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Bethel UniversityHigher Education

EIN: 410708577

UEI: RDG1PW7YKSM9

Audited by: CliftonLarsonAllen LLP

Oversight agency: 84 [Department of Education]

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Data as of September 7, 2026

Bethel University10 audit years18 findings8 repeat
10
Audit Years
18
Total Findings
8
Repeat Findings
$23.1M
Federal Awards Expended (FY 2025)

FY 2025-05-31

$23,133,469 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on January 14, 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 July 14, 2026 (59 days ago).

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2025-001
Special Tests & Provisions
MATERIAL WEAKNESSREPEAT OF 2024-002OTHER MATTERS

During our testing, we noted 33 out of the 60 students tested did not have enrollment data certified every 60 days. In 7 of the 60 students tested, the students’ status per the institution's records did not match what was reported to NSLDS. Furthermore, 24 out of the 60 students had an incorrect enrollment effective date. Questioned Costs: N/A Context: During our testing, it was noted the University does not have adequate processes in place to ensure timeliness and accuracy of NSLDS reporting. Cause: The University’s processes and controls did not ensure that student status changes were properly reported to NSLDS in a timely manner. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: Yes, finding 2024-002 Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

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Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: Various Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number: N/A Award Period: June 1, 2024 – May 31, 2025 Type of Finding: • Material Weakness in Internal Control over Financial Reporting • 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 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 33 out of the 60 students tested did not have enrollment data certified every 60 days. In 7 of the 60 students tested, the students’ status per the institution's records did not match what was reported to NSLDS. Furthermore, 24 out of the 60 students had an incorrect enrollment effective date. Questioned Costs: N/A Context: During our testing, it was noted the University does not have adequate processes in place to ensure timeliness and accuracy of NSLDS reporting. Cause: The University’s processes and controls did not ensure that student status changes were properly reported to NSLDS in a timely manner. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: Yes, finding 2024-002 Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Corrective Action Plan

Student Financial Aid Cluster – 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: In response to these challenges, the University initiated corrective actions beginning in Summer 2025. 1. Dedicated Technical Resources: We have been assigned dedicated ITS staff members (managed by Dynamic Campus) specifically to the resolution of enrollment and graduation submission and compilation logic. 2. Submission Scheduling: A rigid schedule for monthly enrollment and graduation submissions has been established for both Branch 00 and Branch 76. 3. Staffing: An additional Registrar’s Office staff member has been shifted to assist with the NSC process, specifically focusing on the remediation of error reports. 4. Policy Revision: We have simplified the degree conferral policy to improve the accuracy of graduation reporting. We are also working to align end of term grade submission deadlines to allow for timely end of term processing and degree conferrals. This in turn will aid in more timely submissions especially as it affects graduation reporting. 5. Data Mapping: The Registrar’s Office has collaborated with ITS to audit the specific fields and tables used to generate Clearinghouse reports. This addresses the complexity of reporting on two branches involving multiple term codes. 6. Automation: We have implemented a timely and automated submission schedule. 7. Change Management Protocols: A protocol is being implemented to prevent ITS system upgrades or network maintenance during scheduled reporting windows. 8. Data Reconciliation: We will implement a strict monitoring of Clearinghouse records regarding graduation and withdrawal dates, reconciling them against the Student Information System (SIS) and NSLDS data. That will occur once we can gain NSLDS access for the two staff members. Discrepancies will be corrected immediately. Special attention will be paid to conferral dates since they may not align with the final day of the term or sub-term. 9. Cross-Departmental Alignment: We will continue regular consultations with the Financial Aid Office regarding complex registration changes to ensure consistent interpretation and reporting. 10. Ongoing Training: Staff will continue to utilize training opportunities provided by the Clearinghouse, Banner, and other relevant bodies. Name(s) of the contact person(s) responsible for corrective action: Cheryl Fisk, University Registrar Planned completion date for corrective action plan: March 1, 2026

Prior Finding References

2024-002

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2025-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

During our testing, we noted that the University does not have a designated WISP compliance officer or Qualified Individual. We also noted that Bethel has not reviewed or updated any GLBA policies since 2023. Questioned Costs: N/A Context: During our testing, it was noted the University did not address the designated WISP compliance officer requirement. The University did not have adequate processes in place to ensure that GLBA safeguards were being following and operating effectively. Cause: The University’s processes and controls did not ensure that GLBA safeguards were effective and running properly. Effect: The University did not comply with GLBA safeguard rules by failing to have a WISP officer or Qualified Individual in place. Also, the University did not comply with GLBA safeguard rules by not reviewing or updating GLBA policies since 2023. Repeat Finding: No Recommendation: CLA recommends reviewing and updating key IT/financially relevant organization-wide policies and procedures on an annual basis. CLA also recommends the Organization review the institution's written information security program and ensure that a qualified individual (i.e. CIO, CISO, ISO) has been identified to enforce and monitor GLBA compliance. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding

