EIN: 566049935
UEI: KZTTVNK9L8C1
Audited by: BDO USA, P.C.
Oversight agency: 84 [Department of Education]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 9, 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 March 9, 2026 (175 days ago).
What is a management decision? →FAC accepted this audit on December 20, 2024 — management decision was due June 20, 2025.
N. Special Tests and Provisions – Enrollment Reporting Information on Federal Program(s) - Student Financial Assistance Cluster (Federal Assistance Listing #84.063 and #84.268) Criteria or Specific Requirement - Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Campus Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month. Program Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including OPEID number, CIP code, CIP year, credit level, program enrollment status, program enrollment effective date, program length, and program begin date. Condition – During our testing of student enrollment reporting, we noted the following exceptions at the campus level and program level: Campus Level: For 2 students selected for testing, the University did not report enrollment status changes within the required time frames. Program Level: For 1 student selected for testing, the University did not correctly report all program enrollment data elements to NSLDS. Cause – Administrative oversight in internal controls over enrollment reporting requirements. Effect or Potential Effect – The University was not in compliance with the enrollment reporting requirements. Questioned Costs – None. Context – The context at the campus level and program is as follows: Campus Level: 2 of 25 students selected for testing. Program Level: 1 of 25 students selected for testing. Indication of Repeat Finding – There was no similar finding identified during the prior year. Recommendation – We recommend that the University enhance its procedures and its internal controls over enrollment reporting requirements. Views of Responsible Officials – It was identified during the Student Financial Aid audit that Wingate University (WU) is out of compliance with the enrollment reporting requirements for two students (one student at the campus level and one student at both the campus level and program level). We currently contract with the National Student Clearinghouse (NSC) for enrollment reporting and have identified the compliance issue to be a disconnect between the reporting requirements in place with NSC and WU Institutional policy. For each identified student, the student was permitted by WU policy to complete their degree requirements after the end of the academic term. When reporting the Graduated status in NSC, the Registrar is required to select the last date of the term as the Graduation Date instead of the date the student actually completed their degree requirements. When this occurs more than 60 days from the end of the term, the student is noted as out of compliance with reporting requirements due to the limitation identified with NSC. The Registrar and Director of Financial Aid will work with NSC to identify a solution for reporting the actual completion date for a student when it occurs after the conclusion of the standard term and outside of the reporting definitions offered by NSC. If a viable solution cannot be identified with NSC, we will establish a policy to manually update data in NSLDS for impacted students to meet the 60-day reporting requirements for enrollment status changes.
Show full finding ▾Hide full finding ▴N. Special Tests and Provisions – Enrollment Reporting Information on Federal Program(s) - Student Financial Assistance Cluster (Federal Assistance Listing #84.063 and #84.268) Criteria or Specific Requirement - Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the SFA Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Campus Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). At a minimum, institutions are required to certify enrollment every 60 days or every other month. Program Level: Institutions are responsible for accurately and timely reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including OPEID number, CIP code, CIP year, credit level, program enrollment status, program enrollment effective date, program length, and program begin date. Condition – During our testing of student enrollment reporting, we noted the following exceptions at the campus level and program level: Campus Level: For 2 students selected for testing, the University did not report enrollment status changes within the required time frames. Program Level: For 1 student selected for testing, the University did not correctly report all program enrollment data elements to NSLDS. Cause – Administrative oversight in internal controls over enrollment reporting requirements. Effect or Potential Effect – The University was not in compliance with the enrollment reporting requirements. Questioned Costs – None. Context – The context at the campus level and program is as follows: Campus Level: 2 of 25 students selected for testing. Program Level: 1 of 25 students selected for testing. Indication of Repeat Finding – There was no similar finding identified during the prior year. Recommendation – We recommend that the University enhance its procedures and its internal controls over enrollment reporting requirements. Views of Responsible Officials – It was identified during the Student Financial Aid audit that Wingate University (WU) is out of compliance with the enrollment reporting requirements for two students (one student at the campus level and one student at both the campus level and program level). We currently contract with the National Student Clearinghouse (NSC) for enrollment reporting and have identified the compliance issue to be a disconnect between the reporting requirements in place with NSC and WU Institutional policy. For each identified student, the student was permitted by WU policy to complete their degree requirements after the end of the academic term. When reporting the Graduated status in NSC, the Registrar is required to select the last date of the term as the Graduation Date instead of the date the student actually completed their degree requirements. When this occurs more than 60 days from the end of the term, the student is noted as out of compliance with reporting requirements due to the limitation identified with NSC. The Registrar and Director of Financial Aid will work with NSC to identify a solution for reporting the actual completion date for a student when it occurs after the conclusion of the standard term and outside of the reporting definitions offered by NSC. If a viable solution cannot be identified with NSC, we will establish a policy to manually update data in NSLDS for impacted students to meet the 60-day reporting requirements for enrollment status changes.
