EIN: 480543734
UEI: MCHHM98PRN95
Data as of August 20, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 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 August 13, 2026, which was (7 days ago).
What is a management decision? →Finding 2025-001 - Significant Deficiency, Compliance Federal Award No. 84.007 U.S. Department Of Education Student Financial Aid Cluster – Cash Management Criteria: The U.S. Department of Education (ED) may place institutions on a Heightened Cash Monitoring (HCM) payment method to provide additional oversight of cash management. The College was placed on Heightened Cash Monitoring 1 (HCM1) as a requirement of its provisional approval of its program participation agreement. HCM1 requires that the College makes disbursements to eligible students from institutional funds and submits disbursement records to the Common Origination and Disbursement (COD) System before drawing down funds to cover those disbursements from G5. The College must also pay any credit balance due under 34 CFR 668.14(h), before it submits a request for funds. Condition: In our nonstatistical sample of 2 cash drawdowns, we noted 1 cash drawdown completed in Fall 2024 where the Federal Supplemental Education Opportunity Grants (FSEOG) funds were drawn down for which disbursements to students were not made prior to the drawdown of the funds for the full amount of funds drawn down. We noted no instances of noncompliance for the Spring 2025 drawdown tested. Context: The College completed a drawdown of its full FSEOG award for the year ended June 30, 2025, on October 9, 2024, in the amount of $123,980. The College had disbursed the total of $62,500 in FSEOG awards to students in September 2024; however, the remaining FSEOG disbursements did not occur until the Spring 2025 semester in January 2025. Our drawdown sample selections consisted of all Title IV funds drawn down on a specific date. In our testing of the remaining funds drawn down on October 9, 2024, for Direct Loans, Pell, and TEACH grant funds which totaled $2,720,354 we noted that the amounts drawn down on that date did not exceed the disbursements to students that occurred prior to October 9, 2024. Effect: The College is not meeting the requirements of heightened cash monitoring regulations and cash drawdown regulations. Questioned Costs: None noted. Cause: Bethany College did not have proper processes and related controls in place to ensure that heightened cash monitoring requirements were being met in the Fall 2024 semester for all Title IV funding sources. Indication Of Repeat Finding: This is a repeat finding of 2024-001. Recommendation: The Financial Aid department and business office should put in place controls that would ensure that heightened cash monitoring requirements are met and that student refunds that are generated by federal awards are paid prior to drawing down funds for all Title IV funding sources. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has adjusted its processes and controls beginning with the Fall 2025 semester to ensure that all Title IV funding sources including FSEOG are drawn down in accordance with the Heightened Cash Monitoring requirements. Completion Date: August 2025 Contact Person: Laura Crawley, President
Corrective Action Plan 2025-001: The College concurs with the finding and has adjusted its processes and controls beginning with the Fall 2025 semester to ensure that all Title IV funding sources including FSEOG are drawn down in accordance with the Heightened Cash Monitoring requirements. Completion Date: August 2025 Contact Person: Laura Crawley
2024-001
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 4, 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 4, 2025, which was (350 days ago).
What is a management decision? →Finding 2024-001 - Significant Deficiency, Compliance Federal Award No. 84.063, 84.268 U.S. Department Of Education Student Financial Aid Cluster – Cash Management Criteria: The U.S. Department of Education (ED) may place institutions on a Heightened Cash Monitoring (HCM) payment method to provide additional oversight of cash management. The College was placed on Heightened Cash Monitoring 1 (HCM1) as a requirement of its provisional approval of its program participation agreement. HCM1 requires that the College makes disbursements to eligible students from institutional funds and submits disbursement records to the Common Origination and Disbursement (COD) System before drawing down funds to cover those disbursements from G5. The College must also pay any credit balance due under 34 CFR 668.14(h), before it submits a request for funds. Condition: In our nonstatistical sample of 3 cash drawdowns, we noted 2 cash drawdowns completed in Fall 2023 for which refunds were not paid students from institutional funds prior to the funds being drawn down from G5 as required by the Heightened Cash Monitoring 1 requirements. We noted no instances of noncompliance for the Spring 2024 drawdown tested. Context: For the drawdown of Pell grant funds requested on September 15, 2023 and deposited on September 18, 2023 the College did not pay student refunds until September 19, 2023. The disbursement to the student accounts occurred on September 13, 2023, therefore funds were appropriately requested to cover fall awards; however, for any student for which the federal aid awards exceed the institutional charges, the College is required to pay the student refund prior to completing the drawdown for those students. For the drawdown of Direct Loan funds requested on September 29, 2023 and deposited on October 2, 2023 the College did not pay student refunds until October 4, 2023. The disbursements to the student accounts occurred on September 27, 2023 and September 28, 2023, therefore these funds were appropriately requested to cover fall awards; however, for any student for which the federal aid awards exceed the institutional charges, the College is required to pay the student refund prior to completing the drawdown for those students. Effect: The College is not meeting the requirements of heightened cash monitoring regulations. Questioned Costs: None noted. Cause: Bethany College did not have proper processes and related controls in place to ensure that heightened cash monitoring requirements were being met in the Fall 2023 semester. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: The Financial Aid department and business office should put in place controls that would ensure that heightened cash monitoring requirements are met and that student refunds that are generated by federal awards are paid prior to drawing down funds. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has adjusted its processes and controls beginning with the Spring 2024 semester to conduct a review of students for which refund payments need to be made prior to drawing down funds from G5. Completion Date: February 2024 Contact Person: Steven W. Eckman, President
Corrective Action Plan 2024-001: The College concurs with the finding and has adjusted its processes and controls beginning with the Spring 2024 semester to conduct a review of students for which refund payments need to be made prior to drawing down funds from G5. Anticipated Completion Date: February 2024 Contact Person: Steven W. Eckman, President
Finding 2024-002 - Significant Deficiency, Compliance Federal Award No. 84.268, 84.007, 84.379, 84.063, 84.033, 84.038 U.S. Department Of Education Student Financial Aid Cluster - Special Tests And Provisions Criteria: The Federal Trade Commission (FTC) issued the FTC Safeguards Rule on December 9, 2021 and gave notice to entities that are required to follow the Gramm-Leach-Bliley Act (GLBA) that each entity would be required to be in compliance with the revised requirements no later than June 9, 2023. The FTC Safeguards Rule expanded the requirements for the written information security program required to be established by the College. The requirements for the written information security program noted at 16 CFR 314.4 require that the College designate a Qualified Individual responsible for overseeing and implementing the College’s information security program, be based on a risk assessment that identifies reasonably foreseeable internal and external risks and establishes safeguards to address those risks, and requires that the following 8 safeguards be documented: • Implement and periodically review access controls • Conduct a periodic inventory of data, noting where it is collected, stored, or transmitted • Encrypt customer information on the institution’s system and when it’s in transit. • Assess apps developed by the institution • Implement multi-factor authentication for anyone accessing customer information on the institution’s system • Dispose of customer information securely • Anticipate and evaluate changes to the information system or network • Maintain a log of authorized users’ activity and keep an eye out for unauthorized access In addition, the College is responsible for regularly testing and monitoring the effectiveness of the safeguards it has implemented and establishing how it will complete the monitoring and testing in the written Information Security Program. The College is also responsible for documenting in the written Information Security Program how it will oversee its information system service providers and shall also provide for the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring; the results of the required risk assessments; any material changes to the College’s operations or business arrangements; or any other circumstances that it knows or has reason to know may have a material impact on the College’s information security program. Condition: The College took steps toward meeting the requirements of the FTC Safeguards Rule, including conducting an evaluation of its current compliance and implementing many of the new requirements, but the College failed to update its written Information Security Program to incorporate all of the changes required by the FTC Safeguards Rule by June 30, 2024. Context: The College took steps to implement the requirements and established draft policies and procedures to meet the requirements of the FTC Safeguards Rule; however, the College did not formalize the policies and procedures or update its written Information Security Program. Effect: The failure to meet the requirements of the FTC Safeguards Rule including establishing formal documentation of the written Information Security Program could make the College vulnerable to cyber security and student data protection risks. Questioned Costs: None noted. Cause: Given the size of the College’s IT department, the College focused on implementing as many of the safeguards as possible first to meet the FTC Safeguards Rule and did not prioritize a formal update of its written Information Security Program to meet the requirements of the FTC Safeguards Rule. Indication Of Repeat Finding: This is a repeat finding of 2023-005. Recommendation: The College should immediately formalize its written Information Security Program to meet the FTC Safeguards Rule. Views Of Responsible Officials (Unaudited): The College concurs with the finding and will formalize its written Information Security Program. Completion Date: Spring 2025 Contact Person: Joshua Bieber, Director of Information Technology