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Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: Various Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number: N/A Award Period: June 1, 2024 – May 31, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 16 CFR 314.4(a), states that the first element an institution's written information security program must address is the designation of an individual with responsibility for implementing and enforcing an institution’s written information security program. The regulations refer to this individual as the Qualified Individual. If an institution has not designated a Qualified Individual, it is not in compliance with the GLBA requirements. The Qualified Individual has ultimate responsibility and accountability for implementing and enforcing the institution’s information security program. As well, the regulations do provide for an institution to use a service provider as the Qualified Individual. In cases where an institution uses a service provider as the Qualified Individual, the institution must: • Retain responsibility for compliance with GLBA; • Designate a senior member of its personnel responsible for direction and oversight of the Qualified Individual; and • Require the service provider or affiliate to maintain an information security program that protects the institution in accordance with the requirements of the regulations at 16 CFR Part 314(a)(1) through (3). The Code of Federal Regulations, 16 CFR 314.4(g), states that there must be an evaluation and adjustment of its information security program in light of the results of the required testing and monitoring; any material changes to its operations or business arrangements; the results of the required risk assessments; or any other circumstances that it knows or has reason to know may have a material impact on the institution's information security program. Condition: During our testing, we noted that the University does not have a designated WISP compliance officer or Qualified Individual. We also noted that Bethel has not reviewed or updated any GLBA policies since 2023. Questioned Costs: N/A Context: During our testing, it was noted the University did not address the designated WISP compliance officer requirement. The University did not have adequate processes in place to ensure that GLBA safeguards were being following and operating effectively. Cause: The University’s processes and controls did not ensure that GLBA safeguards were effective and running properly. Effect: The University did not comply with GLBA safeguard rules by failing to have a WISP officer or Qualified Individual in place. Also, the University did not comply with GLBA safeguard rules by not reviewing or updating GLBA policies since 2023. Repeat Finding: No Recommendation: CLA recommends reviewing and updating key IT/financially relevant organization-wide policies and procedures on an annual basis. CLA also recommends the Organization review the institution's written information security program and ensure that a qualified individual (i.e. CIO, CISO, ISO) has been identified to enforce and monitor GLBA compliance. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding

Corrective Action Plan

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: CLA recommends reviewing and updating key IT/financially relevant organization-wide policies and procedures on an annual basis. CLA also recommends the Organization review the institution's written information security program and ensure that a qualified individual (i.e. CIO, CISO, ISO) has been identified to enforce and monitor GLBA compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During the audit period, the University experienced significant employee turnover within the Information Technology department, which contributed to delays in the review and update of key IT and financially relevant policies and procedures. A new Chief Information Officer (CIO) has since been hired and has begun addressing the gaps noted in the finding. Under the CIO’s leadership, the University is actively reviewing and updating organization-wide IT policies, procedures, and the written information security program. The CIO is also assuming responsibility for enforcing and monitoring GLBA compliance going forward. Name(s) of the contact person(s) responsible for corrective action: John Honchell, CIO Planned completion date for corrective action plan: May 31, 2026

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FY 2024-05-31

$23,725,167 federal awards expended

FAC accepted this audit on February 27, 2025 — management decision was due August 27, 2025.

2024-002
Special Tests & Provisions
MATERIAL WEAKNESSREPEAT OF 2023-002OTHER MATTERS

During our testing, we noted 6 out of the 60 students tested did not have enrollment data certified every 60 days. In 10 of the 60 students tested, the students’ status per the institution's records did not match what was reported to NSLDS. Furthermore, 14 out of the 60 students had an incorrect enrollment effective date. Lastly, 1 of the 60 students tested was not reported to NSLDS at all but should have been. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness and accuracy of NSLDS reporting. Cause: The University’s processes and controls did not ensure that student status changes were properly reported to NSLDS in a timely manner. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: Yes – 2023-002 Auditor’s 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 and Planned Corrective Actions: There is no disagreement with the audit finding.

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Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: Various Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number: N/A Award Period: June 1, 2023 – May 31, 2024 Type of Finding: • Material Weakness 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 6 out of the 60 students tested did not have enrollment data certified every 60 days. In 10 of the 60 students tested, the students’ status per the institution's records did not match what was reported to NSLDS. Furthermore, 14 out of the 60 students had an incorrect enrollment effective date. Lastly, 1 of the 60 students tested was not reported to NSLDS at all but should have been. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness and accuracy of NSLDS reporting. Cause: The University’s processes and controls did not ensure that student status changes were properly reported to NSLDS in a timely manner. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: Yes – 2023-002 Auditor’s 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 and Planned Corrective Actions: There is no disagreement with the audit finding.

Corrective Action Plan

Student Financial Assistance Cluster – 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. Background: The Bethel University Registrar is responsible for ensuring timely and accurate reporting to NSLD via the National Student Clearinghouse. Cheryl Fisk was appointed to serve as University Registrar on August 1, 2022. While new to Bethel, she is not new to Clearinghouse reporting. She assumed the oversight of the Clearinghouse reporting and is working to ensure timely, accurate submissions. • Bethel reports student enrollment to NSLDS via the National Student Clearinghouse • Currently, the people involved in the process include: o Data Management Team: Ana Ortiz, Records and Data Specialist o Registrar Staff: Cheryl Fisk, University Registrar o Information Technology Service Staff: Bethel Information Technology Staff Based on the previous audit, adjustments were made to standardize the submissions to the Clearinghouse. Extra efforts were made to ensure that needed corrections were done within the required time frame. We have started to simplify our degree conferral policy to improve the accuracy of the reporting of graduates. However, because of major changes in the Information Technology Department staffing, we were not able to research how the submission reports are compiled or the automatic process that is used to clean and prepare the data before it is added to the submission reports. We have reviewed the Clearinghouse training. We have also sought the advice from other institutions who report to the Clearinghouse. We originally thought that the frequency of our batches was the problem. However, it appears that the issues may be in the way the submission data are prepared and compiled into the submission reports. Multiple reports must be compiled and then combined to create the submission for both branches. Corrective Action: Our corrective action will involve several parts. • First, we will work ITS staff to determine which fields and tables the submissions are using to create the Clearinghouse reports. Currently, the submission batches are reporting on two branches where multiple terms (i.e. termcodes) are involved. The reports may need to some revision. • Second, we will be proactive in confirming that the Clearinghouse has received our submissions and has processed them in a timely manner • Third, we will monitor closely what the Clearinghouse records show for graduation and withdrawal dates for students in comparison to what is in our student information system to ensure they are in sync. Then we will double check that information to what is showing at NSLDS. Corrections will be made if needed. • Fourth, we will continue to adjust our conferral process to ensure that graduation information is reported in a timely way • Fifth, we will confer with the Financial Aid Office when dealing with complicated registration changes. This will ensure we are in sync in our interpretations of the situation. • Sixth, we will continue to take advantage of Clearinghouse, Banner, and any other related training opportunities. Name of Contact person Responsible for Corrective Action: Cheryl Fisk Planned completion date for the correction action plan: June 1, 2025. This will provide time to test corrective measures to ensure everything is submitting properly.

