EIN: 430746185
UEI: NQV6E96EEDD5
Audited by: RubinBrown LLP
Cognizant agency: 84 [Department of Education]
View federal awards & risk assessment →
Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 13, 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 September 13, 2026 (15 days from today).
What is a management decision? →FAC accepted this audit on March 18, 2025 — management decision was due September 18, 2025.
The University did not return Title IV funds within the 45-day time period for 1 student tested in our sample population. Cause: Controls over compliance put in place by management were not operating effectively as it relates to return of Title IV funds. Effect: The University’s controls did not prevent the errors noted during the return of Title IV funds. Questioned Costs: $1,559 of known questioned costs were identified in our testing sample. Likely questioned costs did not exceed $25,000. Context: The University provided a listing of all students that withdrew during the academic period, which totaled 68 students. In a statistically valid sample of 7 students that withdrew, the University did not return Title IV funds during the required time period for 1 student tested. Identification As A Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: During the 2023-2024 academic year, Financial Aid employees attended a training over return of Title IV funds, in which they became aware that students who received all incomplete ‘I’ grades for a term had 30 days following that term to complete the courses. If those courses remained incomplete at the end of the 30 days, they should be treated the same as students with all F grades. At that time, financial aid must determine if they are required to complete a return of funds for that student. After the training, funds were returned to Title IV for students who received all ‘I’ grades for the fall 2023 trimester. Total questioned costs related to this amounted to $1,559. The University remains aware of the rules surrounding return of funds for students with all ‘I’ grades and will continue to attend Student Financial Aid trainings.
Show full finding ▾Hide full finding ▴Finding 2024-001 – Significant Deficiency: Special Tests And Provisions – Return Of Title IV Funds – Compliance and Control Finding ALN 84.268 – Federal Direct Student Loan Program – Student Financial Aid Cluster Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible under 34 CFR 668.22(g) as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew as defined in 34 CFR 668.22(l)(3). Condition: The University did not return Title IV funds within the 45-day time period for 1 student tested in our sample population. Cause: Controls over compliance put in place by management were not operating effectively as it relates to return of Title IV funds. Effect: The University’s controls did not prevent the errors noted during the return of Title IV funds. Questioned Costs: $1,559 of known questioned costs were identified in our testing sample. Likely questioned costs did not exceed $25,000. Context: The University provided a listing of all students that withdrew during the academic period, which totaled 68 students. In a statistically valid sample of 7 students that withdrew, the University did not return Title IV funds during the required time period for 1 student tested. Identification As A Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: During the 2023-2024 academic year, Financial Aid employees attended a training over return of Title IV funds, in which they became aware that students who received all incomplete ‘I’ grades for a term had 30 days following that term to complete the courses. If those courses remained incomplete at the end of the 30 days, they should be treated the same as students with all F grades. At that time, financial aid must determine if they are required to complete a return of funds for that student. After the training, funds were returned to Title IV for students who received all ‘I’ grades for the fall 2023 trimester. Total questioned costs related to this amounted to $1,559. The University remains aware of the rules surrounding return of funds for students with all ‘I’ grades and will continue to attend Student Financial Aid trainings.
Finding 2024-001 Personnel Responsible for Corrective Action: Director of Financial Aid, Kerry Hallahan Anticipated Completion Date: May 2024 Corrective Action Plan: The funds for the affected student have been retur
FAC accepted this audit on February 26, 2024 — management decision was due August 26, 2024.
The University did not exclude a scheduled break of at least five consecutive days in the Fall 2022 trimester from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period when calculation the amount of Title IV aid earned by students at the time of the withdrawal date. Cause: Controls over compliance put in place by management were not operating effectively as it relates to return of Title IV funds. Effect: The University’s controls did not prevent the errors noting during the return of Title IV funds. Questioned Costs: $435 of known questioned costs were identified in our testing sample. Likely questioned costs did not exceed $25,000. SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) For The Year Ended August 31, 2023 Context: Based on a sample of 9 students, the University did not exclude a scheduled break of five consecutive days for 5 students tested for the Fall 2022 trimester. The five consecutive days were not excluded from the period of enrollment and the number of calendar days completed in that period when calculating the amount of Title IV aid earned by the student for the trimester. Identification As A Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The 2022-2023 academic year was revised to include a 5 day break for the Thanksgiving holiday. This revision occurred after the calendar has been uploaded to the system and therefore the return of Title IV calculations for Fall 2022 were calculated using the incorrect number of days. Total questioned costs related to this amounted to $2,101. The calendar for 2023 - 2024 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations.
