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Campbell UniversityHigher Education

EIN: 560529940

UEI: DK9MKVC96A47

Audit also covers EIN: 680620773

Audited by: BDO USA, P.C.

Cognizant agency: 84 [Department of Education]

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Data as of August 28, 2026

Campbell University10 audit years17 findings7 repeat
10
Audit Years
17
Total Findings
7
Repeat Findings
$168.8M
Federal Awards Expended (FY 2025)

FY 2025-05-31

LOW-RISK AUDITEE$168,813,272 federal awards expendedNo findings recorded this year

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on October 22, 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 April 22, 2026 (131 days ago).

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FY 2024-05-31

LOW-RISK AUDITEE$170,689,228 federal awards expendedNo findings recorded this year

FAC accepted this audit on December 19, 2024 — management decision was due June 19, 2025.

FY 2023-05-31

LOW-RISK AUDITEE$172,089,717 federal awards expended

FAC accepted this audit on February 2, 2024 — management decision was due August 2, 2024.

2023-001
Special Tests & Provisions
OTHER MATTERS

FINDING 2023-001 FEDERAL PROGRAM INFORMATION: STUDENT FINANCIAL ASSISTANCE CLUSTER (ALN: Various) CRITERIA OR SPECIFIC REQUIREMENT (INCLUDING STATUTORY, REGULATORY OR OTHER CITATION): N. SPECIAL TESTS - RETURN OF TITLE IV FUNDS: PER CRF SECTION 668.22, WHEN RECIPIENTS OF TITLE IV FUNDS WITHDRAW, THE INSTITUTION MUST DETERMINE THE AMOUNT OF TITLE IV AID EARNED BY THE STUDENT AS OF THE STUDENT'S WITHDRAWAL DATE. IF THE TOTAL AMOUNT OF TITLE IV ASSISTANCE EARNED BY THE STUDENT IS LESS THAN THE AMOUNT THAT WAS DISBURSED TO THE STUDENT OR ON HIS OR HER BEHALF AS OF THE DATE OF THE INSTITUTION'S DETERMINATION THAT THE STUDENT WITHDREW, THE DIFFERENCE MUST BE RETURNED TO THE TITLE IV PROGRAMS WITHIN 45 DAYS. CONDITION: DURING OUR TESTING OF TITLE IV RETURNS, WE NOTED THE FOLLOWING EXCEPTION. FOR 1 OF THE 10 SELECTED STUDENTS THAT WITHDREW DURING FISCAL YEAR 2023, RETURNS WERE NOT RETURNED TO THE DEPARTMENT OF EDUCATION WITHIN THE REQUIRED 45 DAY TIMEFRAME. CAUSE: ADMINISTRATIVE OVERSIGHT WITH RESPECT TO RETURN OF TITLE IV FUNDS REQUIREMENTS. EFFECT OR POTENTIAL EFFECT: THE UNIVERSITY IS NOT PROPERLY FOLLOWING ITS POLICIES AND PROCEDURES IN PLACE TO ENSURE THAT COMPLIANCE IS MAINTAINED WITH ALL ASPECTS OF THE RETURN OF TITLE IV FUNDS REQUIREMENTS. QUESTIONED COSTS: NONE. CONTEXT: WE TESTED A SAMPLE OF 10 STUDENTS AND FOUND 1 EXCEPTION AS NOTED IN THE CONDITION. THIS IS A CONDITION IDENTIFIED PER REVIEW OF THE UNIVERSITY'S COMPLIANCE WITH SPECIFIED REQUIREMENTS USING A STATISTICALLY VALID SAMPLE. REPEAT FINDING: THERE WAS NO SIMILAR FINDING FOR THE PRIOR YEAR. RECOMMENDATION: WE RECOMMEND THAT THE UNIVERSITY ENHANCE PROCEDURES TO ENSURE THAT ALL FUNDS REQUIRED TO BE RETURNED FOR STUDENTS THAT HAVE WITHDRAWN ARE RETURNED TIMELY. VIEWS OF RESPONSIBLE OFFICIALS: THE UNIVERSITY CURRENTLY USES AN AUTOMATED WITHDRAWAL PROCESS FOR MAIN-CAMPUS UNDERGRADUATE STUDENTS. TO REMAIN COMPLIANT WITH RETURN OF TITLE IV REGULATIONS, THE OFFICE OF FINANCIAL AID WILL ENGAGE WITH ALL ACADEMIC LEVELS AND DEPARTMENTS ON CAMPUS AND ENCOURAGE THE USE OF THE AUTOMATED WITHDRAWAL PROCESS. THIS WILL ENSURE THE OFFICE OF FINANCIAL AID IS MADE AWARE WHEN A STUDENT IS NO LONGER ATTENDING THE UNIVERSITY AND CAN PROCESS THE R2T4 WITHIN REQUIRED TIMELINES.

