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Northwestern CollegeHigher Education

EIN: 420698196

UEI: YMK7VK3FKX47

Audited by: CliftonLarsonAllen LLP

Oversight agency: 84 [Department of Education]

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Data as of August 31, 2026

Northwestern College10 audit years6 findings2 repeat
10
Audit Years
6
Total Findings
2
Repeat Findings
$11.9M
Federal Awards Expended (FY 2025)

FY 2025-06-30

LOW-RISK AUDITEE$11,888,694 federal awards expended

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 (23 days ago).

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2025-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2024-001OTHER MATTERS

During our testing, we noted one out of the 40 students change in status was not reported to NSLDS within 60 days. Questioned costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure changes in status reported to NSLDS timely. Cause: The College’s processes and controls 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 overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat finding: Yes – 2024-001 Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Views of responsible officials: There is no disagreement with the audit finding.

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Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster – Various Assistance Listing Numbers: Various Federal Award Identification Number and Year: Various Pass-Through Agency: N/A Pass-Through Number: N/A Award Period: July 1, 2024, through June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date as well as program enrollment effective date. Changes to a students' status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: During our testing, we noted one out of the 40 students change in status was not reported to NSLDS within 60 days. Questioned costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure changes in status reported to NSLDS timely. Cause: The College’s processes and controls 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 overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat finding: Yes – 2024-001 Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College re-evaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Early in the 2024-25 fiscal year, the College learned that this finding related to manually reported graduates and withdrawn students. Graduates reported during the automated file submittal process were reported as graduating at end of term, while graduates reported manually were reported as graduating on the College’s actual commencement date (one day different than end of term). The Registrar is now consistent in reporting graduation dates using the end of term for all graduating students. As for the reporting of withdrawals, the Registrar now manually updates the enrollment status and effective dates in NSLDS to ensure accurate and timely reporting. The findings in this audit period occurred prior to the above changes being implemented. Name(s) of the contact person(s) responsible for corrective action: Austin Nyhof, Registrar Planned completion date for corrective action plan: June 30, 2026

Prior Finding References

2024-001

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FY 2024-06-30

LOW-RISK AUDITEE$11,750,077 federal awards expended

FAC accepted this audit on October 23, 2024 — management decision was due April 23, 2025.

2024-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2023-001OTHER MATTERS

During our testing, we noted 14 out of the 40 students’ enrollment effective date reported to NSLDS did not match the College's records. Furthermore, we noted 1 out of the 40 students’ program enrollment effective date reported to NSLDS did not match the College's records. Questioned costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure effectives dates are accurately reported to NSLDS. Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By reporting an incorrect effective date, the grace period begin date for the student will be incorrect. Repeat finding: Yes – 2023-001 Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Views of responsible officials: There is no disagreement with the audit finding.

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Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster – Various Assistance Listing Numbers: Various Federal Award Identification Number and Year: Various Pass-Through Agency: N/A Pass-Through Number: N/A Award Period: July 1, 2023, through June 30, 2024 Type of Finding: 􀁸 Significant Deficiency in Internal Control Over Compliance 􀁸 Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date as well as program enrollment effective date. Changes to a students' status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: During our testing, we noted 14 out of the 40 students’ enrollment effective date reported to NSLDS did not match the College's records. Furthermore, we noted 1 out of the 40 students’ program enrollment effective date reported to NSLDS did not match the College's records. Questioned costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure effectives dates are accurately reported to NSLDS. Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By reporting an incorrect effective date, the grace period begin date for the student will be incorrect. Repeat finding: Yes – 2023-001 Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The 2022-23 audit identified similar issues regarding NSLDS enrollment reporting. Following the 2022-23 audit, the College changed the submission dates to the NSC to allow more time for the NSC to timely report to the NSLDS. Upon further research following the 2023-24 audit, the College learned that this finding relates to manually reported graduates and withdrawn students. Graduates reported during the automated file submittal process were reported as graduating at end of term, while graduates reported manually were reported as graduating on the College’s actual commencement date (one day different than end of term). Going forward the Registrar will be consistent in reporting graduation dates using the end of term for all graduating students. As for the reporting of withdrawals, the Registrar will manually update the enrollment status and effective dates in NSLDS to ensure accurate and timely reporting in the 2024-25 fiscal year. Starting in 2025-26 the College is transitioning to a new ERP, a more robust software system, that will correct this issue. Name(s) of the contact person(s) responsible for corrective action: Austin Nyhof, Registrar Planned completion date for corrective action plan: June 30, 2025

Prior Finding References

2023-001

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2024-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

During our testing, we noted 2 of the 40 students tested had disbursement dates per COD that did not match their student account. Questioned costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that the disbursement date per the College's record must match the disbursement date in COD. 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 Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of responsible officials: There is no disagreement with the audit finding.