Name of Responsible Individual: Maria Taylor, Registrar & Jenn Hall, Director of Financial Aid Corrective Action: It was identified during the Student Financial Aid audit that Wingate University (WU) is out of compliance with the enrollment reporting requirements for two students (one student at the campus level and one student at both the campus level and program level). We currently contract with the National Student Clearinghouse (NSC) for enrollment reporting and have identified the compliance issue to be a disconnect between the reporting requirements in place with NSC and WU Institutional policy. For each identified student, the student was permitted by WU policy to complete their degree requirements after the end of the academic term. When reporting the Graduated status in NSC, the Registrar is required to select the last date of the term as the Graduation Date instead of the date the student actually completed their degree requirements. When this occurs more than 60 days from the end of the term, the student is noted as out of compliance with reporting requirements due to the limitation identified with NSC. The Registrar and Director of Financial Aid will work with NSC to identify a solution for reporting the actual completion date for a student when it occurs after the conclusion of the standard term and outside of the reporting definitions offered by NSC. If a viable solution cannot be identified with NSC, we will establish a policy to manually update data in NSLDS for impacted students to meet the 60-day reporting requirements for enrollment status changes. Anticipated Completion Date: May 31, 2025
FAC accepted this audit on December 8, 2023 — management decision was due June 8, 2024.
Instances were identified where FWS Program funds drawn were held in excess of the allowable time frame. Cause: Administrative and internal control oversight with respect to cash management. Effect or Potential Effect: The University is not in compliance with cash management compliance requirements. Questioned Costs: None. Context: 3 instances of cash held in excess of the allowable time frame were identified for the FWS Program for the current year. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2022-005 in the 2022 report. Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that excess cash is returned timely. Views of Responsible Officials: The University Business Office and Financial Planning Office will review the institutional cash management policies and ensure the proper controls are in place to eliminate instances of excess cash. An additional step will be added to the process that will require CFO review and approval of calculations of draw-down amounts.
Show full finding ▾Hide full finding ▴Federal Program Information: Federal Work-Study (“FWS”) Program (ALN 84.033) Criteria or Specific Requirement: C. 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: Instances were identified where FWS Program funds drawn were held in excess of the allowable time frame. Cause: Administrative and internal control oversight with respect to cash management. Effect or Potential Effect: The University is not in compliance with cash management compliance requirements. Questioned Costs: None. Context: 3 instances of cash held in excess of the allowable time frame were identified for the FWS Program for the current year. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2022-005 in the 2022 report. Recommendation: We recommend the University enhance its policies, procedures and internal controls to ensure that excess cash is returned timely. Views of Responsible Officials: The University Business Office and Financial Planning Office will review the institutional cash management policies and ensure the proper controls are in place to eliminate instances of excess cash. An additional step will be added to the process that will require CFO review and approval of calculations of draw-down amounts.
Name of Responsible Individual: Jenn Hall, Director of Financial Planning and Kristi Furr, Controller Corrective Action: The University Business Office and Financial Planning Office will review the institutional cash management policies and ensure the proper controls are in place to eliminate instances of excess cash. An additional step will be added to the process that will require CFO review and approval of calculations of draw-down amounts. Anticipated Completion Date: December 31, 2023
2022-005
FAC accepted this audit on January 30, 2023 — management decision was due July 30, 2023.