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FINDING 2023-001 FEDERAL PROGRAM INFORMATION: STUDENT FINANCIAL ASSISTANCE CLUSTER (ALN: Various) CRITERIA OR SPECIFIC REQUIREMENT (INCLUDING STATUTORY, REGULATORY OR OTHER CITATION): N. SPECIAL TESTS - RETURN OF TITLE IV FUNDS: PER CRF SECTION 668.22, WHEN RECIPIENTS OF TITLE IV FUNDS WITHDRAW, THE INSTITUTION MUST DETERMINE THE AMOUNT OF TITLE IV AID EARNED BY THE STUDENT AS OF THE STUDENT'S WITHDRAWAL DATE. IF THE TOTAL AMOUNT OF TITLE IV ASSISTANCE EARNED BY THE STUDENT IS LESS THAN THE AMOUNT THAT WAS DISBURSED TO THE STUDENT OR ON HIS OR HER BEHALF AS OF THE DATE OF THE INSTITUTION'S DETERMINATION THAT THE STUDENT WITHDREW, THE DIFFERENCE MUST BE RETURNED TO THE TITLE IV PROGRAMS WITHIN 45 DAYS. CONDITION: DURING OUR TESTING OF TITLE IV RETURNS, WE NOTED THE FOLLOWING EXCEPTION. FOR 1 OF THE 10 SELECTED STUDENTS THAT WITHDREW DURING FISCAL YEAR 2023, RETURNS WERE NOT RETURNED TO THE DEPARTMENT OF EDUCATION WITHIN THE REQUIRED 45 DAY TIMEFRAME. CAUSE: ADMINISTRATIVE OVERSIGHT WITH RESPECT TO RETURN OF TITLE IV FUNDS REQUIREMENTS. EFFECT OR POTENTIAL EFFECT: THE UNIVERSITY IS NOT PROPERLY FOLLOWING ITS POLICIES AND PROCEDURES IN PLACE TO ENSURE THAT COMPLIANCE IS MAINTAINED WITH ALL ASPECTS OF THE RETURN OF TITLE IV FUNDS REQUIREMENTS. QUESTIONED COSTS: NONE. CONTEXT: WE TESTED A SAMPLE OF 10 STUDENTS AND FOUND 1 EXCEPTION AS NOTED IN THE CONDITION. THIS IS A CONDITION IDENTIFIED PER REVIEW OF THE UNIVERSITY'S COMPLIANCE WITH SPECIFIED REQUIREMENTS USING A STATISTICALLY VALID SAMPLE. REPEAT FINDING: THERE WAS NO SIMILAR FINDING FOR THE PRIOR YEAR. RECOMMENDATION: WE RECOMMEND THAT THE UNIVERSITY ENHANCE PROCEDURES TO ENSURE THAT ALL FUNDS REQUIRED TO BE RETURNED FOR STUDENTS THAT HAVE WITHDRAWN ARE RETURNED TIMELY. VIEWS OF RESPONSIBLE OFFICIALS: THE UNIVERSITY CURRENTLY USES AN AUTOMATED WITHDRAWAL PROCESS FOR MAIN-CAMPUS UNDERGRADUATE STUDENTS. TO REMAIN COMPLIANT WITH RETURN OF TITLE IV REGULATIONS, THE OFFICE OF FINANCIAL AID WILL ENGAGE WITH ALL ACADEMIC LEVELS AND DEPARTMENTS ON CAMPUS AND ENCOURAGE THE USE OF THE AUTOMATED WITHDRAWAL PROCESS. THIS WILL ENSURE THE OFFICE OF FINANCIAL AID IS MADE AWARE WHEN A STUDENT IS NO LONGER ATTENDING THE UNIVERSITY AND CAN PROCESS THE R2T4 WITHIN REQUIRED TIMELINES.