Prior Finding References

2023-002

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2024-003
Special Tests & Provisions
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

During our testing, we noted a return of Title IV (R2T4) calculation was erroneously completely for a student that completed greater than 49% of a modular course. The student returned $925.74 of unsubsidized direct loans, but should not have done so. Questioned Costs: $925 Context: During our testing, we noted a return of Title IV (R2T4) calculation was erroneously completely for a student that completed greater than 49% of a modular course. The student returned $925 of unsubsidized direct loans, but should not have done so. Cause: The University used the proper inputs in the R2T4 calculation, but incorrectly concluded that the student had withdrawn and needed to return funds. Effect: The University is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Auditor’s Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are completed timely and accurately. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

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Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.268 Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number: N/A Award Period: June 1, 2023 – May 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(a)(2)(ii) states that in a program offered in modules, a student is not considered to have withdrawn if the student successfully completes one module that includes 49 percent or more of the number of days in the payment period, excluding scheduled breaks of five or more consecutive days and all days between modules. Condition: During our testing, we noted a return of Title IV (R2T4) calculation was erroneously completely for a student that completed greater than 49% of a modular course. The student returned $925.74 of unsubsidized direct loans, but should not have done so. Questioned Costs: $925 Context: During our testing, we noted a return of Title IV (R2T4) calculation was erroneously completely for a student that completed greater than 49% of a modular course. The student returned $925 of unsubsidized direct loans, but should not have done so. Cause: The University used the proper inputs in the R2T4 calculation, but incorrectly concluded that the student had withdrawn and needed to return funds. Effect: The University is not completing accurate R2T4 calculations as defined by the regulations. Repeat Finding: No Auditor’s Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are completed timely and accurately. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Corrective Action Plan

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are completed timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: On October 26, 2024, three modifications were made to the reporting tool the financial aid office uses for Return of Title IV Funds calculations to draw attention to situations when the “student completed more than 49% of a course” exception applies. First, we added a formula to the "5 - Title IV Checklist Revised" sheet in cell D16:F17. If the answer to question 11 "Exemption 3b: Successfully complete >49%?" is Yes, the following narrative will appear in blue, bold, font: "Student Completed more than 49% of a modular course; Exemption 3b applies; NOT a Withdrawal. R2T4 NOT Required. Might need to recalc aid." Second, we modified a formula in cell J34 on the "2 - R2T4 Calc Required" sheet, so that if there is a "yes" in cell C45 (indicating the student qualifies for the "completed more than 49% of a modular course" exemption), then the following phrase will appear in bold, red font: "Student Completed more than 49% of a modular course; Exemption 3b applies; NOT a Withdrawal. R2T4 NOT Required. Might need to recalc aid." Third, we added a formula to cell E36 on the "2 - R2T4 Calc Required" sheet, so that if there is a "yes" in cell C45 (indicating the student qualifies for the "completed more than 49% of a modular course" exemption), then the following phrase will appear in bold, blue font: "Student Completed more than 49% of a modular course; Exemption 3b applies; NOT a Withdrawal. R2T4 NOT Required. Might need to recalc aid." In addition, we completed additional training with the financial aid staff who complete R2T4 calculations to ensure they (a) understand rules related to the “student completed more than 49% of a course” exception, and (b) are aware of the additional warning messages that will appear in our R2T4 calculation spreadsheet. Name of the contact person responsible for corrective action: Jeffrey D Olson, Interim Director of Financial Aid Planned completion date for corrective action plan: October 26, 2024.

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FY 2023-05-31

$24,822,583 federal awards expended

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

2023-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2022-002OTHER MATTERS

During our testing, we noted 18 out of the 40 students tested where the student was not reported in a timely manner after the school determined the students change in status. Furthermore, 3 out of the 40 students had an incorrect report date reported at the enrollment level. Lastly, 1 of the 40 students had an incorrect report date reported at the program level. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness and accuracy of NSLDS reporting. Cause: The University did not have a process in place to ensure the student who graduated or withdrew were reported timely. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: Yes – 2022-002 Auditor’s Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

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2023 – 002 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: Various Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number: N/A Award Period: June 1, 2022 – May 31, 2023 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition: During our testing, we noted 18 out of the 40 students tested where the student was not reported in a timely manner after the school determined the students change in status. Furthermore, 3 out of the 40 students had an incorrect report date reported at the enrollment level. Lastly, 1 of the 40 students had an incorrect report date reported at the program level. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness and accuracy of NSLDS reporting. Cause: The University did not have a process in place to ensure the student who graduated or withdrew were reported timely. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: Yes – 2022-002 Auditor’s Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Corrective Action Plan

