EIN: 410970173
UEI: GMELUJERZCF3
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 9, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by August 9, 2026 (18 days ago).
What is a management decision? →During testing of Direct Loans for a sample of 25 students, the auditors noted that for three students, AGS was unable to provide documentation demonstrating that required communications related to Direct Loan disbursements were provided to the students. Specifically, documentation evidencing the issuance, timing, and content of the required disbursement notifications was not retained. Cause: Management indicated that the institution did not have adequate internal control procedures in place to ensure retention and accessibility of documentation supporting that such communications were issued to students. Effect or Potential Effect: The absence of documented evidence supporting required Direct Loan disbursement communications represents a deficiency in internal control over compliance. While no improper disbursements were identified and no questioned costs resulted, this deficiency increases the risk that noncompliance with federal Direct Loan program requirements could occur and not be detected in a timely manner. Accordingly, the deficiency is considered a significant deficiency. Questioned Costs: None Auditee Response: AGS concurs with the auditors' findings and takes compliance very seriously. Corrective actions were implemented for the Fall 2025 term to ensure all students are notified of Direct Loan disbursements and that sufficient documentation is maintained.
Show full finding ▾Hide full finding ▴Criteria: Uniform Guidance 2 CFR 200.303(a) requires non-federal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of federal awards. Additionally, the U.S. Department of Education regulations require institutions to notify students of Direct Loan disbursements and maintain sufficient documentation to demonstrate compliance with applicable disclosure and notification requirements, including 34 CFR 668.165(a) and 34 CFR 685.301. Condition: During testing of Direct Loans for a sample of 25 students, the auditors noted that for three students, AGS was unable to provide documentation demonstrating that required communications related to Direct Loan disbursements were provided to the students. Specifically, documentation evidencing the issuance, timing, and content of the required disbursement notifications was not retained. Cause: Management indicated that the institution did not have adequate internal control procedures in place to ensure retention and accessibility of documentation supporting that such communications were issued to students. Effect or Potential Effect: The absence of documented evidence supporting required Direct Loan disbursement communications represents a deficiency in internal control over compliance. While no improper disbursements were identified and no questioned costs resulted, this deficiency increases the risk that noncompliance with federal Direct Loan program requirements could occur and not be detected in a timely manner. Accordingly, the deficiency is considered a significant deficiency. Questioned Costs: None Auditee Response: AGS concurs with the auditors' findings and takes compliance very seriously. Corrective actions were implemented for the Fall 2025 term to ensure all students are notified of Direct Loan disbursements and that sufficient documentation is maintained.
Corrective actions were implemented for the Fall 2025 term to ensure all students are notified of Direct Loan disbursements and that sufficient documentation is maintained.
FAC accepted this audit on February 19, 2023 — management decision was due August 19, 2023.
The School was unable to verify that the quarterly public reports for both the student aid portions and institutional portions were properly reviewed and approved by an appropriate independent person and posted to the School?s website, or updated, on a timely basis. Questioned Costs: Not applicable. Context: Not applicable. Cause: The School did not retain verifiable evidence to support adherence to report review and approval requirements or reporting deadlines in accordance with HEERF requirements. Effect: The School did not provide the public with timely, accurate data related to student aid and institutional expenditures. Recommendation: The School should assign an individual to monitor reporting requirements of HEERF awards to ensure the School is in compliance. Management's Response: Management agrees with the finding and will implement enhanced procedures to comply with the requirement of Section 18004(e) of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and 2 CFR sections 200.328 and 200.329.
Show full finding ▾Hide full finding ▴Finding 2022-001: Significant Deficiency in Reporting Federal Program - COVID-19 ? Education Stabilization Fund Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable AL Number - 84.425 Federal Award Identification Numbers - P425E205608, P425F205088 and P425N200710 Federal Award Year - June 30, 2022 Repeat of Prior Year Finding 2021-001 Criteria: Section 18004(e) of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), and Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) requires institutions receiving funds under the respective sections, to submit a report to the Secretary describing the use of funds distributed from the Higher Education Emergency Relief Funds (HEERF). While the American Rescue Plan Act (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR Section 200.328 and 2 CFR section 200.329. Condition: The School was unable to verify that the quarterly public reports for both the student aid portions and institutional portions were properly reviewed and approved by an appropriate independent person and posted to the School?s website, or updated, on a timely basis. Questioned Costs: Not applicable. Context: Not applicable. Cause: The School did not retain verifiable evidence to support adherence to report review and approval requirements or reporting deadlines in accordance with HEERF requirements. Effect: The School did not provide the public with timely, accurate data related to student aid and institutional expenditures. Recommendation: The School should assign an individual to monitor reporting requirements of HEERF awards to ensure the School is in compliance. Management's Response: Management agrees with the finding and will implement enhanced procedures to comply with the requirement of Section 18004(e) of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and 2 CFR sections 200.328 and 200.329.