Corrective Action Plan

CORRECTIVE ACTION: THE UNIVERSITY CURRENTLY USES AN AUTOMATED WITHDRAWAL PROCESS FOR MAIN-CAMPUS UNDERGRADUATE STUDENTS. TO REMAIN COMPLIANT WITH RETURN OF TITLE IV REGULATIONS, THE OFFICE OF FINANCIAL AID WILL ENGAGE WITH ALL ACADEMIC LEVELS AND DEPARTMENTS ON CAMPUS AND ENCOURAGE THE USE OF THE AUTOMATED WITHDRAWAL PROCESS. THIS WILL ENSURE THE OFFICE OF FINANCIAL AID IS MADE AWARE WHEN A STUDENT IS NO LONGER ATTENDING THE UNIVERSITY AND CAN PROCESS THE R2T4 WITHIN REQUIRED TIMELINES. ANTICIPATED COMPLETION DATE: MAY 31, 2024. INDIVIDUALS RESPONSIBLE FOR CORRECTIVE ACTION PLAN: PRESTON DODSON, DIRECTOR OF FINANCIAL AID.

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FY 2022-05-31

LOW-RISK AUDITEE$186,747,252 federal awards expendedNo findings recorded this year

FAC accepted this audit on February 27, 2023 — management decision was due August 27, 2023.

FY 2021-05-31

LOW-RISK AUDITEE$123,274,863 federal awards expendedNo findings recorded this year

FAC accepted this audit on February 10, 2022 — management decision was due August 10, 2022.

FY 2020-05-31

LOW-RISK AUDITEE$121,493,869 federal awards expended

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

2020-001
Special Tests & Provisions
REPEAT OF 2019-002OTHER MATTERS

The University provided supporting documentation from the Colleague system that the students were submitted to the NSLDS in a batch. However, we were unable to obtain corroborating evidence from NSLDS to confirm that the students were added to the University?s Transfer Monitoring list. Cause: The University did not retain evidence from the NSLDS regarding the timing of submission of transfer students to NSLDS. Effect: The University is not in compliance with required federal guidelines. Questioned Costs: None. Context: For the sample of 18 students, the auditor was unable to determine the date on which students were added to the transfer monitoring list. Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2019-002 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University implement policies to obtain and retain documentation of the date that all transfer students are added to the NSLDS alert list.

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Federal Program Information: Student Financial Assistance Cluster (various CFDA #?s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Disbursements to or on Behalf of Students: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the NSLDS Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will "monitor" those students on the school's "inform" list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it "informs" NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19). Condition: The University provided supporting documentation from the Colleague system that the students were submitted to the NSLDS in a batch. However, we were unable to obtain corroborating evidence from NSLDS to confirm that the students were added to the University?s Transfer Monitoring list. Cause: The University did not retain evidence from the NSLDS regarding the timing of submission of transfer students to NSLDS. Effect: The University is not in compliance with required federal guidelines. Questioned Costs: None. Context: For the sample of 18 students, the auditor was unable to determine the date on which students were added to the transfer monitoring list. Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2019-002 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University implement policies to obtain and retain documentation of the date that all transfer students are added to the NSLDS alert list.

Corrective Action Plan

Corrective Action: The institution is working with our Information Technology department and Ellucian to determine why we cannot verify on NSLDS that students that have been sent electronically in a batch process through Colleague are being put on the Transfer Monitoring list. Completion Date: May 31, 2021 Individuals Responsible for Corrective Action Plan Mary Otto Director of Financial Aid

Prior Finding References

2019-002

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FY 2019-05-31

LOW-RISK AUDITEE$119,533,215 federal awards expended

FAC accepted this audit on February 27, 2020 — management decision was due August 27, 2020.