Corrective Action Plan 2024-002: The College concurs with the finding and will formalize its written Information Security Program. Anticipated Completion Date: Spring 2025 Contact Person: Joshua Bieber, Director of Information Technology
2023-005
Finding 2024-003 - Significant Deficiency, Compliance Federal Award No. 84.268 U.S. Department Of Education Student Financial Aid Cluster – Reporting Criteria: According to the 2023-2024 COD Technical Reference and 2023-2024 SFA Handbook, the College must report accurate disbursement dates to Common Origination Disbursement (COD) for all direct loan disbursements made to students. Condition: In our nonstatistical sample of 40 student, we noted 1 student whose disbursement date listed in the College’s student records (10/12/23) differed by 14 days from the date of disbursement reported to COD (9/28/23) for the students’ PLUS loan disbursement. Context: The student in question had an anticipated disbursement date of 9/28/23 that was not updated for the actual disbursement date once the disbursement date was made by the College. Effect: Improperly reported disbursement dates could impact the amount of interest charged to a student. Questioned Costs: None noted. Cause: The College did not have proper processes and related controls in place to ensure that the disbursement date reported in COD agreed with the disbursement date in the College’s records. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: The Financial Aid department should put in place controls that would ensure that all disbursements would be processed on the anticipated disbursement date as planned and controls that would detect if disbursements were processed at a later or earlier date and adjustments to dates reported to COD were necessary. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to report disbursement dates to COD and has corrected the disbursement date in COD for the student discrepancy noted. Completion Date: February 2024 Contact Person: Steven W. Eckman, President
Corrective Action Plan 2024-003: The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to report disbursement dates to COD and has corrected the disbursement date in COD for the student discrepancy noted. Completion Date: February 2024 Contact Person: Steven W. Eckman, President
Finding 2024-004 - Significant Deficiency, Compliance Federal Award No. 84.038 U.S. Department Of Education Student Financial Aid Cluster – Reporting Criteria: Annually, the College is required to submit its Fiscal Operations Report and Application to Participate (FISAP) by October 1st of each year. The FISAP requires reporting primarily of key student financial aid data that ED has deemed necessary to assist with evaluating the College and is utilized to approve the College’s participation in Title IV funding levels for the fiscal year following the submission (ex. 2025-2026 academic year for report due October 1st, 2024). ED and the OMB have identified key line items in the 2024 Compliance Supplement that contain critical information that is required to be tested by the College’s auditors. One of the key line items required to be tested is Part III (Perkins): Section A, Line 1.1 Cash on hand and in depository which represents the amount of Perkins Loan funds cash held by the College at June 30, 2024 resulting from student loan repayments. Condition: The Perkins cash amount reported on Part III, Section A, Line 1.1 on the initial FISAP submitted for the year ended June 30, 2024, which was submitted timely prior to the October 1, 2024 deadline, totaled $231,958 as originally reported. The actual amount of cash held for the Perkins loan fund was $33,507 at June 30, 2024 per the College’s financial and banking records. The amount was not corrected until the discrepancy was identified during the audit testing of the FISAP. The College was able to correct the amount reported prior to the December 13, 2024 corrections due date. Context: The College utilized reports from its third party service provider to populate Part III (Perkin) of the FISAP. The third party service provider had not been informed of repayments made in the year ended June 30, 2024 to ED and to the College that were made as part of the annual distributional share calculation as funds are required to be repaid from the Perkins Cash held at the end of each fiscal year as the Perkins loan fund winds down. Therefore amounts listed in Part III (Perkins), Section A, Lines 1.1, 28.1, and 30.2 had not been updated properly on the initial FISAP submission. Effect: If the improper Perkins Cash was not corrected, the College could have been required to repay funds to ED using institutional funds. Questioned Costs: None noted. Cause: The College did not have proper processes and related controls in place to ensure that the amount reported on Part III (Perkins): Section A, Line 1.1 was accurate at June 30, 2024 as originally submitted. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: The College should implement controls to specifically review Part III (Perkins): Section A, Line 1.1, 28.1, and 30.2 and ensure that the amounts reported agree with the College’s records prior to submission to ensure reporting is accurate. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has taken corrective action by submitting a corrected FISAP with the accurate date prior to the FISAP corrections due date of December 13, 2024. Additionally, the College has established controls to ensure review of the Perkins section of the FISAP for the next reporting year. Completion Date: December 2024 Contact Person: Steven W. Eckman, President
Corrective Action Plan 2024-004: The College concurs with the finding and has taken corrective action by submitting a corrected FISAP with the accurate date prior to the FISAP corrections due date of December 13, 2024. Additionally, the College has established controls to ensure review of the Perkins section of the FISAP for the next reporting year. Completion Date: December 2024 Contact Person: Steven W. Eckman, President
Finding 2024-005 - Significant Deficiency, Compliance Federal Award No. 10.766 U.S. Department Of Agriculture Community Facilities Loan –Special Tests and Provisions Criteria: The USDA established in its Letter of Conditions dated September 13, 2017 certain annual requirements for the College to complete as part of its borrowing of the Community Facilities Loan that was completed in the year ended June 30, 2018. Condition: The College was informed via confirmation response obtained during the financial statement audit for the year ended June 30, 2024 that the College had not met all of its requirements established in the Letter of Conditions related to its Community Facilities Loan. Context: We received a confirmation response from Beverly Howard, State Community Programs Loan Technician with USDA as part of our confirmation of the USDA loan balance outstanding at June 30, 2024. The confirmation response provided indicated that the College was deficient in providing to USDA annual budgets, the Business Analysis Questionnaire and Supplemental Data (since the year ended June 30, 2019), proof of insurance (since the year ended June 30, 2022), and the June 30, 2021 annual audit under the Single Audit Act had not been provided to the USDA. Effect: Without the information requested by the USDA, the USDA may not be able to provide effective oversight of the College’s loan. Questioned Costs: None noted. Cause: Due to transition in management teams in prior years, management of the College from the year ended June 30, 2020 through the year ended June 30, 2024 was not made aware of all of the conditions listed in the USDA’s Letter of Conditions. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: The College should implement controls to ensure that all of the conditions/requirements noted in the USDA’s Letter of Conditions are met and controls to ensure that the Letter of Conditions are communicated to all relevant parties in periods of management transitions. Views Of Responsible Officials (Unaudited): The College has provided to the USDA the required documentation that had been identified as not sufficiently provided and has established controls to ensure that the requirements listed in the Letter of Conditions will be met each year going forward. Completion Date: December 2024 Contact Person: Steven W. Eckman, President
Corrective Action Plan 2024-005: The College has provided to the USDA the required documentation that had been identified as not sufficiently provided and has established controls to ensure that the requirements listed in the Letter of Conditions will be met each year going forward. Completion Date: December 2024 Contact Person: Steven W. Eckman, President
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 7, 2024. 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 7, 2024, which was (712 days ago).