2022-001 ? COVID-19 ? Education Stabilization Fund - Significant Deficiency in Reporting Recommendation: The School should assign an individual to monitor reporting requirements of HEERF awards to ensure the School is in compliance. Planned Action The School plans to review enhance processes related to HEERF reporting to ensure compliance with the requirement of Section 18004(e) of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Section314(e) of the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and 2 CFR sections 200.328 and 200.329. Proposed Completion Date: The School will review processes to ensure we are in compliance by March 15, 2023.
2021-001
The School?s policies and procedures over procurement generally comply with the requirements outlined by the Uniform Guidance, which establishes methods of procurement to be utilized related to the acquisition of both goods and services. However, the School?s policies do not fully adhere to the requirements, as there is no policy or procedure in place related to the verification of vendor suspension or debarment prior to contracting with the vendor. Additionally, the auditors reviewed one procurement transaction over the micro-purchase threshold and noted that the School?s policies were not followed with regard to ensuring full and open competition by obtaining bids or quotes. The School did check for suspension/disbarment following our identification of the finding, and there were no issues. Questioned Costs: Not applicable. Context: Not applicable. Cause: The School's policies were not compared to Uniform Guidance to ensure all elements were incorporated prior to entering into a contract with a vendor for which federal funds were the source of the expenditure. Additionally, the School?s procedures were not followed appropriately with regard to vendor bids/selection. Effect: The School is at risk of procuring goods and services that are not in compliance with the requirements of the Uniform Guidance, which increases the risk of federal funds being used improperly or the School entering into a covered transaction with a vendor that is suspended or debarred. Recommendation: The School should revise its policies and procedures to comply with the requirements of the Uniform Guidance and ensure that they are followed to verify that a vendor with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Additionally, all employees involved in procurement should be trained on the School?s procurement policies and procedures to avoid a break down of internal controls designed to reduce the risk of improper expenditures. Management's Response: Management did review all HEERF-related contracts and expenditures for reasonableness to ensure that the school was being prudent with its financial resources. Management agrees with the finding and will draft a ?Federal Grants Management Policy Manual? and implement related procedures which will be in compliance with 2 CFR 200.318(a). Policy and procedures will address all applicable compliance requirements.
Show full finding ▾Hide full finding ▴Finding 2022-002: COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds, Procurement, Suspension and Disbarment Federal Program - COVID-19 Education Stabilization Fund (ESF) - Institutional Portion Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable AL Number - 84.425F, 84.425N Federal Award Identification Numbers - P425F205088 Federal Award Year - June 30, 2022 Criteria: General procurement standards outlined in 2 CFR 200.318(a) state that a non-Federal entity. Must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to the applicable Federal law and the standards identified by the Uniform Guidance (sections 200.318 ? 200.326). The Uniform Guidance outlines requirements over the proper oversight of contractors, having written standards of conduct for employees involved in contracting, awarding contracts to responsible contractors, maintaining records documenting the history of procurements including cost price analysis, conducting all transactions in a manner which provides full and open competition, having procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded, utilizing the methods of procurement outlined in the Uniform Guidance, and ensuring every purchase order or contract includes the applicable provisions in Appendix II. Condition: The School?s policies and procedures over procurement generally comply with the requirements outlined by the Uniform Guidance, which establishes methods of procurement to be utilized related to the acquisition of both goods and services. However, the School?s policies do not fully adhere to the requirements, as there is no policy or procedure in place related to the verification of vendor suspension or debarment prior to contracting with the vendor. Additionally, the auditors reviewed one procurement transaction over the micro-purchase threshold and noted that the School?s policies were not followed with regard to ensuring full and open competition by obtaining bids or quotes. The School did check for suspension/disbarment following our identification of the finding, and there were no issues. Questioned Costs: Not applicable. Context: Not applicable. Cause: The School's policies were not compared to Uniform Guidance to ensure all elements were incorporated prior to entering into a contract with a vendor for which federal funds were the source of the expenditure. Additionally, the School?s procedures were not followed appropriately with regard to vendor bids/selection. Effect: The School is at risk of procuring goods and services that are not in compliance with the requirements of the Uniform Guidance, which increases the risk of federal funds being used improperly or the School entering into a covered transaction with a vendor that is suspended or debarred. Recommendation: The School should revise its policies and procedures to comply with the requirements of the Uniform Guidance and ensure that they are followed to verify that a vendor with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Additionally, all employees involved in procurement should be trained on the School?s procurement policies and procedures to avoid a break down of internal controls designed to reduce the risk of improper expenditures. Management's Response: Management did review all HEERF-related contracts and expenditures for reasonableness to ensure that the school was being prudent with its financial resources. Management agrees with the finding and will draft a ?Federal Grants Management Policy Manual? and implement related procedures which will be in compliance with 2 CFR 200.318(a). Policy and procedures will address all applicable compliance requirements.