2019-002
Special Tests & Provisions
REPEAT OF 2018-001OTHER MATTERS

Transfer monitoring procedures were not properly completed during the year ended May 31, 2019. The University was unable to provide documentation confirming the date transfer students were added to the NSLDS alert list as required. Questioned Costs:None. Context:For the sample of 14 students selected, the auditor was unable to determine the date on which students were added to the transfer monitoring list based on the information provided by the University. Effect: The University is not in compliance with required federal guidelines. Cause:The University did not retain evidence from the Colleague system or the NSLDS regarding the timing of submission of transfer students to NSLDS. Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2018-001 in the prior year schedule of findings and questioned costs.Recommendation: We recommend that the University implement policies to obtain and retain documentation of the date that all transfer students are added to the NSLDS alert list.Views of Responsible Officials and Planned Corrective Actions: Please refer to the accompanying management?s corrective action plan.

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Program Information: Student Financial Assistance Cluster (various CFDA #?s); Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation)- Special Tests and Provisions ? Disbursements to or on Behalf of Students: If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the NSLDS Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will "monitor" those students on the school's "inform" list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it "informs" NSLDS about a transfer student before disbursing Title IV aid to that student (34 CFR section 668.19).Condition:Transfer monitoring procedures were not properly completed during the year ended May 31, 2019. The University was unable to provide documentation confirming the date transfer students were added to the NSLDS alert list as required. Questioned Costs:None. Context:For the sample of 14 students selected, the auditor was unable to determine the date on which students were added to the transfer monitoring list based on the information provided by the University. Effect: The University is not in compliance with required federal guidelines. Cause:The University did not retain evidence from the Colleague system or the NSLDS regarding the timing of submission of transfer students to NSLDS. Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2018-001 in the prior year schedule of findings and questioned costs.Recommendation: We recommend that the University implement policies to obtain and retain documentation of the date that all transfer students are added to the NSLDS alert list.Views of Responsible Officials and Planned Corrective Actions: Please refer to the accompanying management?s corrective action plan.

Corrective Action Plan

Corrective Action: The University will strive to ensure that all Transfer students are coded as such and therefore they are subject to the Transfer Monitoring automated procedure that is run through our Colleague System.Completion Date: May 31, 2020. Individuals Responsible for Corrective Action Plan: Mary Otto, Director of Financial Aid

Prior Finding References

2018-001

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2019-003
Special Tests & Provisions
REPEAT OF 2018-003OTHER MATTERS

The University did not prepare certain students? return calculations properly. Questioned Costs:None. Context: Compliance exceptions identified for 3 of 27 students selected for withdrawal testing as follows: 1 of 27 students selected for withdrawal testing, the University incorrectly calculated the amount to return; 1 of 27 students selected for withdrawal testing, the University did not perform a R2T4 calculation as required; 1 of 27 students selected for withdrawal testing, the University did not adjust the student?s loan in COD accordingly.Effect: The University is not in compliance with required federal guidelines. Cause: Administrative oversight.Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2018-003 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University enhance its procedures surrounding the preparation and review of Return calculations to ensure compliance with the return of Title IV Funds requirements. Views of Responsible Officials and Planned Corrective Actions:Please refer to the accompanying management?s corrective action plan.

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Federal Program Information: Student Financial Assistance Cluster (various CFDA #?s)Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions ? Return of Title IV Funds - When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. Condition: The University did not prepare certain students? return calculations properly. Questioned Costs:None. Context: Compliance exceptions identified for 3 of 27 students selected for withdrawal testing as follows: 1 of 27 students selected for withdrawal testing, the University incorrectly calculated the amount to return; 1 of 27 students selected for withdrawal testing, the University did not perform a R2T4 calculation as required; 1 of 27 students selected for withdrawal testing, the University did not adjust the student?s loan in COD accordingly.Effect: The University is not in compliance with required federal guidelines. Cause: Administrative oversight.Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2018-003 in the prior year schedule of findings and questioned costs. Recommendation: We recommend that the University enhance its procedures surrounding the preparation and review of Return calculations to ensure compliance with the return of Title IV Funds requirements. Views of Responsible Officials and Planned Corrective Actions:Please refer to the accompanying management?s corrective action plan.

