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BETHANY FELLOWSHIP, INC.Non-Profit

EIN: 416110005

UEI: N2MQFMZVQ1C3

Audited by: CapinCrouse LLC

Oversight agency: 84 [Department of Education]

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Data as of August 31, 2026

BETHANY FELLOWSHIP, INC.9 audit years13 findings1 repeat
9
Audit Years
13
Total Findings
1
Repeat Findings
$1.3M
Federal Awards Expended (FY 2024)

FY 2024-06-30

LOW-RISK AUDITEE$1,340,892 federal awards expendedNo findings recorded this year

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 24, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 24, 2025 (342 days ago).

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FY 2023-06-30

$2,472,956 federal awards expended

FAC accepted this audit on November 20, 2023 — management decision was due May 20, 2024.

2023-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

When students withdrew, Bethany did not always return unearned Title IV aid timely as an attendance taking school. Additionally, there was one incorrect calculation of returned funds for a student that withdrew during a term due to an incorrect calendar setup. Criteria: 34 CFR 668.22 Questioned Costs: $-0- Context: Out of 6 students, 1 student who withdrew during the audit period tested had funds returned 78 days late while the financial aid director was unavailable. The fall 2022 traditional calendar did not include the weekends as break days, resulting in one student with an overreturn of $183 of subsidized loans. Because of the error rate, this is classified as a significant deficiency. Cause: This was an oversight by Bethany in reviewing the calendar setups and cross training for while an individual was out of the office. Effect: Incorrect amounts of federal funding were returned. There was an over-return of subsidized loans of $183. Additionally one return was made late. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany run a listing of withdrawals after each semester or each module and compare the list of students who had R2T4’s completed to ensure completeness. We further recommend a 0-credit report be run at the end of each semester or module to ensure all unofficial withdrawals are followed up on so that R2T4’s are completed timely when required. We recommend an individual with appropriate return calculation knowledge review each calendar set up and recalculate the first few withdrawals manually to ensure the system is functioning as intended. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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Incorrect and Untimely Return of Title IV (R2T4) Funds Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew, Bethany did not always return unearned Title IV aid timely as an attendance taking school. Additionally, there was one incorrect calculation of returned funds for a student that withdrew during a term due to an incorrect calendar setup. Criteria: 34 CFR 668.22 Questioned Costs: $-0- Context: Out of 6 students, 1 student who withdrew during the audit period tested had funds returned 78 days late while the financial aid director was unavailable. The fall 2022 traditional calendar did not include the weekends as break days, resulting in one student with an overreturn of $183 of subsidized loans. Because of the error rate, this is classified as a significant deficiency. Cause: This was an oversight by Bethany in reviewing the calendar setups and cross training for while an individual was out of the office. Effect: Incorrect amounts of federal funding were returned. There was an over-return of subsidized loans of $183. Additionally one return was made late. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany run a listing of withdrawals after each semester or each module and compare the list of students who had R2T4’s completed to ensure completeness. We further recommend a 0-credit report be run at the end of each semester or module to ensure all unofficial withdrawals are followed up on so that R2T4’s are completed timely when required. We recommend an individual with appropriate return calculation knowledge review each calendar set up and recalculate the first few withdrawals manually to ensure the system is functioning as intended. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Incorrect and Untimely Return of Title IV (R2T4) Calculations Planned Corrective Action: The academics and financial aid office will work in conjunction to run a zero-credit earned report at the end of each term and determine if there are any unidentified unofficial withdrawals that must be processed. Throughout the semester the academics department is logging attendance daily to ensure students do not fail for non-attendance and are not missing more than five without proper notice. For students in online courses, professors will check in on student engagement every two days, and the academic administrative team will do a check once a week to identify any students who may be an unofficial withdrawal. For the calendar for R2T4’s the Financial Aid office keeps an excel sheet with the term dates and breaks for the year and will manually check that the dates/percentages align with the calculations on the COD R2T4 calculator. The first couple of students processed will be calculated manually with the information in the excel sheet to ensure it aligns with the calculation completed on COD. Person Responsible for Corrective Action Plan: Anna Bergh, Financial Aid Director and Tiffany Garrison, Interim Registrar Anticipated Date of Completion: 10/27/23