What is a management decision? →Finding 2023-003 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 U.S. Department Of Education Student Financial Aid Cluster – Special Tests and Provisions Criteria: In accordance with Federal Regulations 34 CFR 668.171, an institution administering Federal Student Financial Aid must obtain a minimum composite score of 1.5 to fulfill the requirements of financial responsibility and be above 1.0 to be considered for “Zone Alternative” treatment. Condition: For the year under audit, the College’s financial responsibility composite score will fail to meet the numeric standard of responsibility as set by the Department of Education (ED). However, when an institution cannot meet the criteria for financial responsibility through the composite score, ED provides other ways to comply with this standard. One way the College can comply with this standard is by obtaining an irrevocable letter of credit from a bank. In addition, the College must make Federal Student Financial Aid disbursements under the heightened cash monitoring method described in 34 CFR 668.162. Context: The College’s ED financial responsibility composite was between 1.0 and 1.5 in the past three fiscal years. The College has not been able to bring its score above 1.5, therefore will continue to have to obtain a letter of credit and follow heightened cash monitoring procedures. Effect: The College will have to obtain a letter of credit and follow heightened cash monitoring procedures. Additionally, the College may be required to provide further documentation of its financial plans and progress to accreditation agencies in which it may seek accreditation through. Questioned Costs: None noted. Cause: Bethany College does not have proper processes and related controls in place to ensure that the required financial responsibility composite score does not fall below 1.5. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2022-001. Recommendation: We recommend that the College implement controls and processes for monitoring budgets that include all expenses including non-cash transactions in order to adequately anticipate the revenue needed to cover the expenses of the College. We recommend that the College evaluate all of its cost centers and revenue streams to ensure that the College is maximizing fiscal efficiency while still achieving the mission of the College. Views Of Responsible Officials (Unaudited): The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: August 2024 Contact Person: Steven W. Eckman, President
Corrective Action Plan 2023-003: The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: August 2024 Contact Person: Steven W. Eckman, President
2022-001
Finding 2023-004 - Significant Deficiency, Compliance Federal Award No. 84.268 U.S. Department Of Education Student Financial Aid Cluster – Eligibility Criteria: According to the 2022-2023 Student Financial Aid Handbook, the College is required to award subsidized loans up to the maximum amount available for each student for a given year based on the student’s need analysis and aggregate borrowing history before the College awards unsubsidized loans. Condition: In our nonstatistical sample of 40 students, we noted 2 students who were awarded unsubsidized loans instead of subsidized loans when the student had remaining subsidized loan eligibility in the 2022-23 academic year. Context: Both students that were underawarded subsidized loans and overawarded unsubsidized loans were initially capped on the total amount of federal direct loans that could be awarded to the students based on the students’ need analysis and aggregate loan limits. When packaging the loans, the student financial aid staff erroneously awarded portions of the loan awards as direct unsubsidized loans instead of subsidized loan awards. For both students the total amount of loan awards was proper and the student was not overawarded or underawarded overall. One student was overawarded unsubsidized loans and underawarded subsidized loans in the amount of $5,000 and the other student was overawarded unsubsidized loans and underawarded subsidized loans in the amount of $1,500. Effect: Students are charged interest on unsubsidized loans while enrolled at least half-time at higher education institutions, whereas students are not charged interest on subsidized loans. Therefore, the students were charged approximately $188 and $75, respectively in interest that the students should not have incurred if the loans were awarded properly. Questioned Costs: $263 additional interest costs incurred by students Cause: Bethany College did not have proper processes and related controls in place to ensure that awards were packaged appropriately for circumstances where a student’s loan eligibility was limited by the need analysis calculation or by aggregate loan limits. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: The Financial Aid department should put in place controls that would ensure that all loans are properly awarded including additional review of loan awards that are made as a result of adjustments needed to a student’s loan award to accommodate an annual or aggregate limit. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to package loans when there is an annual or aggregate loan limit reached. Completion Date: August 2023 Contact Person: Haley Wesley, Vice President of Enrollment Management & Marketing
Corrective Action Plan 2023-004: The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to package loans when there is an annual or aggregate loan limit reached. Completion Date: August 2023 Contact Person: Haley Wesley, Vice President of Enrollment Management & Marketing
Finding 2023-005 - Significant Deficiency, Compliance Federal Award No. 84.268, 84.007, 84.379, 84.063, 84.033, 84.038 U.S. Department Of Education Student Financial Aid Cluster - Special Tests and Provisions Criteria: The Federal Trade Commission (FTC) issued the FTC Safeguards Rule on December 9, 2021 and gave notice to entities that are required to follow the Gramm-Leach-Bliley Act (GLBA) that each entity would be required to be in compliance with the revised requirements no later than June 9, 2023. The FTC Safeguards Rule expanded the requirements for the written information security program required to be established by the College. The requirements for the written information security program noted at 16 CFR 314.4 require that the College designate a Qualified Individual responsible for overseeing and implementing the College’s information security program, be based on a risk assessment that identifies reasonably foreseeable internal and external risks and establishes safeguards to address those risks, and requires that the following 8 safeguards be documented: • Implement and periodically review access controls • Conduct a periodic inventory of data, noting where it is collected, stored, or transmitted • Encrypt customer information on the institution’s system and when it’s in transit. • Assess apps developed by the institution • Implement multi-factor authentication for anyone accessing customer information on the institution’s system • Dispose of customer information securely • Anticipate and evaluate changes to the information system or network • Maintain a log of authorized users’ activity and keep an eye out for unauthorized access In addition, the College is responsible for regularly testing and monitoring the effectiveness of the safeguards it has implemented and establishing how it will complete the monitoring and testing in the written Information Security Program. The College is also responsible for documenting in the written Information Security Program how it will oversee its information system service providers and shall also provide for the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring; the results of the required risk assessments; any material changes to the College’s operations or business arrangements; or any other circumstances that it knows or has reason to know may have a material impact on the College’s information security program. Condition: The College took steps toward meeting the requirements of the FTC Safeguards Rule, including conducting an evaluation of its current compliance and implementing many of the new requirements, but the College failed to update its written Information Security Program to incorporate all of the changes required by the FTC Safeguards Rule by the due date of June 9, 2023 or June 30, 2023. Context: The College took steps to implement the requirements and established draft policies and procedures to meet the requirements of the FTC Safeguards Rule; however, the College did not formalize the policies and procedures or update its written Information Security Program. Effect: The failure to meet the requirements of the FTC Safeguards Rule including establishing formal documentation of the written Information Security Program could make the College vulnerable to cyber security and student data protection risks. Questioned Costs: None noted. Cause: Given the size of the College’s IT department, the College focused on implementing as many of the safeguards as possible first to meet the FTC Safeguards Rule and did not prioritize a formal update of its written Information Security Program to meet the requirements of the FTC Safeguards Rule. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: The College should immediately formalize its written Information Security Program to meet the FTC Safeguards Rule. Views Of Responsible Officials (Unaudited): The College concurs with the finding and will formalize its written Information Security Program. Completion Date: Spring 2024 Contact Person: Joshua Bieber, Director of Information Technology
Corrective Action Plan 2023-005: The College concurs with the finding and will formalize its written Information Security Program. Completion Date: Spring 2024 Contact Person: Joshua Bieber, Director of Information Technology
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 13, 2023. 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 13, 2023, which was (1103 days ago).