Corrective Action Plan

Corrective Action: The Financial Aid office will review procedures to ensure that loan fees are included in the recalculation of Federal Direct funds when returned to COD.Completion Date: May 31, 2020.Individuals Responsible for Corrective Action Plan: Mary Otto, Director of Financial Aid

Prior Finding References

2018-003

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2019-004
Cash Management
OTHER MATTERS

An instance was identified where funds drawn were held in excess of the allowable time frame.Questioned Costs: None. Context: We observed a reversal of awards to student accounts totaling $7,988 on August 7, 2019, which caused an excess in cash drawn from G5 compared to total cash disbursed to students of $7,988. There were further reversals of awards on August 13, 2019 of $6,494 which caused the total cash drawn in excess of cash disbursed to increase to $14,482. The University subsequently credited student accounts on August 22, 2019 and did not draw additional funds from G5 related to this disbursement. Effect: The University is not in compliance with Cash Management compliance requirements.Cause: Awards were decreased due to student enrollment changes subsequent to draw down.Identification as a Repeat Finding: No similar finding was identified during the 2018 audit. Recommendation: We recommend the University monitor reversals of Federal awards due to enrollment in order to timely identify draws in excess of awards disbursed.Views of Responsible Officials and Planned Corrective Actions: Please refer to the accompanying management?s corrective action plan.

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Federal Program Information: Federal Direct Student Loan Program (CFDA #84.268)Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution?s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student?s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the ?ED?) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution?s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)).Condition: An instance was identified where funds drawn were held in excess of the allowable time frame.Questioned Costs: None. Context: We observed a reversal of awards to student accounts totaling $7,988 on August 7, 2019, which caused an excess in cash drawn from G5 compared to total cash disbursed to students of $7,988. There were further reversals of awards on August 13, 2019 of $6,494 which caused the total cash drawn in excess of cash disbursed to increase to $14,482. The University subsequently credited student accounts on August 22, 2019 and did not draw additional funds from G5 related to this disbursement. Effect: The University is not in compliance with Cash Management compliance requirements.Cause: Awards were decreased due to student enrollment changes subsequent to draw down.Identification as a Repeat Finding: No similar finding was identified during the 2018 audit. Recommendation: We recommend the University monitor reversals of Federal awards due to enrollment in order to timely identify draws in excess of awards disbursed.Views of Responsible Officials and Planned Corrective Actions: Please refer to the accompanying management?s corrective action plan.

Corrective Action Plan

Corrective Action: The finding relates to corrections placed on student accounts on August 7, 2019 in the amount of $7,988. These funds were not returned to the Department of Education within the required timeframe. On August 22, 2019 corrections of $7,988 and an additional correction on August 13, 2019 of $6,494 were absorbed by funds posted to student accounts on August 22, 2019. We receive a weekly report from the Bursar?s Office of direct lending drawdown requests. Our procedure is to closely monitor these weekly reports for corrections to determine if there are federal funds to be returned to the Department of Education and to return those funds within required timeframe.Completion Date: May 31, 2019. Individuals Responsible for Corrective Action Plan: Julie Byrd, University Comptroller

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2019-005
Special Tests & Provisions
OTHER MATTERS

The University did not submit the Federal Pell Grant Program payment data through the COD website within the required timeframes. Questioned Costs: None.Context: For 1 of 25 students selected for testing, the University did not properly report the disbursement to the COD website within the required timeframes. Effect: The University was not in compliance with COD reporting requirements. Cause: Administrative oversight with respect to Federal Pell Grant reporting requirements. Identification as a Repeat Finding:There was no similar finding for the year ended May 31, 2018.Recommendation: We recommend the University ensure that disbursement dates are entered into the COD website no earlier than 7 days before and no later than 15 days after disbursement as required by federal regulations.Views of Responsible Officials and Planned Corrective Actions: Please refer to the accompanying management?s corrective action plan.

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Federal Program Information: Federal Pell Grant Program (CFDA #84.063)Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Reporting ? Common Origination and Disbursement (?COD?) System: All institutions receiving Pell grants submit Pell payment data to the Department of Education through the COD System. Institutions must report student payment data no earlier than 7 days before and no later than 15 days after the institution makes a payment or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data (ED Notice, December 4, 2018, Federal Register (83 Federal Register 62566)).Condition: The University did not submit the Federal Pell Grant Program payment data through the COD website within the required timeframes. Questioned Costs: None.Context: For 1 of 25 students selected for testing, the University did not properly report the disbursement to the COD website within the required timeframes. Effect: The University was not in compliance with COD reporting requirements. Cause: Administrative oversight with respect to Federal Pell Grant reporting requirements. Identification as a Repeat Finding:There was no similar finding for the year ended May 31, 2018.Recommendation: We recommend the University ensure that disbursement dates are entered into the COD website no earlier than 7 days before and no later than 15 days after disbursement as required by federal regulations.Views of Responsible Officials and Planned Corrective Actions: Please refer to the accompanying management?s corrective action plan.