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2023-003
Eligibility
QUESTIONED COSTSOTHER MATTERS

Bethany paid a student who was on SAP suspension federal work colleges dollars. Criteria: 34 CFR 668.32(f) Questioned Costs: $327 Context: Bethany had not received an approved appeal for one student after the fall semester. The student continued to work and was coded as federal work colleges instead of institutional work colleges. Cause: Bethany removed all aid except the coding of the federal work colleges after the student was on financial aid suspension. Effect: Noncompliance with federal work colleges requirements Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany review eligibility each semester in light of any satisfactory academic progress suspensions. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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Noncompliance with Federal Work Study/Federal Work Colleges Regulations DEPARTMENT OF EDUCATION ALN #: 84.033 Federal Work Study/Federal Work Colleges Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Bethany paid a student who was on SAP suspension federal work colleges dollars. Criteria: 34 CFR 668.32(f) Questioned Costs: $327 Context: Bethany had not received an approved appeal for one student after the fall semester. The student continued to work and was coded as federal work colleges instead of institutional work colleges. Cause: Bethany removed all aid except the coding of the federal work colleges after the student was on financial aid suspension. Effect: Noncompliance with federal work colleges requirements Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany review eligibility each semester in light of any satisfactory academic progress suspensions. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Noncompliance with Federal Work Study/Federal Work Colleges Regulations Planned Corrective Action: The federal funds have been returned and re-disbursed to the student with only institutional funds (Practical Training Tuition Scholarship). We have added a checklist to our SAP report for students who go on Financial Suspension due to not meeting SAP to make sure each award is addressed. Person Responsible for Corrective Action Plan: Anna Bergh, Financial Aid Director Anticipated Date of Completion: 10/27/23

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2023-004
Eligibility
OTHER MATTERS

A student was not appropriately paid subsidized aid based on need. Criteria: 34 CFR 685.203 Questioned Costs: $-0- Context: 1 student out of 51 was initially under awarded subsidized loans of $1,592. Cause: Bethany awarded the student the full eligibility of subsidized and unsubsidized loans. The student declined a portion of the subsidized loans and all of the unsubsidized loans. Bethany’s clean up reports did not identify this student as needing to have paid the full subsidized eligibility first. Effect: Incorrect allocation of subsidized versus unsubsidized affects the amount and timing of interest the student must repay. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany add a step in the clean up reports that looks for students with remaining need and acceptance of loans to ensure proper allocation has occurred. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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Need Analysis DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: A student was not appropriately paid subsidized aid based on need. Criteria: 34 CFR 685.203 Questioned Costs: $-0- Context: 1 student out of 51 was initially under awarded subsidized loans of $1,592. Cause: Bethany awarded the student the full eligibility of subsidized and unsubsidized loans. The student declined a portion of the subsidized loans and all of the unsubsidized loans. Bethany’s clean up reports did not identify this student as needing to have paid the full subsidized eligibility first. Effect: Incorrect allocation of subsidized versus unsubsidized affects the amount and timing of interest the student must repay. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany add a step in the clean up reports that looks for students with remaining need and acceptance of loans to ensure proper allocation has occurred. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Need Analysis Planned Corrective Action: We pull a report each term to verify that students have not been over or under awarded need-based aid or over or under awarded for their COA. We have added a step to our report that is specifically checking that subsidized eligibility has been maximized when a student has both subsidized and unsubsidized loans. This is completed after students have accepted their aid so it will allow us to catch if a student accepted part of both types of loans and make the necessary correction. Person Responsible for Corrective Action Plan: Anna Bergh, Financial Aid Director Anticipated Date of Completion: 10/27/23

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2023-005
Special Tests & Provisions
OTHER MATTERS