What is a management decision? →Finding 2022-001 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: In accordance with Federal Regulations 34 CFR 668.171, an institution administering Federal Student Financial Aid must obtain a minimum composite score of 1.5 to fulfill the requirements of financial responsibility and be above 1.0 to be considered for ?Zone Alternative? treatment. Condition: For the year under audit, the College?s financial responsibility composite score will fail to meet the numeric standard of responsibility as set by the Department of Education (ED). However, when an institution cannot meet the criteria for financial responsibility through the composite score, ED provides other ways to comply with this standard. One way the College can comply with this standard is by obtaining an irrevocable letter of credit from a bank. In addition, the College must make Federal Student Financial Aid disbursements under the heightened cash monitoring method described in 34 CFR 668.162. Context: The College?s ED financial responsibility composite fell below 1.0 in previous years and was between 1.0 and 1.5 in the past two fiscal years. The College has not been able to bring its score above 1.5, therefore will continue to have to obtain a letter of credit and follow heightened cash monitoring procedures. Effect: The College will have to obtain a letter of credit and follow heightened cash monitoring procedures. Additionally, the College may be required to provide further documentation of its financial plans and progress to accreditation agencies in which it may seek accreditation through. Questioned Costs: None noted. Cause: Bethany College does not have proper processes and related controls in place to ensure that the required financial responsibility composite score does not fall below 1.5. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: We recommend that the College implement controls and processes for monitoring budgets that include all expenses including non-cash transactions in order to adequately anticipate the revenue needed to cover the expenses of the College. We recommend that the College evaluate all of its cost centers and revenue streams to ensure that the College is maximizing fiscal efficiency while still achieving the mission of the College. Views Of Responsible Officials (Unaudited): The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: August 2023 Contact Person: Krista Harris, Chief Financial Officer
Corrective Action Plan 2022-001: The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: August 2023 Contact Person: Krista Harris, Chief Financial Officer
2021-001
Finding 2022-002 ? Material Weakness, Compliance Federal Award No. 84.425F U.S. Department Of Education Higher Education Emergency Relief Fund ? Reporting Criteria: In accordance with the Department of Education?s Frequently Asked Questions for the Higher Education Emergency Relief Fund (HEERF) the College is required to post to its website a quarterly report covering the aggregate amounts spent for HEERF I, HEERF II, and HEERF III for each quarterly reporting period 10 day after the end of each calendar quarter. Condition: The College did not post to its website timely one of two HEERF institutional portion quarterly reports selected for testing. The report not posted timely was for the quarter ending March 31, 2022 and was not posted accurately until July 2022. Context: The College erroneously posted the March 31, 2021 HEERF institutional report within the link on its website for the March 31, 2022 HEERF report. This was not identified or corrected until July 2022. Effect: The College did not communicate to the public its use of the institutional portion of the HEERF grant timely. If the Department of Education identifies an institution as having an elevated risk or are suspected of improperly administering their HEERF grant funds, the Department has a range of possible enforcement actions which could include heightened or more frequent reporting, monitoring, or auditing of an institution and placing the HEERF grants on ?Route Payment Status?, which requires prior authorization from the Department to draw down any remaining funds. As of the audit report date, the College has not received any notifications of any enforcement actions taken against the College related to the HEERF program. Questioned Costs: None noted. Cause: Bethany College does not have proper processes and related controls in place to ensure that the HEERF institutional report was submitted accurately and timely. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2021-002. Recommendation: We recommend that the College implement controls and processes to ensure that all due dates for reporting are appropriately monitored and reports are submitted timely to meet the reporting due dates. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through posting the correct institutional report in July 2022 to its website. Completion Date: July 2022 Contact Person: Krista Harris, Chief Financial Officer
Corrective Action Plan 2022-002: The College concurs with the finding and has provided corrective action through posting the correct institutional report in July 2022 to its website. Completion Date: July 2022 Contact Person: Krista Harris, Chief Financial Officer
2021-002
Finding 2022-003 - Significant Deficiency, Compliance Federal Award No. 84.268 U.S. Department Of Education Student Financial Aid Cluster - Special Tests and Provisions Criteria: According to the 2021-2022 COD Technical Reference and 2021-2022 SFA Handbook, the College must report accurate disbursement dates to Common Origination Disbursement (COD) for all direct loan disbursements made to students. Condition: In our nonstatistical sample of 40 students, we noted 24 students whose disbursement dates listed in the College?s student records (8/27/21) differed by one day from the date of disbursement dates reported to COD (8/28/21) for the students? direct loans disbursed in the Fall 2021 semester. Context: The students in question had anticipated disbursement dates of 8/28/21 that were not updated for the actual date of disbursement once the disbursements were made by the College. Effect: Improperly reported disbursement dates could impact the amount of interest charged to a student. Questioned Costs: There were no questioned costs to report as this finding relates only to COD reporting. Cause: Bethany College did not have proper processes and related controls in place to ensure that the disbursement dates reported in COD agreed with the disbursement dates in the College?s records. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: The Financial Aid department should put in place controls that would ensure that all disbursements would be processed on the anticipated disbursement dates as planned and controls that would detect if disbursements were processed at a later or earlier date and adjustments to amounts reported to COD were necessary. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to report disbursement dates to COD. Completion Date: January 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Corrective Action Plan 2022-003: The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to report disbursement dates to COD. Completion Date: January 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-004 - Significant Deficiency, Compliance Federal Award No. 84.268, 84.007, 84.379, 84.063 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to the 2021-2022 Federal Student Aid Handbook a College must exclude institutionally scheduled breaks of five or more consecutive days from the Return to Title IV (R2T4) calculation as periods of nonattendance. The length of the scheduled break is determined by taking the last day that class is held before a scheduled break ? the next day is the first day of the scheduled break and the last day of the scheduled break is the day before the next class. Condition: In our nonstatistical sample of six students, it was noted for two students that the College used 105 days as the total days in the semester for the Fall 2021 semester when the College should have used 107 days as the total days in the semester for the Fall 2021 semester in the R2T4 calculation due to improperly counting two extra days for the institutionally scheduled break. Context: The College counted the last day of classes of November 19th, 2021 before the Thanksgiving break and the first day that classes resumed of November 29th, 2021 totaling 11 days as an institutionally scheduled break that reduced the total days used in the R2T4 calculation for the Fall 2021 semester. However, the College should have only used 9 days as the institutionally scheduled break was from November 20th, 2021 through November 28th, 2021. Effect: The improper calculation of the institutionally scheduled break dates resulted in the students retaining additional aid. Questioned Costs: Known questioned costs for the two students in which the exceptions were noted totaled $125. Likely questioned costs were not expected to exceed $1,000 for the R2T4 calculations performed in the Fall 2021 semester. Cause: Bethany College did not have proper processes and related controls in place to ensure that the correct number of days were used for institutionally scheduled breaks in the Fall 2021 semester. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to calculate the number of days included in institutionally scheduled breaks for the R2T4 calculation. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through adding additional review of the calculation of institutionally scheduled breaks and total days used in the R2T4 calculations. Completion Date: May 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Corrective Action Plan 2022-004: The College concurs with the finding and has provided corrective action through adding additional review of the calculation of institutionally scheduled breaks and total days used in the R2T4 calculations. Completion Date: May 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-005 - Significant Deficiency Federal Award No. 84.425F U.S. Department Of Education Higher Education Emergency Relief Fund ? Cash Management Criteria: The U.S. Department of Education (ED) communicated updated cash management guidance for the HEERF through the release of the HEERF II FAQs on January 14, 2021. The HEERF II FAQ #17 specified that grantees are under an obligation to minimize the time between drawing down funds from G5 and paying obligations incurred by the grantee. ED considered institutions compliant if they paid from the HEERF funds emergency grants to students within 15 days of the draw down and for all other uses within 3 days. The Uniform Guidance requires the identification and documentation of costs as federal expenditures to occur prior to or within the timeframe established for paying obligations when grantees must follow enhanced cash management requirements. Condition/Context: The College drew down approximately $840,000 of HEERF funds from the institutional portion in April 2022 to various costs allowed for the by HEERF institutional portion; however, the College had not identified or documented specific costs or lost revenues that would be applied at the time of the drawdown for approximately $48,000 of the costs requested. Subsequent to the 3-day requirement for obligating institutional portion funds, the College identified and documented the specific costs that occurred prior to the date of the drawdown that were to be applied against this draw. Therefore, the College did not have an adequate control in place at the time of the drawdown to ensure that costs would be allowable; however, subsequently the College was able to identify sufficient allowable costs had been incurred. Effect: The College could have drawn down funds for ineligible costs or with improper timing if sufficient allowable costs had not been identified that occurred prior to or within 3 days of the drawdown date. If the Department of Education identifies an institution as having an elevated risk or are suspected of improperly administering their HEERF grant funds, the Department has a range of possible enforcement actions which could include heightened or more frequent reporting, monitoring, or auditing of an institution and placing the HEERF grants on ?Route Payment Status?, which requires prior authorization from the Department to draw down any remaining funds. As of the audit report date, the College has not received any notifications of any enforcement actions taken against the College related to the HEERF program. Questioned Costs: There were no questioned costs identified as management was able to identify sufficient allowable costs. Cause: The College made an error in the calculation of its initial drawdown request which resulted in the additional approximately $48,000 being requested that had not yet been supported by allowable costs prior to the date of the drawdown or within 3 days after the date of the drawdown. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2021-006. Recommendation: We recommend that the College implement controls and processes to ensure that all expenses are properly identified and documented before any drawdowns are made. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through identification of specific costs incurred prior to drawdown of funds and additional review of the drawdown calculations. Completion Date: July 2022 Contact Person: Krista Harris, Chief Financial Officer
Corrective Action Plan 2022-005: The College concurs with the finding and has provided corrective action through identification of specific costs incurred prior to drawdown of funds and additional review of the drawdown calculations. Completion Date: July 2022 Contact Person: Krista Harris, Chief Financial Officer
2021-006
Finding 2022-006 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.268, 84.033, 84.038, 84.379, 84.063 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: Per guidance in 34 CF 668.46(b), 34 CFR 668.49(b), and 34 CFR 668.41(e) the College is required to distribute its Annual Security Report and Annual Fire Safety Report by October 1st of each year to all enrolled students and current employees. Condition/Context: The College did not distribute its report due on October 1, 2022 on or before October 1, 2022 as the report was not completed until late October 2022. Effect: The College did not timely inform the enrolled students and current employees of the required statistics and information related to campus security and fire safety for the preceding year. Questioned Costs: There were no questioned costs identified as a result of this finding. Cause: The College was delayed in gathering information needed to prepare the report for distribution. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the College implement controls and processes to ensure that the Annual Security Report and Annual Fire Safety report is distributed timely. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through distributing the Annual Security Report and Fire Safety Report as well as establishing appropriate timelines for distribution in future years. Completion Date: October 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Corrective Action Plan 2022-006: The College concurs with the finding and has provided corrective action through distributing the Annual Security Report and Fire Safety Report as well as establishing appropriate timelines for distribution in future years. Completion Date: October 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on April 5, 2022. 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 October 5, 2022, which was (1415 days ago).