2023-002 Student Financial Assistance Cluster – 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: The Bethel University Registrar is responsible for ensuring timely and accurate reporting to NSLD via the National Student Clearinghouse. Cheryl Fisk was appointed to serve as University Registrar on August 1, 2022. While new to Bethel, she is not new to Clearinghouse reporting. She assumed the oversight of the Clearinghouse reporting and is working to ensure timely, accurate submissions. • Bethel reports student enrollment to NSLDS via the National Student Clearinghouse • Currently, the people involved in the process include: o Data Management Team: Ana Ortiz, Data Coordinator o Registrar Staff: Cheryl Fisk, University Registrar o Information Technology Service Staff: Kurt Jarvi, Systems Analyst Based on the previous audit, adjustments were made to the timing of the Clearinghouse enrollment submissions. This has been accomplished with enrollment being reported every month on the same date to enable automated submissions. As we tried to systematize graduation reporting, we encountered multiple technical issues. These issues involved both Information Technology and the Clearinghouse, which resulted in a delay in the reporting of graduates from May through August 2023. Additional training has been provided by the Clearinghouse and other sources which have been viewed by those involved in Clearinghouse reporting. We have also sought the advice from other institutions who report to the Clearinghouse. Our corrective action will involve several parts. • First, we will add more graduation only submissions to our Clearinghouse schedule to ensure they are getting reported in a timely manner. • Second, we will investigate where our Clearinghouse reports are pulling the graduation date form our Student Information System (Banner) to ensure those fields are accurate. • Third, we will review our process for determining degree conferral dates to ensure it aligns with our reporting schedule. • Fourth, over this past summer (2023) we worked with staff to clarify student withdrawal procedures. We will continue to do that. • Fifth, we will continue to take advantage of Clearinghouse training and other related training opportunities. • Sixth, we will be proactive in confirming that the Clearinghouse has received our submissions and has processed them in a timely manner. Name of the contact person responsible for corrective action: Cheryl Fisk, Registrar Planned completion date for corrective action plan: June 1, 2024

Prior Finding References

2022-002

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2023-003
Special Tests & Provisions
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Two checks totaling $3,074 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of May 31, 2023. Questioned Costs: $3,074 Context: During our testing, it was noted the University does not have a process in place to ensure timeliness and accuracy of checks refunded to ED after 240 days outstanding. Cause: The University did not have a process in place to ensure all outstanding checks over 240 days was properly returned to the ED. Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department. Repeat Finding: No Auditor’s Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

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2023 – 003 Special Tests: 240 Day Checks Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: Various Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number: N/A Award Period: June 1, 2022 – May 31, 2023 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. Condition: Two checks totaling $3,074 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of May 31, 2023. Questioned Costs: $3,074 Context: During our testing, it was noted the University does not have a process in place to ensure timeliness and accuracy of checks refunded to ED after 240 days outstanding. Cause: The University did not have a process in place to ensure all outstanding checks over 240 days was properly returned to the ED. Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department. Repeat Finding: No Auditor’s Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Corrective Action Plan

2023-003 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are working with IT to allow for the auditing of uncashed checks to be an action that can be fulfilled with minimal human resource used. We have resumed the monthly audit of student uncashed Title IV resources. Name of the contact person responsible for corrective action: Michael Johnson, Controller Planned completion date for corrective action plan: February 29, 2024

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2023-004
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

During our testing, we noted that 34 out of the 70 Perkins files tested, the MPN was not retained on file. Questioned Costs: None Context: The MPN’s for 34 students were not retained as required by the regulations. Cause: The loans were old and as such the records were not able to be found. Effect: The University was not in compliance with the Perkins recordkeeping regulation as it relates to MPNs. Repeat Finding: No Auditor’s Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

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2023 – 004 Perkins Recordkeeping Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.038 Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number: N/A Award Period: June 1, 2022 – May 31, 2023 Type of Finding: -Significant Deficiency in Internal Control over Compliance -Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 674-19(e) states that Institutions must retain original, true and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan made. Condition: During our testing, we noted that 34 out of the 70 Perkins files tested, the MPN was not retained on file. Questioned Costs: None Context: The MPN’s for 34 students were not retained as required by the regulations. Cause: The loans were old and as such the records were not able to be found. Effect: The University was not in compliance with the Perkins recordkeeping regulation as it relates to MPNs. Repeat Finding: No Auditor’s Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Corrective Action Plan

2023-004 Student Financial Assistance Cluster – Assistance Listing No. 84.038 Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: With one year until the program is fully sunset, we will continue to manage and safeguard the promissory notes that we have in our possession. We do not disagree that some MPNs were not able to be found, but with only 90 accounts remaining, we are confident that we have the grand majority of MPN’s needed to close the program in the near future. Name(s) of the contact person(s) responsible for corrective action: Michael Johnson, Controller Planned completion date for corrective action plan: March 1, 2024

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FY 2022-05-31

LOW-RISK AUDITEE$32,235,458 federal awards expended

FAC accepted this audit on February 26, 2023 — management decision was due August 26, 2023.

2022-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2021-001OTHER MATTERS

During our testing, we noted 11 out of 40 students tested where the student?s status was not reported to NSLDS with in 30 or 60 days of the date they determined the change of status. Questioned Costs: None Context: We noted discrepancies in period it took to report changes in enrollment statuses to NSLDS. Cause: The University's processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. 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 Auditor?s 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 Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

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Full finding narrative

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: Various Award Period: June 1, 2021 ? May 31, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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. Regulations require the status include an accurate effective date. In addition, 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 11 out of 40 students tested where the student?s status was not reported to NSLDS with in 30 or 60 days of the date they determined the change of status. Questioned Costs: None Context: We noted discrepancies in period it took to report changes in enrollment statuses to NSLDS. Cause: The University's processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. 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 Auditor?s 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 Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Corrective Action Plan

Student Financial Assistance Cluster Recommendation: We recommend 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: First, we will do a full audit of our report schedule to ensure the correct information is pulling into the correct report. Our current schedule shows that regular enrollment reports are submitted to the Clearinghouse every month. In addition, corrections are made within a few days of receiving the error reports. We will confirm with NSC that they are receiving all of our transmissions and corrections. Second, a very complex reporting system was previously set up based on programs and location. That system will be reviewed to determine if the current set up is best way to divide out the enrollment reporting. Corrective adjustments will be made once this thorough review is completed. Name of the contact person responsible for corrective action: Cheryl Fisk, Registrar Planned completion date for corrective action plan: June 1, 2023

Prior Finding References

2021-001

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2022-003
Eligibility
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

