guidance, nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet other criteria as specified in 2 CFR section 180.220. All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Condition: We tested five subrecipients paid over $25,000. One of the five tested did not have any documentation to support that the University verified the subrecipient was not suspended or debarred at the time of executing the subaward agreement. The University stated they completed this review however there was no documentation to support the completion of this step prior to entering into a covered transaction. Per review of the suspension and debarment list at the time of testing, we noted the subrecipient was neither suspended nor debarred. Questioned Costs: None Context: During testing, it was noted there was no documentation retained to ensure the SAM verification was done prior to executing the subaward agreement. In addition, there was no documentation of a second review to ensure the subrecipient was not suspended or debarred. Cause: The control system to prevent payment to a suspended and debarred vendor was not in place. Effect: The University could have entered into a covered transaction with a subrecipient who is suspended or debarred. Repeat Finding: No. Recommendation: We recommend the University review its existing policies to ensure it is up to date with federal regulations. We also recommend documenting the subrecipient was checked on the SAM.gov website prior to executing the subaward agreement. A secondary review should be performed prior to payment. This second review should be documented and retained to support the suspension and debarment requirements were followed and completed before entering into a covered transaction. Views of Responsible Officials: There is no disagreement with the audit finding.
Recommendation: CLA recommends the University review its existing policies to ensure it is up to date with federal regulations. They also recommend documenting the subrecipient was checked on the SAM.gov website prior to executing the subaward agreement. CLA suggests a secondary review should be performed prior to payment and that the second review should be documented and retained to support the suspension and debarment requirements were followed and completed before entering into a covered transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: St. Thomas updated processes and procedures to verify subrecipient status’ on a twofold bases. First, at initiation via the Office of Sponsored programs. A secondary review is performed by the Purchasing and Payables team. Name(s) of the contact person(s) responsible for corrective action: Michael Warnock, mjwarnock@stthomas.edu and Karen Harthorn, kmharthorn@stthomas.edu Planned completion date for corrective action plan: This change has been implemented in the spring of 2025.
FAC accepted this audit on March 28, 2024 — management decision was due September 28, 2024.
The University utilizes a third party service for its Perkins Loan servicing. This is a very common practice for colleges and universities in order to provide the most efficient and effective means to not only collect loans but meet the federal regulations for servicing student Perkins Loans. In order to perform the due diligence required per the Code of Regulations, the institution utilizes the external compliance report performed for the third party servicer by other auditors. The third party servicer’s compliance audit report for the year ended June 30, 2023 was not issued as of the report date of the uniform guidance report. Therefore, the University was unable to perform due diligence on the third party provider’s internal control over the Perkin’s requirements. Questioned costs: None Context: We noted that the University was not able to obtain the third party’s compliance report as of the date of the Uniform Guidance Report. Cause: The third party servicer, did not have their Title IV compliance audit report completed for the year ending June 30, 2023 so that the University can perform their required due diligence on the third party servicer. Effect: The University did not perform due diligence to ensure that the third-party service is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Repeat Finding: No Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their report is completed timely so that the University can perform the necessary due diligence they need to perform. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: United States Department of Education Federal Program Name: Federal Perkins Loan Program Assistance Listing Number: 84.038 Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Code of Federal Regulations Title 34, Subtitle B, Chapter VI, Part 674.19 requires that in administering its Federal Perkins Loan program, an institution shall establish and maintain an internal control system of checks and balances that ensures that no office can both authorize payments and disburse funds to students. When an institution uses a third-party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third-party service is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Such due diligence could include obtaining and reviewing the third-party servicer’s most recent Title IV compliance audit. Condition: The University utilizes a third party service for its Perkins Loan servicing. This is a very common practice for colleges and universities in order to provide the most efficient and effective means to not only collect loans but meet the federal regulations for servicing student Perkins Loans. In order to perform the due diligence required per the Code of Regulations, the institution utilizes the external compliance report performed for the third party servicer by other auditors. The third party servicer’s compliance audit report for the year ended June 30, 2023 was not issued as of the report date of the uniform guidance report. Therefore, the University was unable to perform due diligence on the third party provider’s internal control over the Perkin’s requirements. Questioned costs: None Context: We noted that the University was not able to obtain the third party’s compliance report as of the date of the Uniform Guidance Report. Cause: The third party servicer, did not have their Title IV compliance audit report completed for the year ending June 30, 2023 so that the University can perform their required due diligence on the third party servicer. Effect: The University did not perform due diligence to ensure that the third-party service is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Repeat Finding: No Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their report is completed timely so that the University can perform the necessary due diligence they need to perform. Views of responsible officials: There is no disagreement with the audit finding.