Bethany did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: Bethany has contracted with a third party to assist with compliance with GLBA. Bethany is in the process of fully documenting its information security program. Bethany has implemented multi-factor authentication (MFA) on some systems that contain personally identifiable information and is working to implement MFA on the remaining systems. Bethany is also working to implement sufficient continuous monitoring, such as penetration testing and vulnerability scanning. Cause: The timing of the contracting by Bethany has not allowed all updated components of GLBA to be addressed and documented during the audit process. Effect: Bethany may have unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany work with the third party and determine timeframes remaining to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Bethany did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: Bethany has contracted with a third party to assist with compliance with GLBA. Bethany is in the process of fully documenting its information security program. Bethany has implemented multi-factor authentication (MFA) on some systems that contain personally identifiable information and is working to implement MFA on the remaining systems. Bethany is also working to implement sufficient continuous monitoring, such as penetration testing and vulnerability scanning. Cause: The timing of the contracting by Bethany has not allowed all updated components of GLBA to be addressed and documented during the audit process. Effect: Bethany may have unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany work with the third party and determine timeframes remaining to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: Multi-Factor Authentication: The University’s Compliance Committee, led by the Chief Financial Officer, now requires that Multi Factor Authentication (MFA) is turned on for all MFA capable software systems that house Sensitive Personally Identifiable Information of students. The Committee will implement policies to ensure that all users who access those systems are required to use Multi Factor Authentication. Any legacy systems without MFA will be retired. Information System Monitoring/Testing: In June of 2023, the University entered into a contract with an outside Managed IT Services provider. This third-party vendor provides the following services: • Firewall to protect network perimeter. • Security updates and critical patches. • Alerts to inform about issues on all endpoints. • Defense agents that scan and monitor external devices. • Agents to actively monitor web traffic and block malicious links. • Tools used for internal and external vulnerability scans. • Alerts to monitor for any malicious activity or events of potential compromise. • Other advanced threat protection. The University's Compliance Committee will assess the effectiveness of the existing continuous monitoring procedures and ascertain whether further vulnerability assessments and penetration testing are necessary to meet the stipulated criteria within Title 16, Chapter I, Subchapter C, Part 314 of the Federal Trade Commission regulations. The Compliance Committee will collaborate with additional IT Security Professionals as deemed necessary and ensure that the University is in compliance with the regulations. Person Responsible for Corrective Action Plan: David Entler, Chief Financial Officer Anticipated Date of Completion: January 31, 2024

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FY 2022-06-30

$2,430,444 federal awards expended

FAC accepted this audit on December 22, 2022 — management decision was due June 22, 2023.

2022-002
Special Tests & Provisions
OTHER MATTERS

The anticipated disbursement dates in COD were not updated with the actual dates of disbursement when reporting disbursement records for Pell and Federal Direct Loans (FDL) to COD. Criteria: 34 CFR 668.164(a) Questioned Costs: $-0- Context: 35 of 51 students tested had COD loan disbursement date errors or Pell COD date errors ranging primarily from 5-55 days. The majority of the errors were in the spring 2022 term and were noticed in March 2022. There were no errors in the amounts reported, just the date of disbursement. Cause: The anticipated disbursement dates in COD were not updated to the actual dates that Pell and FDL were disbursed to the students? accounts. This was due to a synch issue between the student information system and COD, and it occurred during staffing storages for the University. Effect: Inaccurate FDL reporting can impact a student?s interest accumulating period based on the dates of the loan disbursement dates. Inaccurate Pell reporting could allow a student to exceed their lifetime limit. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates and that the monthly review be retained to show any unsynched transactions. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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Common Origination and Disbursement (COD) Dates Not Reflecting Actual Disbursement Dates DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: The anticipated disbursement dates in COD were not updated with the actual dates of disbursement when reporting disbursement records for Pell and Federal Direct Loans (FDL) to COD. Criteria: 34 CFR 668.164(a) Questioned Costs: $-0- Context: 35 of 51 students tested had COD loan disbursement date errors or Pell COD date errors ranging primarily from 5-55 days. The majority of the errors were in the spring 2022 term and were noticed in March 2022. There were no errors in the amounts reported, just the date of disbursement. Cause: The anticipated disbursement dates in COD were not updated to the actual dates that Pell and FDL were disbursed to the students? accounts. This was due to a synch issue between the student information system and COD, and it occurred during staffing storages for the University. Effect: Inaccurate FDL reporting can impact a student?s interest accumulating period based on the dates of the loan disbursement dates. Inaccurate Pell reporting could allow a student to exceed their lifetime limit. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates and that the monthly review be retained to show any unsynched transactions. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