During our testing, we noted one out of the 40 students? tested for eligibility were not properly awarded subsidized Stafford loans. A student reported themselves as a sophomore during the 2021-22 academic year; however, the student was actually a freshman. The student?s Stafford loans were incorrectly overawarded $1,000 of subsidized loans. Questioned Costs: $1,000 Context: The student reported on his FAFSA that he would be a sophomore in the 2021-22 academic year. This response pulls through Banner which triggers the Grade Level and Subsidized Loan amount to be offered. The student was awarded $4,500 as a Sophomore; however, did not reach Sophomore status during the academic year therefore should have been awarded the maximum Subsidized loan amount for a Freshman of $3,500. Ultimately, the University over awarded the student in the amount of $1,000. Cause: The University's processes and controls did not ensure that student was correctly awarded based on their academic level causing the student to be over awarded for the 2021-22 academic year. Effect: The University is awarding subsidized Stafford loans for which the student is not eligible. However, the over awarded subsidized loan can be corrected by awarding an unsubsidized loan in place of it. Repeat Finding: No Auditor?s Recommendation: We recommend the University review its procedures to ensure the students' academic level is correctly reported to ensure proper awarding. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

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Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.268 Award Period: June 1, 2021 ? May 31, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203 specifies the annual and aggregate loan limits the Institutions may not exceed for an academic year of study under the Direct Loan program and also requires loans to be prorated for a program of student that is less than a full academic year in length. Condition: During our testing, we noted one out of the 40 students? tested for eligibility were not properly awarded subsidized Stafford loans. A student reported themselves as a sophomore during the 2021-22 academic year; however, the student was actually a freshman. The student?s Stafford loans were incorrectly overawarded $1,000 of subsidized loans. Questioned Costs: $1,000 Context: The student reported on his FAFSA that he would be a sophomore in the 2021-22 academic year. This response pulls through Banner which triggers the Grade Level and Subsidized Loan amount to be offered. The student was awarded $4,500 as a Sophomore; however, did not reach Sophomore status during the academic year therefore should have been awarded the maximum Subsidized loan amount for a Freshman of $3,500. Ultimately, the University over awarded the student in the amount of $1,000. Cause: The University's processes and controls did not ensure that student was correctly awarded based on their academic level causing the student to be over awarded for the 2021-22 academic year. Effect: The University is awarding subsidized Stafford loans for which the student is not eligible. However, the over awarded subsidized loan can be corrected by awarding an unsubsidized loan in place of it. Repeat Finding: No Auditor?s Recommendation: We recommend the University review its procedures to ensure the students' academic level is correctly reported to ensure proper awarding. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Corrective Action Plan

Student Financial Assistance Cluster Recommendation: We recommend the University review its procedures to ensure the students' academic level is correctly reported to ensure proper awarding. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid Director and Associate Director reviewed the student?s file associated with this finding. The error in certifying was associated with a one-time deviation from normal business practices in certifying loans. Financial aid staff involved in certifying loans were reminded, by the Associate Director, of the need to follow established business practices so these types of errors do not occur. Name of the contact person responsible for corrective action: Jeffrey Olson, Director of Financial Aid Planned completion date for corrective action plan: February 20, 2023

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2022-004
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

During our testing, we noted 1 of the 40 students tested had an applied date outside of the 15 day requirement to be applied to the student account. Questioned Costs: None Context: During our testing, it was noted the University did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The University did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Auditor?s Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

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Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: Various Award Period: June 1, 2021 ? May 31, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted 1 of the 40 students tested had an applied date outside of the 15 day requirement to be applied to the student account. Questioned Costs: None Context: During our testing, it was noted the University did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The University did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Direct Loan disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Auditor?s Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Corrective Action Plan

Student Financial Assistance Cluster Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial aid staff will review procedures related to reporting Pell disbursements to COD, and promptly responding to rejected records, to ensure that student information is reported accurately and timely. Name of the contact person responsible for corrective action: Jeffrey Olson, Director of Financial Aid Planned completion date for corrective action plan: May 31, 2023

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2022-005
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

During our testing, we noted that the NSLDS rosters returned yielded errors that were not corrected and resubmitted within the 10 days. Questioned Costs: None Context: During our review of the SCHER1 reports, we noted error records were not being corrected and resubmitted within the required 10 days. Cause: The University process and controls in place did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Auditor?s Recommendation: We recommend the University review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS and all errors are corrected with the appropriate timeframe as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

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Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: Various Award Period: June 1, 2021 ? May 31, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, if roster file submitted to NSLDS contains records that don?t pass the NSLDS enrollment reporting edits, an institution must make necessary corrections within 10 days and resubmit them. Condition: During our testing, we noted that the NSLDS rosters returned yielded errors that were not corrected and resubmitted within the 10 days. Questioned Costs: None Context: During our review of the SCHER1 reports, we noted error records were not being corrected and resubmitted within the required 10 days. Cause: The University process and controls in place did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Auditor?s Recommendation: We recommend the University review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS and all errors are corrected with the appropriate timeframe as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Corrective Action Plan

Student Financial Assistance Cluster Recommendation: We recommend the University review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS and all errors are corrected with the appropriate timeframe as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: First, we will do a full audit of our report schedule to ensure the correct information is pulling into the correct report. Our current schedule shows that regular enrollment reports are submitted to the Clearinghouse every month. In addition, corrections are made within a few days of receiving the error reports. We will confirm with NSC that they are receiving all of our transmissions and corrections. Second, we will also ensure that that multiple staff are thoroughly trained on the process of submitting files and correcting errors. This will provide redundancy to ensure transmissions and corrections are done in the required windows of time. Name of the contact person responsible for corrective action: Cheryl Fisk, Registrar Planned completion date for corrective action plan: June 1, 2023

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2022-006
Special Tests & Provisions
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