2022-002 ? COVID-19 ? Education Stabilization Fund ? Institutional Portion Recommendation: The School should revise its policies and procedures to comply with the requirements of the Uniform Guidance and ensure that they are followed to verify that a vendor with which its plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Additionally, all employees involved in procurement should be trained on the School?s procurement policies and procedures to avoid a break down of internal controls designed to reduce the risk of improper expenditures. Planned Action Management agrees with the finding and is committed to strengthening its procedures to avoid similar issues in the future. Members of the College did not appropriately follow federal procurement guidelines related to costs that were included in the institutional reimbursement portion of HEERF funding. This was an oversight and occurred as a result of the timing of when the purchases were made, or the contracts were entered into, and when the HEERF funding and applicable guidance was communicated by the Department of Education. At the time the contracts were entered into, members of the College did appropriately review all contracts and the related costs for reasonableness to ensure that the College was being prudent with its financial resources, whether from the federal government or not. Members of the College have also reviewed SAM to ensure that these vendors were not suspended or debarred. The College?s federal procurement policies and procedures will be updated to ensure that all items from the Uniform Guidance are included and followed for all federal grants. Proposed Completion Date: The School will review processes to ensure we are in compliance by March 15, 2023.
The drawdowns were completed, but were not reviewed or approved by anyone other than the original preparer. Questioned Costs: Not applicable. Context: Neither of the two drawdowns that were tested were reviewed or approved by someone who was not the original preparer. However, none of the reconciliations contained errors. The sample was not considered statistically valid. Cause: The School did not ensure proper review and approval of drawdown requests in accordance with HEERF requirements. Effect: Drawdowns could contain errors or may not balance, resulting in errors in the drawdowns. Recommendation: After the drawdown requests are completed, they should be reviewed and approved by someone other than the original preparer who would be knowledgeable enough to identify an error in the reconciliation. Management's Response: The School is aware that the drawdowns were not reviewed or approved by anyone other than the original preparer. The School currently has an insufficient number of personnel which does not allow for the drawdowns to be reviewed and approved by someone with sufficient knowledge other than the original preparer. The School is in the process of hiring a President, and with that hire, the drawdowns can be reviewed and approved by someone knowledgeable enough to identify an error in the reconciliation.
Show full finding ▾Hide full finding ▴Finding 2022-003: Significant Deficiency in Cash Management Federal Program - COVID-19 Education Stabilization Fund (ESF) ? Institutional and Student Portion Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable AL Number - 84.425 Federal Award Identification Numbers - P425E205608, P425F205088 and P425N200710 Federal Award Year - June 30, 2022 Criteria: Recipients of federal awards are required to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. Condition: The drawdowns were completed, but were not reviewed or approved by anyone other than the original preparer. Questioned Costs: Not applicable. Context: Neither of the two drawdowns that were tested were reviewed or approved by someone who was not the original preparer. However, none of the reconciliations contained errors. The sample was not considered statistically valid. Cause: The School did not ensure proper review and approval of drawdown requests in accordance with HEERF requirements. Effect: Drawdowns could contain errors or may not balance, resulting in errors in the drawdowns. Recommendation: After the drawdown requests are completed, they should be reviewed and approved by someone other than the original preparer who would be knowledgeable enough to identify an error in the reconciliation. Management's Response: The School is aware that the drawdowns were not reviewed or approved by anyone other than the original preparer. The School currently has an insufficient number of personnel which does not allow for the drawdowns to be reviewed and approved by someone with sufficient knowledge other than the original preparer. The School is in the process of hiring a President, and with that hire, the drawdowns can be reviewed and approved by someone knowledgeable enough to identify an error in the reconciliation.