2022-002 COD Dates Not Reflecting Actual Disbursement Dates Planned Corrective Action: All 21-22 batch disbursement dates will be checked within COD. Any dates that do not match will be updated to match with the date the funds were disbursed as recorded in Populi. To prevent this in the future when the finance office receives funds and posts them on student accounts in Populi the financial aid office will manually mark each disbursement in Populi to sync and send them to COD. This will cause the disbursements COD status to change to pending in Populi while it processes, when the status changes back to accepted the Populi and COD disbursement data will align. Once updates process with COD each disbursement will again show as accepted a PDF of the disbursement batch will be saved in our files which displays that the awards are synced with COD. We will perform a spot check of the disbursements within each batch by looking up individuals in COD and verifying that the disbursement date updated in the sync from Populi. Person Responsible for Corrective Action Plan: Anna Bergh, Financial Aid Director Anticipated Date of Completion: January 1, 2023

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FY 2021-06-30

LOW-RISK AUDITEE$2,346,026 federal awards expended

FAC accepted this audit on November 7, 2021 — management decision was due May 7, 2022.

2021-001
Eligibility
MATERIAL WEAKNESSQUESTIONED COSTSOTHER MATTERS

Errors in need analysis for federal financial aid let to inaccurate awarding and disbursing need based federal financial aid. Criteria: 34 CFR 675.9, 34 CFR 685.200 (a)z, 34 CFR 690.75 Questioned Costs: $500 Context: Out of 51 students tested, 3 students were over awarded $6,698 in subsidized direct loans, 2 students were under awarded $5,765 subsidized direct loans, 2 students were over awarded $4,763 in Work College funds and 1 student was over awarded $500 in Pell. Loan amounts were correct, just the allocation between subsidized and unsubsidized loans was incorrect. The Work College over awards should have been allocated to institutional funds. Cause: For The third-party administrator (TPA) didn't For some students the TPA didn't use the correct cost of attendance. The TPA also didn't apply the need analysis methodology for the Work College program consistently. Effect: Students not awarded need based federal aid according to eligibility. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend that the University set up reports in the student information system to periodically check for over or under awarding of need based federal aid. We also recommend that the student information system have notifications when update ISIR's are received to review need analysis and update awarding as needed. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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2021-001 Need Analysis Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.007, 84.063, and 84.268 Federal Award Identification #: 20/21 Financial Aid Year Condition: Errors in need analysis for federal financial aid let to inaccurate awarding and disbursing need based federal financial aid. Criteria: 34 CFR 675.9, 34 CFR 685.200 (a)z, 34 CFR 690.75 Questioned Costs: $500 Context: Out of 51 students tested, 3 students were over awarded $6,698 in subsidized direct loans, 2 students were under awarded $5,765 subsidized direct loans, 2 students were over awarded $4,763 in Work College funds and 1 student was over awarded $500 in Pell. Loan amounts were correct, just the allocation between subsidized and unsubsidized loans was incorrect. The Work College over awards should have been allocated to institutional funds. Cause: For The third-party administrator (TPA) didn't For some students the TPA didn't use the correct cost of attendance. The TPA also didn't apply the need analysis methodology for the Work College program consistently. Effect: Students not awarded need based federal aid according to eligibility. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend that the University set up reports in the student information system to periodically check for over or under awarding of need based federal aid. We also recommend that the student information system have notifications when update ISIR's are received to review need analysis and update awarding as needed. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Finding Number: 2021-001 Need Analysis Planned Corrective Action: After the material finding on the Uniform Guidance Audit, Bethany Global University made the decision to fire the current Third-Party Administrator (Campus Ivy) and move all procedures for Financial Aid in-house to avoid future issues. Our TPA didn?t consistently update the EFC of students and didn?t apply the principles of the Work College program consistently, likely due to a lack of understanding of the work college program and their own inexperience in processing transactions on federal funds. Campus Ivy acquired Weber, our previous TPA, and the changes they made had significant administrative impact on us. Now that our existing student information system (Populi) is set up to receive ISIR?s and notifications directly from COD and other federal systems, we are no longer reliant on a TPA to perform the calculations and can leverage our understanding into action. Person Responsible for Corrective Action Plan: Brian Schwarz: Senior Budget Owner of Bethany Global University