Show full finding ▾Hide full finding ▴Finding 2023-001 – Significant Deficiency: Special Tests And Provisions – Return Of Title IV Funds – Compliance and Control Finding ALN 84.063 – Federal Pell Grant Program and 84.268 – Federal Direct Student Loan Program – Student Financial Aid Cluster and 84.007 – Federal Supplemental Educational Opportunity Grant Program Federal Agency: Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: Per 34 CFR 668.22(f)(2)(i) and (ii)(B), the total number of calendar days in a period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period. Condition: The University did not exclude a scheduled break of at least five consecutive days in the Fall 2022 trimester from the total number of calendar days in a period of enrollment and the number of calendar days completed in that period when calculation the amount of Title IV aid earned by students at the time of the withdrawal date. Cause: Controls over compliance put in place by management were not operating effectively as it relates to return of Title IV funds. Effect: The University’s controls did not prevent the errors noting during the return of Title IV funds. Questioned Costs: $435 of known questioned costs were identified in our testing sample. Likely questioned costs did not exceed $25,000. SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) For The Year Ended August 31, 2023 Context: Based on a sample of 9 students, the University did not exclude a scheduled break of five consecutive days for 5 students tested for the Fall 2022 trimester. The five consecutive days were not excluded from the period of enrollment and the number of calendar days completed in that period when calculating the amount of Title IV aid earned by the student for the trimester. Identification As A Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend that management review its processes and controls surrounding this compliance requirement to ensure that the control is appropriate and operating effectively to support that the University is in compliance with the requirements of its federal program. Views Of Responsible Officials: The 2022-2023 academic year was revised to include a 5 day break for the Thanksgiving holiday. This revision occurred after the calendar has been uploaded to the system and therefore the return of Title IV calculations for Fall 2022 were calculated using the incorrect number of days. Total questioned costs related to this amounted to $2,101. The calendar for 2023 - 2024 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations.
Personnel Responsible for Corrective Action: Director of Financial Aid, Kerry Hallahan Anticipated Completion Date: October 2023 Corrective Action Plan: The calendar for 2023 - 2024 academic year has been updated to ensure the correct number of days are used for return of Title IV calculations. At the start of each trimester, the calendar will be reviewed to verify any break of 5 days or more are accounted for within the R2T4 calculation setup.
FAC accepted this audit on February 2, 2023 — management decision was due August 2, 2023.
FAC accepted this audit on July 31, 2022 — management decision was due January 31, 2023.
The University utilized the National Student Loan Clearinghouse (NSC) as a service provider to upload information on behalf of the University to NSLDS. In our sample of 40 students, it was noted for 15 individuals that information was not properly updated in NSLDS within the allotted timeframe. Cause: The University adjusted its controls and processes related to enrollment reporting during the current year, which resulted in delays in timely uploading to NSLDS. Effect: In our sample of 40 students, it was noted for 15 individuals that information was not properly updated in NSLDS within 60 days, which resulted in noncompliance with federal requirements as described above. Questioned Costs: None noted. All information for the impacted student was eventually uploaded in NSLDS by the University. Identification As A Repeat Finding: The finding is not a repeat finding. Recommendation: The University should review and consider revisions to its processes and related controls in place to ensure the timely receipt, processing, and tracking of data submitted to NSLDS by National Student Clearinghouse. Views of Responsible Officials: The University agrees with this finding and has implemented an internal control procedure to ensure compliance in the future.