Federal Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their report is completed timely so that the University can perform the necessary due diligence they need to perform. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Recognizing the importance of resolving this finding the University of St Thomas intends to leverage its Internal Audit function in review of its relationship with UAS and the regulations and compliance items therein. Name of the contact person responsible for corrective action: Wade Holmberg Planned completion date for corrective action plan: 6/1/2024
FAC accepted this audit on November 27, 2022 — management decision was due May 27, 2023.
FAC accepted this audit on September 20, 2022 — management decision was due March 20, 2023.
During our testing we noted certain elements of the University?s procurement policy did not specifically address all requirements in CRF subsections 200.317 through 200.326. Furthermore, of the four vendors tested who were paid over $25,000, it was noted there was no documentation to support the University verified the vendors were not suspended or debarred at the time of purchase. The University stated they completed the review however there was no documentation to support the completion of this step prior to entering into a procured transaction. Per review of the suspension and debarment list at the time of testing, we noted the vendors were neither suspended nor debarred. Questioned Costs: None Context: During testing, it was noted the University?s procurement policy did not include all required elements under federal regulations. Additionally, there was no documentation to ensure certain vendors were not suspended or debarred. Cause: The University did not ensure its procurement policies were up to date with federal regulations and the control system to prevent payment to a suspended and barred vendor was not in place. Effect: The University could have entered into a procurement that does not follow federal regulations or could have paid a vendor who was suspended or barred at the time of payment. Repeat Finding: No Recommendation: We recommend the University review its existing procurement policies to ensure it is up to date with federal regulations. We also recommend documenting the vendor was checked on the SAM.gov website prior to payment. A secondary review should be performed prior to payment. This second review should be documented and retained to support the procurement requirements were followed and completed before entering into a procured transaction. Views of Responsible Officials: Management agrees with finding.
Show full finding ▾Hide full finding ▴2021-001: Suspension and Debarment and Procurement Federal Agency: U.S. Department of Education Federal Program Title: Research & Development Cluster Assistance Listing Number: 47.041, 47.049, 47.050, 47.070, 47.074, 47.076 Award Period: July 01, 2020 - June 30, 2021 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or Specific Requirement: The CRF subsections 200.317 through 200.326 address procurement standards within the Uniform Guidance. These standards include elements that should be included in a written procurement policy. Additionally, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215?. Condition: During our testing we noted certain elements of the University?s procurement policy did not specifically address all requirements in CRF subsections 200.317 through 200.326. Furthermore, of the four vendors tested who were paid over $25,000, it was noted there was no documentation to support the University verified the vendors were not suspended or debarred at the time of purchase. The University stated they completed the review however there was no documentation to support the completion of this step prior to entering into a procured transaction. Per review of the suspension and debarment list at the time of testing, we noted the vendors were neither suspended nor debarred. Questioned Costs: None Context: During testing, it was noted the University?s procurement policy did not include all required elements under federal regulations. Additionally, there was no documentation to ensure certain vendors were not suspended or debarred. Cause: The University did not ensure its procurement policies were up to date with federal regulations and the control system to prevent payment to a suspended and barred vendor was not in place. Effect: The University could have entered into a procurement that does not follow federal regulations or could have paid a vendor who was suspended or barred at the time of payment. Repeat Finding: No Recommendation: We recommend the University review its existing procurement policies to ensure it is up to date with federal regulations. We also recommend documenting the vendor was checked on the SAM.gov website prior to payment. A secondary review should be performed prior to payment. This second review should be documented and retained to support the procurement requirements were followed and completed before entering into a procured transaction. Views of Responsible Officials: Management agrees with finding.
2021-001 Suspension and Debarment and Procurement ? Research & Development Cluster Recommendation: We recommend the University review its existing procurement policies to ensure it is up to date with federal regulations. We also recommend documenting the vendor was checked on the SAM.gov website prior to payment. A supervisor review should be performed prior to payment. This second review should be documented and retained to support the procurement requirements were followed and completed before entering into a procured transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will ensure that all procurement policies are up to date with federal regulations. In addition, the University will implement processes to confirm that all reviews for these vendors are completed timely and that documentation for the reviews is evident and accessible. Name(s) of the contact person(s) responsible for corrective action: Sarah Ervin Planned completion date for corrective action plan: December 31, 2022
During our testing of two completed grants (total of seven key personnel), we identified a missing time and effort form for one individual identified as a key personnel member under the grant agreement. Questioned Costs: None Context: During testing, it was noted there was no documentation to ensure the time and effort certification was completed for one key personnel identified in the grant agreement. Upon further review the institution?s payroll records appear to show the required time commitment had been met for this individual however the time and effort certification should have still been completed as required. Cause: The control system to ensure completion of all time and effort certifications was not in place. Effect: The University had incomplete records over time and effort reporting for key personnel. Repeat Finding: No Recommendation: We recommend documenting the required time and effort reporting/ certification as part of the grant close-out checklist. In addition, we also recommend a supervisor review of the documentation prior to the grant close out to ensure all required procedures were performed. Views of Responsible Officials: Management agrees with finding.