Corrective Action Plan

Corrective Action: SSCR error notifications will continue to be received from the National Student Clearinghouse through email notification and website notification. SSCR errors that are not able to be corrected individually via the National Student Clearinghouse will be escalated to correction with the NSLDS key holder on campus, Mary Otto, Director of Financial Aid. The Registrar?s office does not have access to NSLDS directly so we will provide the Director of Financial Aid the information that we can to notify NSLDS directly within the 10 day time requirement. Completion Date: Effective immediately Individuals Responsible for Corrective Action Plan Corrective Action: Karen Pore University Registrar

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2019-007
Procurement & Suspension/Debarment
OTHER MATTERS

The University?s purchasing policy was not in compliance with the Uniform Guidance. Cause: Administrative oversight. Effect: The University was not in compliance with Procurement requirements. Questioned Costs: None. Context: The University does not have a written procurement policy applicable to Federal awards. Identification as a Repeat Finding: No similar finding was identified during the 2018 audit. Recommendation: We recommend that the University implement a policy in compliance with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: The Office of Sponsored Research and Programs (OSRP) will work with the Business Office (BO) and the Office of the Provost (OP) to revise the current procurement policy or develop a separate policy and procedures pertaining to federal funding to comply with the Uniform Guidance. OSRP, BO, and OP will also develop best practices that define a systematic approach to implementing polices.

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Federal Program Information: Research and Development Cluster (various CFDA #?s); Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): I. Procurement and Suspension and Debarment ? The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity?s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Condition:The University?s purchasing policy was not in compliance with the Uniform Guidance. Cause: Administrative oversight. Effect: The University was not in compliance with Procurement requirements. Questioned Costs: None. Context: The University does not have a written procurement policy applicable to Federal awards. Identification as a Repeat Finding: No similar finding was identified during the 2018 audit. Recommendation: We recommend that the University implement a policy in compliance with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: The Office of Sponsored Research and Programs (OSRP) will work with the Business Office (BO) and the Office of the Provost (OP) to revise the current procurement policy or develop a separate policy and procedures pertaining to federal funding to comply with the Uniform Guidance. OSRP, BO, and OP will also develop best practices that define a systematic approach to implementing polices.

Corrective Action Plan

Corrective Action: The Office of Sponsored Research and Programs (OSRP) will work with the Business Office (BO) and the Office of the Provost (OP) to revise the current procurement policy or develop a separate policy and procedures pertaining to federal funding to comply with the Uniform Guidance. OSRP, BO, and OP will also develop best practices that define a systematic approach to implementing polices. Completion Date: May 31, 2020 Individuals Responsible for Corrective Action Plan Corrective Action: Vincenzo Cassella Director, Office of Sponsored Research and Programs

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FY 2018-05-31

LOW-RISK AUDITEE$119,739,829 federal awards expended

FAC accepted this audit on February 27, 2019 — management decision was due August 27, 2019.

2018-001
Special Tests & Provisions
OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2018-002
Special Tests & Provisions
OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2018-003
Special Tests & Provisions
REPEAT OF 2017-001OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-001

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2018-004
Eligibility
QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2018-008
Subrecipient Monitoring
OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2018-009
Activities Allowed or Unallowed
QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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FY 2017-05-31

LOW-RISK AUDITEE$119,791,367 federal awards expended

FAC accepted this audit on February 15, 2018 — management decision was due August 15, 2018.

2017-001
Special Tests & Provisions
QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2017-002
Special Tests & Provisions
REPEAT OF 2016-002OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-002

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FY 2016-05-31

LOW-RISK AUDITEE$107,875,188 federal awards expended

FAC accepted this audit on February 7, 2017 — management decision was due August 7, 2017.

2016-001
Special Tests & Provisions
REPEAT OF 2015-003OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2015-003

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2016-002
Special Tests & Provisions
REPEAT OF 2015-004OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2015-004

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