Certain borrowers did not receive a loan disbursement notification or did not receive notification timely. Cause: Insufficient internal controls and administrative oversight with respect to loan disbursement notifications. Effect or Potential Effect: Borrowers were not notified of loan disbursements and/or their right to cancel/decline loan awards or were not notified in a timely manner. Questioned Costs: None. Context: For 4 of 25 disbursements selected for testing, the University did not send the disbursement notification within the required timeframe. For 7 of 25 disbursements selected for testing, the University was unable to provide documentation showing that a notification was sent to the borrower as required. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over loan disbursement notifications to ensure that such notifications are sent to student and/or parent borrowers within the required timeframe. Views of Responsible Officials: The Financial Planning Office has reviewed the loan disbursement notification process to ensure that notices are sent in a timely manner to needed recipients. After a review of the 2021-2022 award cycle, it was determined that an application ID was missing from the Direct PLUS Loan file that prevented the disbursement notification from being issued to the Parent borrower in some instances. Internal controls have been put in place for the 2022-2023 award cycle and beyond so that this data element is accurately assigned.
Show full finding ▾Hide full finding ▴Federal Program Information: Federal Direct Student Loan Program (ALN#: 84.268) Criteria or Specific Requirement: N. Special Test and Provisions ? Disbursements To or On Behalf of Students ? Loan Disbursement Notification - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (?FSA?) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student?s account. Condition: Certain borrowers did not receive a loan disbursement notification or did not receive notification timely. Cause: Insufficient internal controls and administrative oversight with respect to loan disbursement notifications. Effect or Potential Effect: Borrowers were not notified of loan disbursements and/or their right to cancel/decline loan awards or were not notified in a timely manner. Questioned Costs: None. Context: For 4 of 25 disbursements selected for testing, the University did not send the disbursement notification within the required timeframe. For 7 of 25 disbursements selected for testing, the University was unable to provide documentation showing that a notification was sent to the borrower as required. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures over loan disbursement notifications to ensure that such notifications are sent to student and/or parent borrowers within the required timeframe. Views of Responsible Officials: The Financial Planning Office has reviewed the loan disbursement notification process to ensure that notices are sent in a timely manner to needed recipients. After a review of the 2021-2022 award cycle, it was determined that an application ID was missing from the Direct PLUS Loan file that prevented the disbursement notification from being issued to the Parent borrower in some instances. Internal controls have been put in place for the 2022-2023 award cycle and beyond so that this data element is accurately assigned.
Name of Responsible Individual: Jenn Hall, Director of Financial Planning and Sara Benes, Associate Director of Financial Planning Corrective Action: The Financial Planning Office has reviewed the loan disbursement notification process to ensure that notices are sent in a timely manner to needed recipients. After a review of the 2021-2022 award cycle, it was determined that an application ID was missing from the Direct PLUS Loan file that prevented the disbursement notification from being issued to the Parent borrower in some instances. Internal controls have been put in place for the 2022-2023 award cycle and beyond so that this data element is accurately assigned. Anticipated Completion Date: December 31, 2022
For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified. Cause: Insufficient internal controls and administrative oversight with respect to verification requirements. Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations and the University was not in compliance with verification compliance requirements. Questioned Costs: None. Context: For 6 of 25 students selected for testing, the University did not complete appropriate verification procedures prior to disbursing aid. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance is procedures and internal controls to ensure that students are verified as required. Views of Responsible Officials: The Financial Planning Office has reviewed the verification policies and added a supervisory review process and internal audit of verification records. Additional staff training will be provided to help team members identify potential instances of noncompliance.