Show full finding ▾Hide full finding ▴2021-002: Key Personnel Reporting Federal Agency: U.S. Department of Education Federal Program Title: Research & Development Cluster Assistance Listing Number: 47.041, 47.049, 47.050, 47.070, 47.074, 47.076 Award Period: July 01, 2020 - June 30, 2021 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or Specific Requirement: Non-federal entities are required to adhered to key personnel commitments specified in the application/proposal or award. Condition: During our testing of two completed grants (total of seven key personnel), we identified a missing time and effort form for one individual identified as a key personnel member under the grant agreement. Questioned Costs: None Context: During testing, it was noted there was no documentation to ensure the time and effort certification was completed for one key personnel identified in the grant agreement. Upon further review the institution?s payroll records appear to show the required time commitment had been met for this individual however the time and effort certification should have still been completed as required. Cause: The control system to ensure completion of all time and effort certifications was not in place. Effect: The University had incomplete records over time and effort reporting for key personnel. Repeat Finding: No Recommendation: We recommend documenting the required time and effort reporting/ certification as part of the grant close-out checklist. In addition, we also recommend a supervisor review of the documentation prior to the grant close out to ensure all required procedures were performed. Views of Responsible Officials: Management agrees with finding.
2021-002 Key Personnel Reporting ? Research & Development Cluster Recommendation: We recommend documenting the required time and effort reporting/certification as part of the grant close-out checklist. In addition, we also recommend a supervisor review of the documentation prior to the grant close out to ensure all required procedures were performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University incorporates a review of time and effort reporting throughout the grant period, however there was one instance where the faculty member did not return a signed form. The University will incorporate additional steps in the grant review process to ensure no federal grants are charged if there is no signed time and effort certification. Name(s) of the contact person(s) responsible for corrective action: Sarah Ervin Planned completion date for corrective action plan: June 30, 2022
FAC accepted this audit on April 15, 2021 — management decision was due October 15, 2021.
FAC accepted this audit on November 19, 2019 — management decision was due May 19, 2020.
The University utilizes University Accounting Service, LLC (UAS) for its third-party Perkins Loan servicing. This is a very common practice for colleges and universities in order to provide the most efficient and effective means to not only collect loans but meet the federal regulations for servicing student Perkins Loans. In auditing the compliance features for the loan servicing, CliftonLarsonAllen utilizes the external compliance report performed for UAS by other auditors. We noted within the UAS compliance audit report for the year ended June 30, 2019, there was a finding for not contacting the student within the required timeframes. The audit did not specify the students that were not contacted within the required guidelines and UAS is one of the largest third-party servicer for federal student loans. Therefore, we do not know if there were any University of St. Thomas students that were impacted by the noncompliance noted at UAS. Questioned Costs: None Context: We noted the University?s third-party servicer, UAS, failed to comply with notifying students of their grace period as required noting 2 of 50 students were noncompliant. Cause: UAS, the third-party servicer, did not have controls in place to ensure they complied with Department of Education Rules and Regulations in regards to timely engagement with students with federal loans. Given the University relies on UAS to meet their compliance responsibilities and there was not testing completed specifically for the University to determine if the noncompliance is specific to them, this is a finding for the University. Effect: UAS is not in compliance with all statutory or regulatory provisions as it pertains to the notification of students exiting its grace period. Any finding UAS receives that is not mitigated with additional testing (with results of no errors specific to the college or university), that finding becomes a finding of the institutions they service. Repeat Finding: No Recommendation: We recommend that the University implement a thorough review process of all third-party servicer contracts to make sure they comply with all Department of Education Rules and Regulations. View of Responsible Official: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster CFDA Numbers: 84.038 ? Federal Perkins Loans Award Period: July 1, 2018 to June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: The Code of Federal Regulation, 34 CFR 674.42 requires contact to a borrower for the first time 90 days after the commencement of any grace period. The University at this time shall remind the borrower of his or her responsibility to comply with the terms of the loan. The University is then required at 150 days and 240 days to send subsequent notices to notify the borrower of the first required payment. Condition: The University utilizes University Accounting Service, LLC (UAS) for its third-party Perkins Loan servicing. This is a very common practice for colleges and universities in order to provide the most efficient and effective means to not only collect loans but meet the federal regulations for servicing student Perkins Loans. In auditing the compliance features for the loan servicing, CliftonLarsonAllen utilizes the external compliance report performed for UAS by other