What is a management decision? →Finding 2021-001 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: In accordance with Federal Regulations 34 CFR 668.171, an institution administering Federal Student Financial Aid must obtain a minimum composite score of 1.5 to fulfill the requirements of financial responsibility and be above 1.0 to be considered for ?Zone Alternative? treatment. Condition: For the year under audit, the College?s financial responsibility composite score will fail to meet the numeric standard of responsibility as set by the Department of Education (ED). However, when an institution cannot meet the criteria for financial responsibility through the composite score, ED provides other ways to comply with this standard. One way the College can comply with this standard is by obtaining an irrevocable letter of credit from a bank. In addition, the College must make Federal Student Financial Aid disbursements under the heightened cash monitoring method described in 34 CFR 668.162. Context: The College?s ED financial responsibility composite fell below 1.0 in previous years and was between 1.0 and 1.5 in the past two fiscal years. The College has not been able to bring its score above 1.5, therefore will continue to have to obtain a letter of credit and follow heightened cash monitoring procedures. Effect: The College will have to obtain a letter of credit and follow heightened cash monitoring procedures. Additionally, the College may be required to provide further documentation of its financial plans and progress to accreditation agencies in which it may seek accreditation through. Questioned Costs: None noted. Cause: Bethany College does not have proper processes and related controls in place to ensure that the required financial responsibility composite score does not fall below 1.5. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2020-001.Recommendation: We recommend that the College implement controls and processes for monitoring budgets that include all expenses including non-cash transactions in order to adequately anticipate the revenue needed to cover the expenses of the College. We recommend that the College evaluate all of its cost centers and revenue streams to ensure that the College is maximizing fiscal efficiency while still achieving the mission of the College. Views Of Responsible Officials (Unaudited): The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: August 2022 Contact Person: Krista Harris, Chief Financial Officer
Corrective Action Plan 2021-001: The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: August 2022 Contact Person: Krista Harris, Chief Financial Officer
2020-001
Finding 2021-002 ? Material Weakness, Compliance Federal Award No. 84.425F U.S. Department Of Education Higher Education Emergency Relief Fund ? Reporting Criteria: In accordance with the Department of Education?s Frequently Asked Questions for the Higher Education Emergency Relief Fund (HEERF) the College is required to post to its website a quarterly report covering the aggregate amounts spent for HEERF I, HEERF II, and HEERF III for each quarterly reporting period 10 day after the end of each calendar quarter apart from the first report covering the quarter ending September 30, 2020 which was due October 30, 2020 and the report covering the quarter ending March 31, 2021 which was due July 10, 2021. Condition: The College did not post to its website the two HEERF institutional portion quarterly reports selected for testing for the quarters ending March 31, 2021 and June 30, 2021 until September 2021, which was past the due date for the reports to be posted. Context: The College was not aware that the institutional portion reports, in addition to the student portion reports, were required to be posted to the College?s website until September 2021 at which time the College promptly posted all required reports to its website. Effect: The College did not communicate to the public its use of the institutional portion of the HEERF grant timely. If the Department of Education identifies an institution as having an elevated risk or are suspected of improperly administering their HEERF grant funds, the Department has a range of possible enforcement actions which could include heightened or more frequent reporting, monitoring, or auditing of an institution and placing the HEERF grants on ?Route Payment Status?, which requires prior authorization from the Department to draw down any remaining funds. As of the audit report date, the College has not received any notifications of any enforcement actions taken against the College related to the HEERF program. Questioned Costs: None noted. Cause: Bethany College does not have proper processes and related controls in place to ensure that the HEERF institutional report was submitted timely. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2020-002. Recommendation: We recommend that the College implement controls and processes to ensure that all due dates for reporting are appropriately monitored and reports are submitted timely to meet the reporting due dates. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through posting the institutional reports in September 2021 to its website. Completion Date: September 2021 Contact Person: Krista Harris, Chief Financial Officer
Corrective Action Plan 2021-002: The College concurs with the finding and has provided corrective action through posting the institutional reports in September 2021 to its website. Completion Date: September 2021 Contact Person: Krista Harris, Chief Financial Officer
2020-002
Finding 2021-003 - Material Weakness, Compliance Federal Award No. 84.425F U.S. Department Of Education Higher Education Emergency Relief Fund - Reporting Criteria: The quarterly reporting form that was required to be utilized for the HEERF institutional portion included specific instructions to include only HEERF funds spent from the institutional portion. Additionally, the instructions to the form required an institution to provide ?Explanatory Notes? for any amounts designated as being expended for ?Other Uses of (a)(1) Institutional Portion funds?. Condition/Context: The College improperly reported $511,010 of HEERF student portion costs on the HEERF institutional portion report on the line ?Providing additional emergency financial aid grants to students? on the report posted for the quarter ending March 31, 2021. Additionally, the College included $1,000,000 in the ?Other Uses of (a)(1) Institutional Portion funds? line but failed to specify in the ?Explanatory Notes? the nature of these costs. The College was not aware of the requirements to exclude the student portion costs from the institutional portion report and also failed to identify that the ?Explanatory Notes? were necessary to describe the allowable payroll costs and lost revenues applied against the HEERF funds in the quarter ending March 31, 2021. Effect: The College did not communicate to the public sufficient information within the HEERF institutional quarterly report for the quarter ending March 31, 2021 that would allow the public to understand the proper amount and nature of its use of the institutional portion of the HEERF grant. If the Department of Education identifies an institution as having an elevated risk or are suspected of improperly administering their HEERF grant funds, the Department has a range of possible enforcement actions which could include heightened or more frequent reporting, monitoring, or auditing of an institution and placing the HEERF grants on ?Route Payment Status?, which requires prior authorization from the Department to draw down any remaining funds. As of the audit report date, the College has not received any notifications of any enforcement actions taken against the College related to the HEERF program. Questioned Costs: None noted. Cause: Bethany College does not have proper processes and related controls in place to ensure that the HEERF institutional report was submitted accurately. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the College implement controls and processes to ensure that all data elements for reporting are reported accurately and that all instructions to the reporting are followed. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through posting updated reports to its website on December 20th, 2021. Completion Date: December 2021 Contact Person: Krista Harris, Chief Financial Officer
Corrective Action Plan 2021-003: The College concurs with the finding and has provided corrective action through posting updated reports to its website on December 20th, 2021. Completion Date: December 2021 Contact Person: Krista Harris, Chief Financial Officer
Finding 2021-004 - Significant Deficiency, Compliance Federal Award No. 84.268, 84.038 U.S. Department Of Education Student Financial Aid Cluster - Special Tests and Provisions Criteria: According to the Federal Student Aid Handbook, Volume 2, Chapter 6, a College must confirm that the student has completed face-to face or online counseling, or that the student has been mailed exit loan counseling material within 30 days of learning the student has withdrawn or failed to participate in an exit counseling session. Condition: In our nonstatistical sample of 40 students, it was noted for two individuals that the student had not completed exit counseling and the communication of exit counseling materials had not been completed within the 30 day threshold after learning that the student withdrew from the College. Context: The students in question were not provided exit counseling materials after the students withdrew in the Fall 2020 semester until approximately one year from the date of the withdrawal. Effect: Students are not properly informed of their responsibilities for the repayment of loans received once leaving the College. Questioned Costs: There were no questioned costs to report as this finding relates only to exit counseling and is not related to eligibility. Cause: Bethany College did not have proper processes and related controls in place to complete the exit counseling requirements within 30 days of the date the College determined the student withdrew. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to complete the exit counseling requirements for all students who have exited the College within 30 days of the date of the student?s exit. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to identify students who should receive notification of exit counseling and provide that to them timely. Completion Date: May 2021 Contact Person: Jeff Roush, Student Financial Aid Director
Corrective Action Plan 2021-004: The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to identify students who should receive notification of exit counseling and provide that to them timely. Completion Date: May 2021 Contact Person: Jeff Roush, Student Financial Aid Director