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2021-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Verification was not completed on 4 students who received federal aid. Criteria: 34 CFR 668.56 Questioned Costs: $26,602 Context: Out of 90 students selected by the Central Processing System to have their ISIR verified, verification was not completed on 4 students but they were disbursed need based federal financial aid, $17,302 in Pell, $9,000 in subsidized direct loans and $300 in FSEOG. Cause: The TPA?s system has a flag to identify students with ISIRs selected for verification but for some reason, it didn't trigger the request for verification documents on these students so verification wasn't completed as required. There was no review process to ensure that students selected for verification were properly verified before awarding need based federal aid. Effect: Students who don't complete verification are only eligible for unsubsidized loans. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the University ensure that the student information system is set up properly to flag ISIR's selected for verification and notifications when verification documents are received. We also recommend that the University periodically run system reports to ensure that verification has been completed for students with need based aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

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2021-002 Verification Significant Deficiency DEPARTMENT OF EDUCATION CFDA #: 84.007, 84.063, and 84.268 Federal Award Identification #: 20/21 Financial Aid Year Condition: Verification was not completed on 4 students who received federal aid. Criteria: 34 CFR 668.56 Questioned Costs: $26,602 Context: Out of 90 students selected by the Central Processing System to have their ISIR verified, verification was not completed on 4 students but they were disbursed need based federal financial aid, $17,302 in Pell, $9,000 in subsidized direct loans and $300 in FSEOG. Cause: The TPA?s system has a flag to identify students with ISIRs selected for verification but for some reason, it didn't trigger the request for verification documents on these students so verification wasn't completed as required. There was no review process to ensure that students selected for verification were properly verified before awarding need based federal aid. Effect: Students who don't complete verification are only eligible for unsubsidized loans. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the University ensure that the student information system is set up properly to flag ISIR's selected for verification and notifications when verification documents are received. We also recommend that the University periodically run system reports to ensure that verification has been completed for students with need based aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

Finding Number: 2021-002 Verification Planned Corrective Action: In moving to in-house financial aid, we have also set up new systems to track and manage verification. Our Student Information System automatically checks ISIR?s to confirm when students are selected for verification, and we log information in a secure Access database to keep track of where students are in the process of Verification. We walk through the verification worksheet with each student, saving any relevant documents needed for verification, and our new financial aid director Anna Bergh audits the database to ensure we are compliant. Person Responsible for Corrective Action Plan: Anna Bergh: Financial Aid Director Anticipated Date of Completion: 11/1/2021

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FY 2020-06-30

LOW-RISK AUDITEE$2,418,990 federal awards expendedNo findings recorded this year

FAC accepted this audit on November 15, 2020 — management decision was due May 15, 2021.

FY 2019-06-30

LOW-RISK AUDITEE$2,258,277 federal awards expended

FAC accepted this audit on November 19, 2019 — management decision was due May 19, 2020.

2019-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

Certain provisions under the GLBA were not fully implemented by June 30, 2019. Cause: Bethany Fellowship, Inc. (d.b.a. Bethany International) did not meet certain provisions under the GLBA. Questioned Costs: None Effect: Bethany Fellowship, Inc. (d.b.a. Bethany International) did not meet certain provisions under the GLBA. Recommendation: Bethany Fellowship, Inc. (d.b.a. Bethany International) has met certain requirements under the GLBA and should continue to develop, implement and document items required under 16 CFR 314 in order to fully comply with the requirements. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and recommendation. The Information Technology Department of Bethany Fellowship, Inc. (d.b.a. Bethany International) will take the lead in continuing to develop, implement and document the items required under 16 CFR 314 in order to fully comply with the requirement.