Show full finding ▾Hide full finding ▴Federal Program Information: Student Financial Assistance Cluster: Federal Supplemental Education Opportunity Grants (Assistance Listing #84.007), Federal Work-Study Program (Assistance Listing #84.033), Federal Pell Grant Program (Assistance Listing #84.063), Federal Direct Loan Program (Assistance Listing #84.268) Criteria or Specific Requirement: N. Special Tests and Provisions ? Verification: For students selected for verification by the central processor, the University must obtain acceptable documentation to verify the information required, match information on the documentation to the student aid application, and, if necessary, submit data corrections to the central processor and recalculate awards (34 CFR Part 668 Subpart E). Condition: For certain students selected for verification, the information required to be verified either did not match the underlying supporting documentation (including certain tax information) or was not verified. Cause: Insufficient internal controls and administrative oversight with respect to verification requirements. Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations and the University was not in compliance with verification compliance requirements. Questioned Costs: None. Context: For 6 of 25 students selected for testing, the University did not complete appropriate verification procedures prior to disbursing aid. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance is procedures and internal controls to ensure that students are verified as required. Views of Responsible Officials: The Financial Planning Office has reviewed the verification policies and added a supervisory review process and internal audit of verification records. Additional staff training will be provided to help team members identify potential instances of noncompliance.
Name of Responsible Individual: Jenn Hall, Director of Financial Planning Corrective Action: The Financial Planning Office has reviewed the verification policies and added a supervisory review process and internal audit of verification records. Additional staff training will be provided to help team members identify potential instances of noncompliance. Anticipated Completion Date: December 31, 2022
For certain students identified through our testing, the University did not issue a refund for a credit balance to the student within 14 days of the credit balance occurring as required. Cause: Administrative oversight with respect to the credit balance refund requirements. Effect or Potential Effect: The University is not in compliance with Title IV HEA refund requirements. Questioned Costs: None. Context: For 2 of 25 student refunds selected for testing, the University did not issue the refund within 14 days of the credit balance occurring as required. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhance its procedures to ensure that credit refunds are disbursed to students as soon as possible, but no later than 14 days after the credit balance occurs. Views of Responsible Officials: The University Business Office and Financial Planning Office will review the institutional refund policies and put the proper controls in place to disburse Title IV credit balances to students/parents in the required timeframe.
Show full finding ▾Hide full finding ▴Federal Program Information: Student Financial Aid Cluster (various ALN #?s) Criteria or Specific Requirement: N. Special Tests and Provisions ? Credit Balances ? Federal regulations (34 CFR 668.164(h)) state that when a Title IV Higher Education Act (?HEA?) credit balance occurs on a student?s account, the University must be pay the balance directly to the students or parents as soon as possible, but no later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period, or 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: For certain students identified through our testing, the University did not issue a refund for a credit balance to the student within 14 days of the credit balance occurring as required. Cause: Administrative oversight with respect to the credit balance refund requirements. Effect or Potential Effect: The University is not in compliance with Title IV HEA refund requirements. Questioned Costs: None. Context: For 2 of 25 student refunds selected for testing, the University did not issue the refund within 14 days of the credit balance occurring as required. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend that the University enhance its procedures to ensure that credit refunds are disbursed to students as soon as possible, but no later than 14 days after the credit balance occurs. Views of Responsible Officials: The University Business Office and Financial Planning Office will review the institutional refund policies and put the proper controls in place to disburse Title IV credit balances to students/parents in the required timeframe.
Name of Responsible Individual: Jenn Hall, Director of Financial Planning and Kristi Furr, Controller Corrective Action: The University Business Office and Financial Planning Office will review the institutional refund policies and put the proper controls in place to disburse Title IV credit balances to students/parents in the required timeframe. Anticipated Completion Date: December 31, 2022
A student was disbursed FSEOG funds during the year who was not eligible to receive a Federal Pell Grant while there were other Federal Pell Grant recipients who were not awarded FSEOG funds. Cause: Administrative oversight with respect to awarding of FSEOG awards. Effect or Potential Effect: The University is not in compliance with prioritizing the awarding of FSEOG funds to Federal Pell Grant recipients. Questioned Costs: None. Context: 1 student out of 136 SEOG recipients was not also a Federal Pell Grant recipient. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures to ensure FSEOG awards are going first to Federal Pell Grant recipients. Views of Responsible Officials: The Financial Planning Office has reviewed its policies surrounding FSEOG awarding and added additional quality control measures for the 2022-2023 award cycle so that FSEOG funding is provided solely to PELL recipients.