Finding 2021-005 - Significant Deficiency, Compliance Federal Award No. 84.268 U.S. Department Of Education Student Financial Aid Cluster ? Eligibility Criteria: According to the Federal Student Aid Handbook a College must prorate a student?s federal direct loans when it identifies that the student is attending for only one remaining semester in an academic year based on the student?s actual enrollment for that semester compared to the standard enrollment for a full academic year. Condition: In our nonstatistical sample of 40 students, it was noted for one student that the student had received a prorated federal direct loan award in the Fall 2020 semester, the final semester of enrollment for the student. The student?s total federal direct loan award of $5,937 was awarded appropriately; however, the allocation between subsidized loans and unsubsidized loans was completed improperly resulting in an underaward of $96 of subsidized federal direct loans and an overaward of $96 of unsubsidized federal direct loans. Context: The student in question notified the College of the intent to graduate after the Fall 2020 semester and enrolled in 19 credit hours. The College prorated the annual federal direct loan award limit for a 4th year dependent student of $7,500 by multiplying this amount by 19 credit hours divided by the standard 24 credit hours in an academic year resulting in a direct loan award amount of $5,937. The subsidized direct loan limit for this student should have been $4,354 ($5,500 x 19/24); however, the student was only packaged a subsidized direct loan award of $4,258. The difference of $96 was added to the unsubsidized direct loan award. Effect: Student was not properly awarded the correct type of loan in the correct amount. Questioned Costs: There are no questioned costs as the student was awarded the correct amount of aid in total and the difference in the amount of interest paid by the student could not be estimated. Cause: Bethany College did not have proper processes and related controls in place to ensure that the allocation between the subsidized direct loans and unsubsidized direct loan awards were accurate when direct loan awards were required to be prorated. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to complete the proration calculations accurately including evaluation of the allocation between subsidized direct loan awards and unsubsidized direct loan awards. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through reviewing and updating the proration awarding process for single term graduates. Completion Date: May 2021 Contact Person: Jeff Roush, Student Financial Aid Director
Corrective Action Plan 2021-005: The College concurs with the finding and has provided corrective action through reviewing and updating the proration awarding process for single term graduates. Completion Date: May 2021 Contact Person: Jeff Roush, Student Financial Aid Director
Finding 2021-006 - Significant Deficiency Federal Award No. 84.425F U.S. Department Of Education Higher Education Emergency Relief Fund ? Cash Management Criteria: The U.S. Department of Education (ED) communicated updated cash management guidance for the HEERF through the release of the HEERF II FAQs on January 14, 2021. The HEERF II FAQ #17 specified that grantees are under an obligation to minimize the time between drawing down funds from G5 and paying obligations incurred by the grantee. ED considered institutions compliant if they paid from the HEERF funds emergency grants to students within 15 days of the draw down and for all other uses within 3 days. The Uniform Guidance requires the identification and documentation of costs as federal expenditures to occur prior to or within the timeframe established for paying obligations when grantees must follow enhanced cash management requirements. Condition/Context: The College drew down $1,000,000 of HEERF funds from the institutional portion in January 2021 to cover payroll costs shortly after the HEERF II allocations were made available; however, the College had not identified or documented specific payroll costs or lost revenues that would be applied at the time of the drawdown. Subsequent to the 3-day requirement for obligating institutional portion funds, the College identified and documented the specific payroll costs that occurred prior to the date of the drawdown that were to be applied against this draw. Therefore, the College did not have an adequate control in place at the time of the drawdown to ensure that costs would be allowable; however, subsequently the College was able to identify sufficient allowable costs had been incurred. Effect: The College could have drawn down funds for ineligible costs or with improper timing if sufficient allowable costs had not been identified that occurred prior to or within 3 days of the drawdown date. If the Department of Education identifies an institution as having an elevated risk or are suspected of improperly administering their HEERF grant funds, the Department has a range of possible enforcement actions which could include heightened or more frequent reporting, monitoring, or auditing of an institution and placing the HEERF grants on ?Route Payment Status?, which requires prior authorization from the Department to draw down any remaining funds. As of the audit report date, the College has not received any notifications of any enforcement actions taken against the College related to the HEERF program. Questioned Costs: There were no questioned costs identified as management was able to identify sufficient allowable costs. Cause: The College was not aware of the cash management requirements established within the Frequently Asked Questions that were released with the HEERF II allocations on January 14, 2021 until after the initial drawdown was completed. After reviewing the cash management requirements, the College determined that it had sufficient payroll costs that were incurred prior to or within 3 days of the drawdown date. Indication Of Repeat Finding: This is not a repeat finding Recommendation: We recommend that the College implement controls and processes to ensure that all expenses are properly identified and documented before any drawdowns are made. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through no longer requesting draws for HEERF funds until the College has made the appropriate calculations for allowable costs for the institutional portion. Completion Date: August 2021 Contact Person: Krista Harris, Chief Financial Officer
Corrective Action Plan 2021-006: The College concurs with the finding and has provided corrective action through no longer requesting draws for HEERF funds until the College has made the appropriate calculations for allowable costs for the institutional portion. Completion Date: August 2021 Contact Person: Krista Harris, Chief Financial Officer
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 16, 2021. 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 March 16, 2022, which was (1618 days ago).
What is a management decision? →Finding 2020-001 - Significant Deficiency Federal Award No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 U.S. Department Of Education Student Financial Aid Cluster Criteria: In accordance with Federal Regulations 34 CFR 668.171, an institution administering Federal Student Financial Aid must obtain a minimum composite score of 1.5 to fulfill the requirements of financial responsibility and be above 1.0 to be considered for ?Zone Alternative? treatment. Condition: For the year under audit, the College?s financial responsibility composite score will fail to meet the numeric standard of responsibility as set by the Department of Education (ED ). However, when an institution cannot meet the criteria for financial responsibility through the composite score, ED provides other ways to comply with this standard. One way the College can comply with this standard is by obtaining an irrevocable letter of credit from a bank. In addition, the College must make Federal Student Financial Aid disbursements under the heightened cash monitoring method described in 34 CFR 668.162. Context: The College?s ED financial responsibility composite fell below 1.0 for the prior year and was approximately a 1.0 in the current year. The College has not been able to bring its score above 1.5, therefore will continue to have to obtain a letter of credit and follow heightened cash monitoring procedures. Effect: The College will have to obtain a letter of credit and follow heightened cash monitoring procedures. Additionally, the College may be required to provide further documentation of its financial plans and progress to accreditation agencies in which it may seek accreditation through. Questioned Costs: None noted. Cause: Bethany College does not have proper processes and related controls in place to ensure that the required financial responsibility composite score does not fall below 1.5. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2019-002. Recommendation: We recommend that the College implement controls and processes for monitoring budgets that include all expenses including non-cash transactions in order to adequately anticipate the revenue needed to cover the expenses of the College. We recommend that the College evaluate all of its cost centers and revenue streams to ensure that the College is maximizing fiscal efficiency while still achieving the mission of the College. Views Of Responsible Officials (Unaudited): The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: June 2021 Contact Person: Krista Harris, Chief Financial Officer
Corrective Action Plan 2020-001: The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: June 2021 Contact Person: Krista Harris, Chief Financial Officer
2019-002
Finding 2020-002 - Significant Deficiency Federal Award No. 84.425E U.S. Department Of Education Higher Education Emergency Relief Fund Criteria: In accordance with the Department of Education?s Electronic Announcement dated May 6, 2020 and titled Higher Education Emergency Relief Fund Reporting ? Emergency Financial Aid Grants to Students, the College is required to post a 30-day report on the use of the student portion of the HEERF funding received under the CARES Act to its website. The 30-day report is due 30 days from the date of the award. Condition: The College?s award date for the student portion of HEERF was May 4, 2020, therefore the 30-day student portion initial report was required to be posted to the College?s website by June 4, 2020. The College did not post its initial report to its website until June 25, 2020 which was 21 days past the due date. Context: Due to multiple communications received during the months of April 2020 through June 2020 from the Department of Education, the College believed it had until June 25th to post the report to its website. Effect: The College did not communicate to the public its use of the student portion of the HEERF grant timely. Questioned Costs: None noted. Cause: Bethany College does not have proper processes and related controls in place to ensure that the HEERF student report was submitted timely. Recommendation: We recommend that the College implement controls and processes to ensure that all due dates for reporting are appropriately monitored and reports are submitted timely to meet the reporting due dates. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through posting the student report on June 25, 2020 to its website. Completion Date: June 2020 Contact Person: Krista Harris, Chief Financial Officer
Corrective Action Plan 2020-002: The College concurs with the finding and has provided corrective action through posting the student report on June 25, 2020 to its website. Completion Date: June 2020 Contact Person: Krista Harris, Chief Financial Officer
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on November 19, 2019. 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 May 19, 2020, which was (2284 days ago).