Show full finding ▾Hide full finding ▴Criteria: According to the November 2020 NSLDS Enrollment Reporting Guide, ?As with any school/servicer arrangement for the administration of Title IV programs, if the school uses an Enrollment Reporting Servicer, the school still has the primary responsibility for submitting timely, accurate, and complete responses to Enrollment Reporting roster files, and for reporting any changes in student enrollment status in a timely manner? (page 12). Condition: The University utilized the National Student Loan Clearinghouse (NSC) as a service provider to upload information on behalf of the University to NSLDS. In our sample of 40 students, it was noted for 15 individuals that information was not properly updated in NSLDS within the allotted timeframe. Cause: The University adjusted its controls and processes related to enrollment reporting during the current year, which resulted in delays in timely uploading to NSLDS. Effect: In our sample of 40 students, it was noted for 15 individuals that information was not properly updated in NSLDS within 60 days, which resulted in noncompliance with federal requirements as described above. Questioned Costs: None noted. All information for the impacted student was eventually uploaded in NSLDS by the University. Identification As A Repeat Finding: The finding is not a repeat finding. Recommendation: The University should review and consider revisions to its processes and related controls in place to ensure the timely receipt, processing, and tracking of data submitted to NSLDS by National Student Clearinghouse. Views of Responsible Officials: The University agrees with this finding and has implemented an internal control procedure to ensure compliance in the future.
Personnel Responsible for Corrective Action: Registrar Team and Associate Director of Federal Enrollment Reporting & Title IV Compliance. Anticipated Completion Date: January 2022. The University agrees with the finding. This late reporting of graduated students happened during a transition of reporting duties from the Registrar to the newly created Associate Director of Federal Enrollment Reporting & Title IV Compliance position. This position reports to both the University Registrar & Associate Provost of Academic Administration (50%) as well as the Director of Financial Aid (50%) and was established to focus on the enrollment reporting. At the end of the term, the Registrar team ensures that every graduated student?s status is marked as graduated. The Associate Director of Federal Enrollment Reporting & Title IV Compliance worked with IT and the National Student Clearinghouse to improve the enrollment status report that is sent to National Student Clearinghouse on a monthly basis, as well as the graduated report in order to reduce errors and allow for more timely reporting. As a cross check, the Associate Director of Federal Enrollment Reporting & Title IV Compliance reviews the SCHEP4 report from NSLDS on a monthly basis and compares to the University?s internal records.
FAC accepted this audit on November 29, 2021 — management decision was due May 29, 2022.
FAC accepted this audit on January 20, 2020 — management decision was due July 20, 2020.
The University utilized the National Student Loan Clearinghouse (NSC) as a service provider to upload information on behalf of the University to NSLDS. In our sample of 40 students, it was noted for 1 individual that information was not properly updated in NSLDS within the allotted timeframe. Cause: The University relies on a third-party service provider to submit data in NSLDS, and it does not have a properly functioning control mechanism in place to ensure that data is uploaded timely to NSLDS in the event that it is not completed by the selected service provider and the office of the University Registrar. Effect: In our sample of 40 students, it was noted for 1 individual that information was not properly updated in NSLDS within 60 days, which resulted in noncompliance with federal requirements as described above. Questioned Costs: None noted. All information for the impacted student was eventually uploaded in NSLDS by the University. Identification As A Repeat Finding: The finding is a repeat finding. Recommendation: The University should review and consider revisions to its processes and related controls in place to ensure the timely receipt, processing, and tracking of data submitted to NSLDS by NSC. Views of The University agrees with this finding and has implemented an internal Responsible control procedure to ensure compliance in the future. Officials:
Show full finding ▾Hide full finding ▴Federal Program: Student Financial Aid Cluster Award ID No: - - CFDA 84.007, 84.033, 84.063, 84.268, 84.038 Federal Agency: U.S. Department of Education Criteria: According to the October 2015 NSLDS Enrollment Reporting Guide, ?As with any school/servicer arrangement for the administration of Title IV programs, if the school uses an Enrollment Reporting Servicer, the school still has the primary responsibility for submitting timely, accurate, and complete responses to Enrollment Reporting roster files, and for reporting any changes in student enrollment status in a timely manner? (page 9). ?The school is ultimately responsible for timely and accurate reporting, even when it uses an Enrollment Reporting Servicer to submit the Enrollment Reporting files. Therefore, Late Enrollment Reporting email notifications are sent to the school and not to the servicer.? Condition: The University utilized the National Student Loan Clearinghouse (NSC) as a service provider to upload information on behalf of the University to NSLDS. In our sample of 40 students, it was noted for 1 individual that information was not properly updated in NSLDS