Show full finding ▾Hide full finding ▴Federal Program Information: Federal Supplemental Education Opportunity Grants (?FSEOG?) (ALN# 84.007) Criteria or Specific Requirement: E. Eligibility ? Selection of Students for FSEOG awards ? Federal regulations (34 CFR 676.10) require that in selecting among eligible students for FSEOG awards in each award year, the University is required to select those students with the lowest expected family contributions who will also receive Federal Pell Grants in that year. Only if the University has awarded FSEOG awards to all the Federal Pell Grant recipients can they award to FSEOG funds to those eligible students with the lowest expected family contributions who did not receive Federal Pell Grants. Condition: A student was disbursed FSEOG funds during the year who was not eligible to receive a Federal Pell Grant while there were other Federal Pell Grant recipients who were not awarded FSEOG funds. Cause: Administrative oversight with respect to awarding of FSEOG awards. Effect or Potential Effect: The University is not in compliance with prioritizing the awarding of FSEOG funds to Federal Pell Grant recipients. Questioned Costs: None. Context: 1 student out of 136 SEOG recipients was not also a Federal Pell Grant recipient. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its procedures to ensure FSEOG awards are going first to Federal Pell Grant recipients. Views of Responsible Officials: The Financial Planning Office has reviewed its policies surrounding FSEOG awarding and added additional quality control measures for the 2022-2023 award cycle so that FSEOG funding is provided solely to PELL recipients.
Name of Responsible Individual: Jenn Hall, Director of Financial Planning Corrective Action: The Financial Planning Office has reviewed its policies surrounding FSEOG awarding and added additional quality control measures for the 2022-2023 award cycle so that FSEOG funding is provided solely to PELL recipients. Anticipated Completion Date: December 31, 2022
Instances were identified where funds drawn were held in excess of the allowable time frame. Cause: Administrative oversight with respect to cash management. Effect or Potential Effect: The University is not in compliance with Cash Management compliance requirements. Questioned Costs: None. Context: 1 instance of cash held in excess of the allowable time frame was identified for each Federal program. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its policies and procedures to ensure that excess cash is returned timely. Views of Responsible Officials: The University Business Office and Financial Planning Office will review the institutional cash management policies and ensure the proper controls are in place to eliminate instances of excess cash.
Show full finding ▾Hide full finding ▴Federal Program Information: Federal Supplemental Educational Opportunity Grants (FSEOG) (ALN 84.007), Federal Work-Study Program (ALN 84.033), Federal Direct Student Loan Program (ALN 84.268) Criteria or Specific Requirement: C. 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: Instances were identified where funds drawn were held in excess of the allowable time frame. Cause: Administrative oversight with respect to cash management. Effect or Potential Effect: The University is not in compliance with Cash Management compliance requirements. Questioned Costs: None. Context: 1 instance of cash held in excess of the allowable time frame was identified for each Federal program. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the University enhance its policies and procedures to ensure that excess cash is returned timely. Views of Responsible Officials: The University Business Office and Financial Planning Office will review the institutional cash management policies and ensure the proper controls are in place to eliminate instances of excess cash.
Name of Responsible Individual: Jenn Hall, Director of Financial Planning and Kristi Furr, Controller Corrective Action: The University Business Office and Financial Planning Office will review the institutional cash management policies and ensure the proper controls are in place to eliminate instances of excess cash. Anticipated Completion Date: December 31, 2022
FAC accepted this audit on November 28, 2021 — management decision was due May 28, 2022.
FAC accepted this audit on October 20, 2020 — management decision was due April 20, 2021.
FAC accepted this audit on November 14, 2019 — management decision was due May 14, 2020.