During our testing, we noted 7 of the 29 individuals tested had used an incorrect percentage of days attended causing the University to incorrectly calculated the return of Title IV funds. Questioned Costs: $9,558 Context: During our testing, we noted the University had a one-day variance which caused a negative impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The University's return of Title IV funds template was not including the first day of class thus students? percentage of days attended was miscalculated. Effect: The University is not completing accurate return of Title IV funds calculations as defined by the regulations. Repeat Finding: No Auditor?s Recommendation: We recommend the University review the return of Title IV funds requirements and implement procedures to ensure the return of Title IV funds calculations are using the correct number of break days and are accurately completed. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

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Full finding narrative

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: Various Award Period: June 1, 2021 ? May 31, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted 7 of the 29 individuals tested had used an incorrect percentage of days attended causing the University to incorrectly calculated the return of Title IV funds. Questioned Costs: $9,558 Context: During our testing, we noted the University had a one-day variance which caused a negative impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The University's return of Title IV funds template was not including the first day of class thus students? percentage of days attended was miscalculated. Effect: The University is not completing accurate return of Title IV funds calculations as defined by the regulations. Repeat Finding: No Auditor?s Recommendation: We recommend the University review the return of Title IV funds requirements and implement procedures to ensure the return of Title IV funds calculations are using the correct number of break days and are accurately completed. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Corrective Action Plan

Student Financial Assistance Cluster Recommendation: We recommend the University review the return of Title IV funds requirements and implement procedures to ensure the return of Title IV funds calculations are using the correct number of break days and are accurately completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office reviewed all R2T4 calculations for the 2021-2022 award year, recalculating the ?percent of aid earned? calculation when necessary. Information gleaned from the review of 2021-2022 R2T4 calculations was used to modify the spreadsheet used to process R2T4 calculations for 2022-2023. All 2022-2023 R2T4 calculations made prior to fixing the ?percent of aid earned? calculations were reviewed and adjusted, as needed. The audit tool we used to double-check the 2021-2022 ?percent of earned aid? calculations was added to the 2022-2023 R2T4 tool, as a way to flag calculation inconsistencies for 2022-2023 R2T4 calculations. Financial aid staff involved in processing R2T4 calculations were trained in how to use the revised R2T4 calculation tool. Name of the contact person responsible for corrective action: Jeffrey Olson, Director of Financial Aid Planned completion date for corrective action plan: February 20, 2023

About Special Tests and Provisions →

FY 2021-05-31

LOW-RISK AUDITEE$32,630,810 federal awards expended

FAC accepted this audit on June 1, 2022 — management decision was due December 1, 2022.

2021-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2020-001OTHER MATTERS

During our testing, we noted 6 out of 40 students tested were reported to NSLDS with an Incorrect enrollment effective date. There was also 3 out of 40 students tested where the students status was not reported to NSLDS with in 30 or 60 days of the date they determined the change of status. Lastly, 3 out of 40 students tested had effective dates per program level of NSLDS that did not match the institutions records for effective date of status change. Questioned Costs: None Context: We noted discrepancies in enrollment statuses reported to NSLDS. Cause: The University's processes and controls did not ensure that student status changes and effective dates were properly 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: Yes Auditor?s 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 Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

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Full finding narrative

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster CFDA Number: Various Award Period: June 1, 2020 ? May 31, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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. Regulations require the status include an accurate effective date. In addition, 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 6 out of 40 students tested were reported to NSLDS with an Incorrect enrollment effective date. There was also 3 out of 40 students tested where the students status was not reported to NSLDS with in 30 or 60 days of the date they determined the change of status. Lastly, 3 out of 40 students tested had effective dates per program level of NSLDS that did not match the institutions records for effective date of status change. Questioned Costs: None Context: We noted discrepancies in enrollment statuses reported to NSLDS. Cause: The University's processes and controls did not ensure that student status changes and effective dates were properly 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: Yes Auditor?s 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 Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Corrective Action Plan