2022-003 ?Significant Deficiency in Cash Management Recommendation: After the drawdown requests are completed, they should be reviewed and approved by someone other than the original preparer who would be knowledgeable enough to identify an error in the reconciliation. Planned Action The School plans to add an additional individual to the process to review and approve the drawdown requests. Proposed Completion Date: The School will review processes to ensure we are in compliance by January 31, 2023.
FAC accepted this audit on March 13, 2022 — management decision was due September 13, 2022.
The School was unable to verify that they posted, or posted timely, their initial and quarterly public reports for both the student aid portion and institutional portion, on their website. Additionally, for the institutional portion report for the quarter ended December 31, 2020, it appears the applicable expenditures and lost revenue for the period were not reported. The 2020 annual report did not disclose the funds the School expended under HEERF (a)(1) institutional dollars or (a)(3) dollars, and it could not be verified that the report was filed timely. Questioned Costs: Not applicable. Context: Not applicable. Cause: The School did not retain verifiable evidence to support adherence to HEERF reporting deadlines and did not post or fill out all of the forms and reports correctly in accordance with HEERF reporting requirements. Effect: The School did not comply with the reporting requirements related to HEERF reporting and did not provide the public with timely, accurate data related to student aid and institutional expenditures. Recommendation: The School should assign an individual to monitor reporting requirements of HEERF awards to ensure the School is in compliance. Management's Response: Management agrees with the finding and will implement enhanced procedures to comply with the requirement of Section 18004(e) of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and 2 CFR sections 200.328 and 200.329.
Show full finding ▾Hide full finding ▴Finding 2021-001: Significant Deficiency in Reporting Federal Program - COVID-19 ? Education Stabilization Fund Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable AL Number - 84.425 Federal Award Identification Numbers - P425E205608, P425F205088 and P425N200710 Federal Award Year - June 30, 2021 Criteria: Section 18004(e) of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), and Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) requires institutions receiving funds under the respective sections, to submit a report to the Secretary describing the use of funds distributed from the Higher Education Emergency Relief Funds (HEERF). While the American Rescue Plan Act (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: The School was unable to verify that they posted, or posted timely, their initial and quarterly public reports for both the student aid portion and institutional portion, on their website. Additionally, for the institutional portion report for the quarter ended December 31, 2020, it appears the applicable expenditures and lost revenue for the period were not reported. The 2020 annual report did not disclose the funds the School expended under HEERF (a)(1) institutional dollars or (a)(3) dollars, and it could not be verified that the report was filed timely. Questioned Costs: Not applicable. Context: Not applicable. Cause: The School did not retain verifiable evidence to support adherence to HEERF reporting deadlines and did not post or fill out all of the forms and reports correctly in accordance with HEERF reporting requirements. Effect: The School did not comply with the reporting requirements related to HEERF reporting and did not provide the public with timely, accurate data related to student aid and institutional expenditures. Recommendation: The School should assign an individual to monitor reporting requirements of HEERF awards to ensure the School is in compliance. Management's Response: Management agrees with the finding and will implement enhanced procedures to comply with the requirement of Section 18004(e) of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Section 314(e) of the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and 2 CFR sections 200.328 and 200.329.
March 3, 2022 U.S. Department of Education Adler Graduate School respectfully submits the following corrective action plan for the year ended June 30, 2021. Name and address of independent public accounting firm: Baker Tilly 225 South 6th Street Minneapolis, MN 55402 Audit period: July 01, 2020 ? June 30, 2021 The findings from the June 30, 2021 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings ? Federal Awards Findings and Questioned Costs 2021-001 ? COVID-19 ? Education Stabilization Fund - Significant Deficiency in Reporting Recommendation: The School should assign an individual to monitor reporting requirements of HEERF awards to ensure the School is in compliance. Planned Action The School plans to review enhance processes related to HEERF reporting to ensure compliance with the requirement of Section 18004(e) of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Section314(e) of the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and 2 CFR sections 200.328 and 200.329. Proposed Completion Date: The School will review processes to ensure we are in compliance by March 15, 2022. Sincerely, Jennie Claver Consulting CFO
FAC accepted this audit on November 27, 2018 — management decision was due May 27, 2019.
GSA_MIGRATION
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GSA_MIGRATION
2017-003
FAC accepted this audit on November 21, 2017 — management decision was due May 21, 2018.
GSA_MIGRATION
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GSA_MIGRATION
2016-003
FAC accepted this audit on October 20, 2016 — management decision was due April 20, 2017.
GSA_MIGRATION
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GSA_MIGRATION
2015-002
GSA_MIGRATION
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GSA_MIGRATION
2015-007
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