The University did not have formal written policies in place nor document safeguards for identified risk areas noted in 16 CFR 314.4 (b), as defined above. Cause: The University engaged a third-party to assist with the risk assessment process but failed to formally document policies and procedures, as well as safeguards, that address the requirements under the Gramm-Leach-Bliley Act, specifically the risk areas noted in 16 CFR 314.4 (b), as defined above. Effect of potential effect: The University is not in compliance with the requirements defined above. Questioned costs: None Context: We inquired with University personnel, particularly the Executive Director of Student Financial Planning and the Chief Information Officer ? Information Technology Services, regarding the University?s compliance with the provisions of the Gramm-Leach-Bliley Act. We requested copies of documented policies and procedures that addressed the three areas noted in 16 CFR 314.4 (b), which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures, and documented safeguards for identified risks. It was noted that the University did not have adequate policies and procedures documented to address the risk areas defined above. Repeat Finding: No Recommendation: We recommend that the University formally document its policies and procedures that address the requirements of the Gramm-Leach-Bliley Act, as defined above. Views of responsible officials: Refer to the University?s Corrective Action Plan.
Show full finding ▾Hide full finding ▴-001: Gramm-Leach-Bliley Act ? Student Information Security Identification of the federal program: U.S. Department of Education Student Financial Aid Cluster Criteria or specific requirement: Uniform Guidance for Student Financial Aid (SFA) Programs {III. Compliance Requirements, N. Special Tests and Provisions, 10. Gramm-Leach-Bliley Act ? Student Information Security (16 CFR 313 and 314) stipulates that under the Gramm-Leach-Bliley Act (Public Law 106-102), financial institutions are required to explain their information-sharing practices to their customers and to safeguard sensitive data. The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the Gramm-Leach-Bliley Act. Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Institutions should perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b), which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures, and documented safeguards for identified risks. Condition: The University did not have formal written policies in place nor document safeguards for identified risk areas noted in 16 CFR 314.4 (b), as defined above. Cause: The University engaged a third-party to assist with the risk assessment process but failed to formally document policies and procedures, as well as safeguards, that address the requirements under the Gramm-Leach-Bliley Act, specifically the risk areas noted in 16 CFR 314.4 (b), as defined above. Effect of potential effect: The University is not in compliance with the requirements defined above. Questioned costs: None Context: We inquired with University personnel, particularly the Executive Director of Student Financial Planning and the Chief Information Officer ? Information Technology Services, regarding the University?s compliance with the provisions of the Gramm-Leach-Bliley Act. We requested copies of documented policies and procedures that addressed the three areas noted in 16 CFR 314.4 (b), which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures, and documented safeguards for identified risks. It was noted that the University did not have adequate policies and procedures documented to address the risk areas defined above. Repeat Finding: No Recommendation: We recommend that the University formally document its policies and procedures that address the requirements of the Gramm-Leach-Bliley Act, as defined above. Views of responsible officials: Refer to the University?s Corrective Action Plan.
Identifying Number: 2019-001 ? Gramm-Leach-Bliley Act ? Student Information Security Finding: The University did not have formal written policies in place to document safeguards for identified risk areas noted in 16 CFR 314.4 (b), during the year subject to audit. The three areas that are required to be addressed by the standard are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures, and documented safeguards for identified risks. Anticipated Completion Date: May 31, 2020 University Official Responsible for Corrective Action: William Durham, Vice President for Finance Corrective Action Taken or Planned: In order to assess compliance with the Gramm-LeachBiley Act, the University commissioned an independent third party to review compliance with the Act. The results of the assessment indicated that the University needed to document its current practices into formal policies and procedures. The University has been fortunate to have virtually no turnover in departments that directly oversee the ultimate protection of this information. Both the Offices of Financial Planning and Information Technology are in the process of updating documentation related to their current internal practices and will formalize policies and procedures that clearly articulate and address all of the key risk areas, including employee training and management, information systems and detecting, preventing and responding to attacks, intrusions or other system failures and documenting safeguards for identified risks.
FAC accepted this audit on October 28, 2018 — management decision was due April 28, 2019.
FAC accepted this audit on October 16, 2017 — management decision was due April 16, 2018.
FAC accepted this audit on September 29, 2016 — management decision was due March 29, 2017.
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