auditors. We noted within the UAS compliance audit report for the year ended June 30, 2019, there was a finding for not contacting the student within the required timeframes. The audit did not specify the students that were not contacted within the required guidelines and UAS is one of the largest third-party servicer for federal student loans. Therefore, we do not know if there were any University of St. Thomas students that were impacted by the noncompliance noted at UAS. Questioned Costs: None Context: We noted the University?s third-party servicer, UAS, failed to comply with notifying students of their grace period as required noting 2 of 50 students were noncompliant. Cause: UAS, the third-party servicer, did not have controls in place to ensure they complied with Department of Education Rules and Regulations in regards to timely engagement with students with federal loans. Given the University relies on UAS to meet their compliance responsibilities and there was not testing completed specifically for the University to determine if the noncompliance is specific to them, this is a finding for the University. Effect: UAS is not in compliance with all statutory or regulatory provisions as it pertains to the notification of students exiting its grace period. Any finding UAS receives that is not mitigated with additional testing (with results of no errors specific to the college or university), that finding becomes a finding of the institutions they service. Repeat Finding: No Recommendation: We recommend that the University implement a thorough review process of all third-party servicer contracts to make sure they comply with all Department of Education Rules and Regulations. View of Responsible Official: There is no disagreement with the audit finding.
Grace Period Notifications CFDA No: 84.038 Recommendation: It was recommended the University implement a thorough review process of all third-party servicer contracts to make sure they comply with all Department of Education Rules and Regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University of St. Thomas reached out to UAS in October of 2019 and asked what their action plan was for the UAS finding that flows to universities. The UAS audit findings were specific to the new UAS Connect platform and not the UAS Echo Loan Manage site. Since St. Thomas? Federal Perkins and Roach Fellowship programs are both housed in the UAS Echo Loan Manager site, there were no accounts from the University of St. Thomas relevant to the findings. The programming that caused the grace period ending letters to fail has been addressed and corrected at UAS in the UAS Connect platform. St. Thomas therefore does not see this being an issue moving forward. Name(s) of the contact person(s) responsible for corrective action: William (Bill) Peterson is the Perkins Coordinator within the Business Office at the University of St. Thomas. Bill will be responsible for working with UAS and maintaining compliance moving forward. Planned completion date for corrective action plan: October 31, 2019.
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. Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) (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). Questioned Costs: None Context: During our audit procedures, it was noted that the University had not performed 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 documented safeguards for identified risks. Cause: The University did not perform an IT risk assessment tailored specifically to the organization, identify risks, or address risks identified as required by the GLBA. Possible Asserted Effect: Personal information could be vulnerable without safeguards in place. Repeat Finding: No Recommendation: We recommend that the University designate an individual to 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. View of Responsible Official: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Award Period: July 1, 2018 to June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters 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. Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) (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). Questioned Costs: None Context: During our audit procedures, it was noted that the University had not performed 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 documented safeguards for identified risks. Cause: The University did not perform an IT risk assessment tailored specifically to the organization, identify risks, or address risks identified as required by the GLBA. Possible Asserted Effect: Personal information could be vulnerable without safeguards in place. Repeat Finding: No Recommendation: We recommend that the University designate an individual to 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. View of Responsible Official: There is no disagreement with the audit finding.
Gramm-Leach-Bliley Act Requirements CFDA No: 84.007; 84.033; 84.038; 84.063; 84.268 Recommendation: It was recommended the University designate an individual to 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: During the coming year, the University of St. Thomas will perform a GLBA risk assessment to identify, asses and respond to risks in regards to student information. This risk assessment will include documentation of the safeguards for each risk. Once this risk assessment is performed, it will be updated on an annual basis. Name(s) of the contact person(s) responsible for corrective action: Chris Gregg, Chief Information Security Officer (651-962-6265) Planned completion date for corrective action plan: June 30, 2020
FAC accepted this audit on November 27, 2018 — management decision was due May 27, 2019.
FAC accepted this audit on December 10, 2017 — management decision was due June 10, 2018.
FAC accepted this audit on December 22, 2016 — management decision was due June 22, 2017.
GSA_MIGRATION
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GSA_MIGRATION
2015-001
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