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2019-01: Standards for Safeguarding Student Information Student Financial Aid Cluster - CFDA numbers 84.063, 84.007, 84.268, and 84.033 according to 16 CFR 314 Criteria: Certain provisions of the Gramm-Leach-Bliley Act (GLBA) requires Bethany Fellowship, Inc. (d.b.a. Bethany International) to perform a risk assessment that addresses 1) employee training and management; 2) information systems, including network and software design as well as information processing, storage, transmission and disposal; and 3) detecting, preventing and responding to attacks, intrusions, or other system failures. In addition, there are requirements to design and implement information safeguards to control risks that were identified through the risk assessment process and to regularly test or otherwise monitor the effectiveness of the safeguards? key controls, system and procedures. Condition: Certain provisions under the GLBA were not fully implemented by June 30, 2019. Cause: Bethany Fellowship, Inc. (d.b.a. Bethany International) did not meet certain provisions under the GLBA. Questioned Costs: None Effect: Bethany Fellowship, Inc. (d.b.a. Bethany International) did not meet certain provisions under the GLBA. Recommendation: Bethany Fellowship, Inc. (d.b.a. Bethany International) has met certain requirements under the GLBA and should continue to develop, implement and document items required under 16 CFR 314 in order to fully comply with the requirements. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and recommendation. The Information Technology Department of Bethany Fellowship, Inc. (d.b.a. Bethany International) will take the lead in continuing to develop, implement and document the items required under 16 CFR 314 in order to fully comply with the requirement.

Corrective Action Plan

CORRECTIVE ACTION PLAN November 26, 2019 Department of Education Bethany Fellowship, Inc. (d.b.a. Bethany International and d.b.a Bethany Global University) respectfully submits the following corrective action plan for the year ended June 30, 2019. Bethany Global University is the higher education division of Bethany Fellowship, Inc. Name and address of independent public accounting firm: Boulay PLLP 750 Flying Cloud Drive, Suite 800 Minneapolis, MN 55344 Audit period: July 1, 2018 ? June 30, 2019 The finding from the June 30, 2019 schedule of finding and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS AND QUESTIONED COSTS ? MAJOR FEDERAL AWARD PROGRAM AUDIT 2019-01: Standards for Safeguarding Student Information Student Financial Aid Cluster - CFDA numbers 84.063, 84.007, 84.268, and 84.033 according to 16 CFR 314 Recommendation: Bethany Fellowship, Inc. (d.b.a. Bethany International) has met certain requirements under the GLBA and should continue to develop, implement and document items required under 16 CFR 314 in order to fully comply with the requirements. Planned Action: Management concurs with the finding and recommendation. The Information Technology Department of Bethany Fellowship, Inc. will take the lead in continuing to develop, implement and document the items required under 16CFR 314 in order to fully comply with the requirement. If the Department of Education has questions regarding these resolutions of prior year findings, please call David Entler at 952-946-4193. Sincerely yours, Daniel H. Brokke President Bethany Fellowship, Inc. d.b.a Bethany International d.b.a. Bethany Global University

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FY 2018-06-30

LOW-RISK AUDITEE$2,000,175 federal awards expended

FAC accepted this audit on December 18, 2018 — management decision was due June 18, 2019.

2018-001
Reporting
OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2018-002
Reporting
OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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FY 2017-06-30

$1,635,160 federal awards expended

FAC accepted this audit on March 18, 2018 — management decision was due September 18, 2018.

2017-001
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2016-001

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

Prior Finding References

2016-001

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FY 2016-06-30

$775,037 federal awards expended

FAC accepted this audit on March 30, 2017 — management decision was due September 30, 2017.

2016-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2016-002
Eligibility
QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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