2021-001: Student Financial Assistance Cluster 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. Regulations require the status include an accurate effective date. In addition, 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 6 out of 40 students tested were reported to NSLDS with an Incorrect enrollment effective date. There was also 3 out of 40 students tested where the students status was not reported to NSLDS with in 30 or 60 days of the date they determined the change of status. Lastly, 3 out of 40 students tested had effective dates per program level of NSLDS that did not match the institutions records for effective date of status change. Questioned Costs: None Context: We noted discrepancies in enrollment statuses reported to NSLDS. Cause: The University's processes and controls did not ensure that student status changes and effective dates were properly 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: Yes Auditor?s 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 Officials: There is no disagreement with the audit finding. Planned Corrective Actions: Bethel?s Registrar is responsible for ensuring timely and accurate enrollment reporting to NSLDS via the Clearinghouse. In September, 2020, our Registrar (Diane Krusemark) resigned to take a position at Wheaton College (IL). Bethel appointed Kerri Vickers to serve as Registrar effective December 7, 2020. On January 6, 2021, the Director of Financial Aid (Jeff Olson) asked Vickers to instruct the Clearinghouse to copy Vickers on all NSLDS SSCR Error reports. On February 1, 2021, Vickers confirmed she was working with the Clearinghouse to ensure she was included in NSLDS SSCR Error Reports. On March 8, 2021, Olson briefed Vickers on audit findings related to enrollment reporting to NSLDS from 2014-2015 through 2019-2020. On March 10, 2021, Vickers initiated a collaborative process involving staff from Registrar and Information Technology teams to (a) review Bethel?s enrollment reporting processes, (b) determine what caused the Clearinghouse to generate NSLDS SSCR Error reports, and (c) adjust Bethel?s enrollment reporting policies and procedures to ensure Bethel submits students? enrollment statuses accurately to NSLDS, via the Clearinghouse, as required by regulations. By October 1, 2021, new business practices were implemented to report student enrollment information into NSLDS. These practices impacted the following areas: ? Training for ITS and Registrar?s staff to ensure they have access, and know how to work with data, on Clearinghouse and NSLDS websites. ? Corrected problems in the ?graduate only? reports Bethel had been submitting, ? Corrected problems in sending ?enrollment reports? instead of ?degree verify reports.? ? Developed reports that identify discrepancies between withdrawal dates in different forms with our Banner enterprise software system, which are then prioritized and resolved by Registrar team. ? Registrar teams met to ensure all withdrawal dates were being tracked consistently, specifically those for students that were being processed beyond the term of their last attendance date. Inconsistent processes had been used previously, causing reporting errors. ? A review was conducted of all Program Duration Rule entries in Banner to make sure they were consistent and updated, as discrepancies in those entries had resulted in reporting errors. Below is a brief overview of the persons involved, and the review process to ensure accurate and timely reporting. ? Bethel reports student enrollment to NSLDS via the National Student Clearinghouse. ? People in the positions that are involved in the process include: o Data Management Team - Ana Ortiz, Data Coordinator o Registrar staff - Kerri Vickers, Registrar, and Michelle Graber, Assistant Registrar o Information Technology Services staff - Kurt Jarvi, Systems Analyst ? Data Management Team reviews transmissions to National Student Clearinghouse before submission and there is regular, continual communication between Registrar's Office and Info Technology Services staff to resolve errors and ensure timely transmissions. Our Registrar (Kerri Vickers) resigned effective April 29, 2022, to become Registrar at St. Catherine?s University (MN). In her absence Michelle Graber, Assistant Registrar, will assume responsibility for accurate and timely reporting of student enrollment data to NSLDS (via the National Clearinghouse) until such time as a new Registrar is employed. Michelle has completed training with the Registrar, including working closely with Ana Ortiz, Data Coordinator on correction of recent error reports, and participating in webinars and training opportunities through the National Student Clearinghouse to ensure compliance with (a) report correct ?effective date? to NSLDS, (b) report student status changes within 30 or 60 days of the date we determined the change of status, and (c) ensure the ?effective dates? at a program level in NSLDS match the institution?s records for the effective date of status change. It has become clear that a large contributing factor to errors in reporting is the institution?s use of three separate terms in Banner. As an increasing number of students take courses between two different schools or move into a program from one school to another, the students? branches can change causing them to appear on multiple or incorrect enrollment reports. This overly complex setup with multiple terms creates challenges with reporting our enrollment accurately. Bethel University is dedicating resources to combine the multiple schools and terms into one system with one single term code, which will alleviate a significant number of the errors that have been occurring. Name of the contact person responsible for corrective action: Michelle Graber Planned completion date for corrective action plan: June 1, 2022

Prior Finding References

2020-001

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2021-002
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

During our testing of the reporting process, we noted that documentation to support some of the amounts reported for student, institutional and annual reports did not reflect the support provided. Additionally, it was noted that two quarterly student reports were not reported timely. Lastly, there were multiple flags for quality as the reports were not completed properly, therefore internal controls surrounding the review process were determined to not be operating effectively. Questioned Costs: None Context: A robust tracking system was not employed for all the various reporting requirements included documentation of review and maintenance of records or recorded numbers. Cause: The University did not have a robust system in place to document and track reporting requirements. Effect: Inaccurate reporting on the University's annual report. Additionally, two reports were submitted late. Repeat Finding: No Auditor?s Recommendation: We recommend the University establish a system to track due dates of reports to ensure timely submission and retain documents to support the submission and accuracy of the reports. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

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Federal Agency: Department of Education Federal Program Title: Education Stabilization Fund CFDA Numbers: 84.425E and 84.425F Award Period: June 1, 2020 ? May 31, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Uniform Guidance 2 CFR 200.303 states that non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the Institution?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. Condition: During our testing of the reporting process, we noted that documentation to support some of the amounts reported for student, institutional and annual reports did not reflect the support provided. Additionally, it was noted that two quarterly student reports were not reported timely. Lastly, there were multiple flags for quality as the reports were not completed properly, therefore internal controls surrounding the review process were determined to not be operating effectively. Questioned Costs: None Context: A robust tracking system was not employed for all the various reporting requirements included documentation of review and maintenance of records or recorded numbers. Cause: The University did not have a robust system in place to document and track reporting requirements. Effect: Inaccurate reporting on the University's annual report. Additionally, two reports were submitted late. Repeat Finding: No Auditor?s Recommendation: We recommend the University establish a system to track due dates of reports to ensure timely submission and retain documents to support the submission and accuracy of the reports. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Corrective Action Plan

2021-002: Education Stabilization Fund ? Assistance Listing Nos. 84,425E and 84.425F Recommendation: We recommend the University establish a system to track due dates of reports to ensure timely submission and retain documents to support the submission and accuracy of the reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Upon learning that reporting related to HEERF funding was not submitted in a timely fashion the University reassigned responsibility for reporting to the University Controller and the Director of Financial Aid. Both parties now received requests and automated remainders from the Department. In addition, monthly meeting have been scheduled through the 2022 calendar year to review any reporting requirements. Names of the contact persons responsible for corrective action: Wade Holmberg and Jeff Olson Planned completion date for corrective action plan: 4-25-22

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FY 2020-05-31

LOW-RISK AUDITEE$34,139,151 federal awards expended

FAC accepted this audit on April 5, 2021 — management decision was due October 5, 2021.