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Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster – Various Assistance Listing Numbers: Various Federal Award Identification Number and Year: Various Pass-Through Agency: N/A Pass-Through Number: N/A Award Period: July 1, 2023, through June 30, 2024 Type of Finding: 􀁸 Significant Deficiency in Internal Control Over Compliance 􀁸 Other Matters Criteria or specific requirement: The Department of Education requires the College 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 2 of the 40 students tested had disbursement dates per COD that did not match their student account. Questioned costs: None Context: During our testing, it was noted the College did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The College did not follow the procedure to meet the requirement that the disbursement date per the College's record must match the disbursement date in COD. 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 Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Recommendation: We recommend the College 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: Starting in 2025-26 the College is transitioning to a new ERP, a more robust software system, that will correct this issue. However, in the meantime, the financial aid office will not rely on our current software to automatically match COD Disbursement dates with student account posting dates. The financial aid and business offices will communicate to ensure posting to student accounts are done on the same day as aid is disbursed. In addition, the financial aid and business offices will add a new process to compare COD reports with current software reports on a regular basis to look for any discrepancies. Any discrepancies found will be manually corrected on a timely basis. Name(s) of the contact person(s) responsible for corrective action: Eric Anderson, Director of Financial Aid Planned completion date for corrective action plan: June 30, 2025

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FY 2023-06-30

LOW-RISK AUDITEE$11,853,219 federal awards expended

FAC accepted this audit on December 5, 2023 — management decision was due June 5, 2024.

2023-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

We noted, during our testing, that five out of 40 students tested whose enrollment status was not updated to graduate to NSLDS. Six out of 40 students tested enrollment status was reported timely. We also noted that 30 of the 40 students tested did not have effective dates in NLSDS compared to the institutions’ records. Lastly, for three of the 40 students tested, the program effective date did not agree in NSLDS to the institutions’ records. Questioned Costs: None Cause: The College’s processes and controls 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 overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College 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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2023-001 Enrollment Reporting Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 to June 30, 2023 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: We noted, during our testing, that five out of 40 students tested whose enrollment status was not updated to graduate to NSLDS. Six out of 40 students tested enrollment status was reported timely. We also noted that 30 of the 40 students tested did not have effective dates in NLSDS compared to the institutions’ records. Lastly, for three of the 40 students tested, the program effective date did not agree in NSLDS to the institutions’ records. Questioned Costs: None Cause: The College’s processes and controls 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 overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College 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

2023-001 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to National Student Loan Data System (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: After being alerted to the finding, the Registrar changed the submission dates to the National Student Clearinghouse (NSC) to allow more time for the NSC to timely report to the NSLDS. The Registrar’s Office will notify the Business Office when files have been submitted to the NSC. The Business Office will periodically monitor the NSLDS system and alert the Registrar of their observations. Name(s) of the contact person(s) responsible for corrective action: Austin Nyhof, Registrar Planned completion date for corrective action plan: June 30, 2024

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2023-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted that the College did not prepare a formal risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks. Cause: The College has hired a consultant to help with and enhance the implementation of the updated Gramm-Leach-Bliley Act requirements and that didn’t occur until late in the 2023 fiscal year. Effect: The student personal information could potentially be vulnerable. Repeat Finding: No Recommendation: We recommend the College work with their consulting firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are implemented. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

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2023-002 Gramm-Leach-Bliley Act Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted that the College did not prepare a formal risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks. Cause: The College has hired a consultant to help with and enhance the implementation of the updated Gramm-Leach-Bliley Act requirements and that didn’t occur until late in the 2023 fiscal year. Effect: The student personal information could potentially be vulnerable. Repeat Finding: No Recommendation: We recommend the College work with their consulting firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are implemented. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: 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 College work with their consulting firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are implemented. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act (GLBA) regulations that were required to be implemented as of June 9, 2023. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College engaged a consulting firm as our Virtual Chief Information Security Officer (vCISO) in 2022-23 to assist in compliance with the GLBA. The College’s work with our vCISO includes a comprehensive risk assessment of the College’s information security posture, a determination of identified risks, access to expert security resources to build an effective and measurable security program, and an evaluation of the controls protecting the external network. These action items began in the 2022-23 fiscal year and are ongoing in the 2023-24 fiscal year. The vCISO program includes virtual multi-year ongoing support. Name(s) of the contact person(s) responsible for corrective action: Harlan Jorgensen, Director of Computing Services Planned completion date for corrective action plan: June 30, 2024

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FY 2022-06-30

LOW-RISK AUDITEE$12,812,567 federal awards expendedNo findings recorded this year

FAC accepted this audit on November 17, 2022 — management decision was due May 17, 2023.

FY 2021-06-30

LOW-RISK AUDITEE$11,653,267 federal awards expendedNo findings recorded this year

FAC accepted this audit on January 4, 2022 — management decision was due July 4, 2022.

FY 2020-06-30

LOW-RISK AUDITEE$10,369,017 federal awards expendedNo findings recorded this year

FAC accepted this audit on January 7, 2021 — management decision was due July 7, 2021.

FY 2019-06-30

LOW-RISK AUDITEE$9,143,511 federal awards expendedNo findings recorded this year

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

FY 2018-06-30

LOW-RISK AUDITEE$9,283,716 federal awards expendedNo findings recorded this year

FAC accepted this audit on December 26, 2018 — management decision was due June 26, 2019.

FY 2017-06-30

LOW-RISK AUDITEE$9,749,818 federal awards expendedNo findings recorded this year

FAC accepted this audit on December 20, 2017 — management decision was due June 20, 2018.

FY 2016-06-30

$9,842,238 federal awards expended

FAC accepted this audit on December 14, 2016 — management decision was due June 14, 2017.

2016-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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