What is a management decision? →Finding 2019-001 - Significant Deficiency Federal Award No. 84.268 & 84.379 U.S. Department Of Education Student Financial Aid Cluster Criteria: According to the Federal Student Financial Aid Handbook, Volume 4, Chapter 2, ?Except in the case of loan funds made as a part of a post-withdrawal disbursement, when Perkins Loan or Direct Loan funds are being credited to a student?s account, the school must also notify the borrower in writing (paper or electronically) of the: anticipated date and amount of the disbursement; borrower?s right to cancel all or a part of the loan or disbursement; and procedures for canceling a Direct Loan or Perkins Loan and the time by which the borrower must notify the school that he or she wishes to cancel the loan or loan disbursement.? Due to the College obtaining affirmative confirmation, the notification must be sent ?no earlier than 30 days before and no later than 30 days after crediting the student?s account.? Condition: In our nonstatistical sample of 40 students, it was noted that 35 students did not receive written notification of their loan disbursement within 30 days of the loan disbursement date. Context: We noted that all of the exceptions noted were noted to be in the Spring 2019 semester and were missed due to a system error in which the file that was set to be generated was not generated that would notify students of their loan disbursements. It was noted the majority of students noted as exceptions were notified in writing within 125 days from the date of the disbursement. Effect: Students may not be properly notified of their rights and responsibilities with regard to loans being credited to their accounts. Questioned Costs: Since students were not properly notified of their right to cancel loans on a timely basis, it is possible that eligible students may have chosen to cancel their disbursements/loans. It is not possible at this time to estimate the number of students that might have considered this option had they been properly notified; therefore, we cannot estimate a monetary amount of questioned costs. No exceptions related to student eligibility were noted. Cause: Bethany College does not have proper processes and related controls in place to notify students (or parents) of the required information, within the proper timeframe, when crediting the student accounts with loan funds. Indication of Repeat Finding: This is a repeat finding of a finding in the immediately prior year; see summary schedule of prior audit findings 2018-004. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to notify students (or parents) of the required information, within the proper timeframe, when crediting student accounts with loan funds. Views Of Responsible Officials (Unaudited): The College agrees and has implemented procedures to ensure timely delivery of loan disbursement notifications to students. During FY19, the College implemented new accounts receivable software. The new software failed to issue the appropriate loan notification letters in Spring 2019. As soon as the College learned of the failure, the College moved to both correct the software and implement oversight controls. The financial aid and business offices collaborated on these solutions to ensure that all notifications are now processed timely. In addition to correcting the software?s communication management feature, the business office now regularly reviews the software?s communication management tool to view communications sent to students and verify that all loan notices have been properly sent. Completion Date: June 2019 Contact Person: Student Financial Aid Director
Corrective Action Plan 2019-001: The College agrees and has implemented procedures to ensure timely delivery of loan disbursement notifications to students. During FY19, the College implemented new accounts receivable software. The new software failed to issue the appropriate loan notification letters in Spring 2019. As soon as the College learned of the failure, the College moved to both correct the software and implement oversight controls. The financial aid and business offices collaborated on these solutions to ensure that all notifications are now processed timely. In addition to correcting the software?s communication management feature, the business office now regularly reviews the software?s communication management tool to view communications sent to students and verify that all loan notices have been properly sent. Completion Date: June 2019 Contact Person: Chief Financial Officer
2018-004
Finding 2019-002 - Significant Deficiency Federal Award No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 U.S. Department Of Education Student Financial Aid Cluster Criteria: In accordance with Federal Regulations 34 CFR 668.171, an institution administering Federal Student Financial Aid must obtain a minimum composite score of 1.5 to fulfill the requirements of financial responsibility and be above 1.0 to be considered for ?Zone Alternative? treatment. Condition: For the year under audit, the College?s financial responsibility composite score will fail to meet the numeric standard of responsibility as set by the Department of Education (ED ) and the threshold for ?Zone Alternative? treatment. However, when an institution cannot meet the criteria for financial responsibility through the composite score, ED provides other ways to comply with this standard. One way the College can comply with this standard is by obtaining an irrevocable letter of credit from a bank. In addition, the College must make Federal Student Financial Aid disbursements under the heightened cash monitoring method described in 34 CFR 668.162. Context: The College had a decrease in net assets in the current year which resulted in College?s ED financial responsibility composite score to fall below 1.0 for the current year under audit. Effect: The College will have to obtain a letter of credit and follow heightened cash monitoring procedures. Additionally, the College may be required to provide further documentation of its financial plans and progress to accreditation agencies in which it may seek accreditation through. Questioned Costs: None noted. Cause: Bethany College does not have proper processes and related controls in place to ensure that the required financial responsibility composite score does not fall below 1.5 or 1.0. The College?s expenses were not matched or exceeded in the current year by unrestricted revenues or releases from restrictions. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2018-006. Recommendation: We recommend that the College implement controls and processes for monitoring budgets that include all expenses including non-cash transactions in order to adequately anticipate the revenue needed to cover the expenses of the College. We recommend that the College evaluate all of its cost centers and revenue streams to ensure that the College is maximizing fiscal efficiency while still achieving the mission of the College. Views Of Responsible Officials (Unaudited): The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: June 2020 Contact Person: Chief Financial Officer
Corrective Action Plan 2019-002: The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: June 2020 Contact Person: Chief Financial Officer
2018-006
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 21, 2019. 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 21, 2019, which was (2556 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
2017-004
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
2017-002
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 1, 2018. 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 1, 2018, which was (2910 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
2016-005
GSA_MIGRATION
GSA_MIGRATION
2016-008
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 29, 2017. 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 29, 2017, which was (3247 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
2015-007
GSA_MIGRATION
GSA_MIGRATION
2015-012
GSA_MIGRATION
GSA_MIGRATION
2015-013
GSA_MIGRATION
GSA_MIGRATION
2015-014
GSA_MIGRATION
GSA_MIGRATION
2015-015
GSA_MIGRATION
GSA_MIGRATION
2015-006
GSA_MIGRATION
GSA_MIGRATION
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.
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