2020-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2019-001OTHER MATTERS

In our testing of NSLDS reporting, it was noted that the graduate enrollment statuses of all post-baccalaureate students who graduated after the fall term were incorrectly reported to NSLDS. Questioned Costs: None Context: We noted discrepancies in enrollment statuses reported to NSLDS for 2 of 40 students tested. The same issue affected all post-baccalaureate students who graduated after the fall term. Cause: The University's processes and controls did not ensure that student status changes were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, 2019-001 Auditor?s 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 Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

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Full finding narrative

Significant Deficiency in Internal Control over Compliance and 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. Regulations require the status include an accurate effective date. In addition, 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: In our testing of NSLDS reporting, it was noted that the graduate enrollment statuses of all post-baccalaureate students who graduated after the fall term were incorrectly reported to NSLDS. Questioned Costs: None Context: We noted discrepancies in enrollment statuses reported to NSLDS for 2 of 40 students tested. The same issue affected all post-baccalaureate students who graduated after the fall term. Cause: The University's processes and controls did not ensure that student status changes were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, 2019-001 Auditor?s 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 Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Corrective Action Plan

United States Department of Education Bethel University and Affiliates respectfully submit the following corrective action plan for the year ended May 31, 2020. Audit period: June 1, 2019 to May 31, 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 current year. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS United States Department of Education 2020-001 Student Financial Assistance Cluster ? CFDA No. 84.268 Recommendation: The University should review its reporting procedures to ensure 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: Bethel?s Registrar is responsible for ensuring timely and accurate enrollment reporting to NSLDS via the Clearinghouse. In September 2020, our Registrar resigned to take a position at Wheaton College (IL). Bethel appointed Kerri Vickers to serve as Registrar effective December 7, 2020. On January 6, 2021, the Director of Financial Aid (Jeff Olson) asked Vickers to instruct the Clearinghouse to copy Kerri Vickers on all NSLDS SSCR Error reports. On February 1, 2021, Kerri Vickers confirmed she was working with the Clearinghouse to ensure she was included in NSLDS SSCR Error Reports. On March 8, 2021, Jeff Olson briefed Kerri Vickers on audit findings related to enrollment reporting to NSLDS from 2014-2015 through 2019-2020. On March 10, 2021, Kerri Vickers initiated a collaborative process involving staff from Registrar and Information Technology teams to (a) review Bethel?s enrollment reporting processes, (b) determine what caused the Clearinghouse to generate NSLDS SSCR Error reports, and (c) adjust Bethel?s enrollment reporting policies and procedures to ensure Bethel submits students? enrollment statuses accurately to NSLDS, via the Clearinghouse, as required by regulations. Name of the contact person responsible for corrective action: Kerri Vickers Planned completion date for corrective action plan: June 1, 2021 If the Department of Education has questions regarding this plan, please call Amy Blaz at 651-638-6120.

Prior Finding References

2019-001

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FY 2019-05-31

LOW-RISK AUDITEE$34,575,080 federal awards expended

FAC accepted this audit on November 14, 2019 — management decision was due May 14, 2020.

2019-001
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

During our testing of the Direct Loan and Pell Grant programs, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). We noted, during our testing, that 4 out of 26 students tested for NSLDS enrollment reporting were not reported with correct enrollment status and 1 out of 26 students was not reported with a correct effective date to NSLDS. Questioned Costs: None Context: We noted discrepancies in enrollment status and effective dates reported to NSLDS for 5 of 26 students tested. Cause: The University's processes and controls did not ensure that student status changes and effective dates were properly 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 student information which can cause a student to not properly enter the repayment period. Repeat Finding: No Auditor?s Recommendation: We recommend the University review its reporting procedures to ensure the students' statuses and effective dates are accurately reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

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2019 ? 001 Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster CFDA Number: Various Award Period: June 1, 2018 ? May 31, 2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 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. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). We noted, during our testing, that 4 out of 26 students tested for NSLDS enrollment reporting were not reported with correct enrollment status and 1 out of 26 students was not reported with a correct effective date to NSLDS. Questioned Costs: None Context: We noted discrepancies in enrollment status and effective dates reported to NSLDS for 5 of 26 students tested. Cause: The University's processes and controls did not ensure that student status changes and effective dates were properly 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 student information which can cause a student to not properly enter the repayment period. Repeat Finding: No Auditor?s Recommendation: We recommend the University review its reporting procedures to ensure the students' statuses and effective dates are accurately reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Corrective Action Plan

BETHEL UNIVERSITY BETHEL UNIVERSITY CORRECTIVE ACTION PLAN YEAR ENDED MAY 31, 2019 United States Department of Education Bethel University respectfully submits the following corrective action plan for the year ended May 31, 2019. Audit period: June 01, 2018 to May 31, 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 current year. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS United States Department of Education 2019-001 Student Financial Assistance Cluster - CFDA No. 84.268 Recommendation: The University should review its reporting procedures to ensure the students' statuses and effective dates 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: The Registrar has three main objectives and, in conjunction with Bethel Information Technology Services, plans to consult with Ellucian (parent company of Student Information System) and the National Student Clearinghouse to accomplish them. The three objectives are: (1) to determine the best way to record within the Student Information System and report the effective date of the enrollment status changes when students proactively withdraw from the institution after the end of an enrollment term, (2) to convert the assignment of Graduate enrollment statuses from the National Student Clearinghouse's "G from DV" (Graduate enrollment status from Degree Verification file) process to a Graduates Only enrollment submission process, and (3) to retroactively adjust the enrollment statuses in NSLDS from W to G for the students whose data failed the "G from DV" process since May 2018. Name(s) of the contact person(s) responsible for corrective action: Diane Krusemark, Registrar Planned completion date for corrective action plan: March 15, 2020. If the Department of Education has questions regarding this plan, please call Amy Blaz at 651-638-6120.

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FY 2018-05-31

LOW-RISK AUDITEE$35,465,841 federal awards expendedNo findings recorded this year

FAC accepted this audit on November 27, 2018 — management decision was due May 27, 2019.

FY 2017-05-31

LOW-RISK AUDITEE$35,889,944 federal awards expendedNo findings recorded this year

FAC accepted this audit on November 19, 2017 — management decision was due May 19, 2018.

FY 2016-05-31

$38,574,295 federal awards expended

FAC accepted this audit on December 7, 2016 — management decision was due June 7, 2017.

2016-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2015-001

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2015-001

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2016-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2015-002QUESTIONED COSTS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2015-002

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