within the allotted timeframe. Cause: The University relies on a third-party service provider to submit data in NSLDS, and it does not have a properly functioning control mechanism in place to ensure that data is uploaded timely to NSLDS in the event that it is not completed by the selected service provider and the office of the University Registrar. Effect: In our sample of 40 students, it was noted for 1 individual that information was not properly updated in NSLDS within 60 days, which resulted in noncompliance with federal requirements as described above. Questioned Costs: None noted. All information for the impacted student was eventually uploaded in NSLDS by the University. Identification As A Repeat Finding: The finding is a repeat finding. Recommendation: The University should review and consider revisions to its processes and related controls in place to ensure the timely receipt, processing, and tracking of data submitted to NSLDS by NSC. Views of The University agrees with this finding and has implemented an internal Responsible control procedure to ensure compliance in the future. Officials:
Finding 2019--001 Personnel Responsible for Corrective Action: Registrar and Director of Financial Aid Anticipated Completion Date: January 2020 Corrective Action Plan: The University agrees with the finding. At the end of the term, the Registrar will check in the National Student Clearinghouse (NSC) that every graduated student?s status is marked as graduated. As a cross check, the Director of Financial Aid will run the SCHEP4 (graduated/withdrawn) report from NSLDS and compare to the Registrar?s internal records. The IT department has completely rebuilt the enrollment reports to be sent to NSC. Scheduled enrollment reports are processed and sent to NSC four times each semester. A separate graduation file is sent at the end of each semester. The Registrar?s Office will submit enrollment reports at least 4 days prior to the appropriate NSC enrollment schedule. The Registrar has now cross-trained two additional staff for enrollment reporting, therefore reports should be sent in a timely manner. The Registrar?s Office and Financial Aid Office will continue to work in close cooperation to solve any enrollment reporting issues.
2018-001
In our sample of 13 students, 1 instance was noted in which the refund was not returned within the 45 day timeframe. Cause: The University?s internal controls failed to ensure that a return was required to be remitted to the Department of Education within the required timeframe. Effect: In our sample of 13 students, 1 instance was noted in which the refund was not returned within 45 days, which resulted in noncompliance with federal requirements as described above. Questioned Costs: $8,637 Identification As A Repeat Finding: Not applicable Recommendation: The University should review its processes and related controls in place to ensure refunds are remitted within the appropriate timeframe. Views of The University agrees with this finding and has implemented an Responsible internal control procedure to ensure compliance in the future. Officials:
Show full finding ▾Hide full finding ▴Federal Program: Student Financial Aid Cluster Award ID No: - - CFDA 84.007, 84.033, 84.063, 84.268, 84.038 Federal Agency: U.S. Department of Education Criteria: If a student receives Title IV grant or loan funds and withdraws from the school after beginning attendance, the amount of Title IV grant or loan assistance earned by the student must be determined. The refund amount determined must be disbursed to the Department of Education no later than 45 days after the date of the University?s determination that the student withdrew. Condition: In our sample of 13 students, 1 instance was noted in which the refund was not returned within the 45 day timeframe. Cause: The University?s internal controls failed to ensure that a return was required to be remitted to the Department of Education within the required timeframe. Effect: In our sample of 13 students, 1 instance was noted in which the refund was not returned within 45 days, which resulted in noncompliance with federal requirements as described above. Questioned Costs: $8,637 Identification As A Repeat Finding: Not applicable Recommendation: The University should review its processes and related controls in place to ensure refunds are remitted within the appropriate timeframe. Views of The University agrees with this finding and has implemented an Responsible internal control procedure to ensure compliance in the future. Officials:
Finding 2019--002 Personnel Responsible for Corrective Action: Director of Financial Aid Anticipated Completion Date: December 2019 Corrective Action Plan: The University agrees with the finding. The University has implemented an internal control procedure to review enrollment status change reports on a bi-weekly basis in the Fall of 2019, complete with a cross-reference check between the enrollment status report and all applicable Return of Title IV funds calculations. This control procedure is completed by the Office of Financial Aid and reviewed by the Director.
FAC accepted this audit on January 6, 2019 — management decision was due July 6, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2017-001
FAC accepted this audit on December 11, 2017 — management decision was due June 11, 2018.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
FAC accepted this audit on December 1, 2016 — management decision was due June 1, 2017.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
Track your findings and corrective action plans across audit cycles.
Start tracking findings →Monitor subrecipient audit findings and filing records.
Start monitoring →© 2026 Single Audit Intelligence. All data is public domain.
