EIN: 580566212
UEI: NGYMABXHNT49
Audited by: CliftonLarsonAllen LLP
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 March 31, 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 October 1, 2026 (33 days from today).
What is a management decision? →FAC accepted this audit on March 31, 2025 — management decision was due October 1, 2025.
FAC accepted this audit on January 30, 2024 — management decision was due July 30, 2024.
The University was not in compliance with GLBA. Questioned costs: None Context: These new GLBA requirements were applicable beginning on June 9, 2023 and we identified that the organization does not meet the compliance requirements outlined in the GLBA Safeguards Rule. Specifically, discrepancies were identified in requirement B.3, pertaining to the implementation of periodic review and implementation of user access controls, encryption controls, the use of multi-factor authentication, and change management policy. Furthermore, it was noted that the written information security program (WISP) lacked any mention of penetration testing or vulnerability scans. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal agency: Department of Education Federal program title: Student Financial Aid Cluster Assistance Listing Number: 84.033, 84.063, 84.007, 84.379, 84.268 Federal Award Identification Number and Year: P033A223771 (CWS 22‐23), P063P220377 (Pell 22‐23), P007A223771 (SEOG 22‐23), P379T230377 (Teach 22‐23), P268K230377 (Direct Loan 2023) Award Period: July 1, 2022, through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program (WISP) for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act (GLBA), 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. Condition: The University was not in compliance with GLBA. Questioned costs: None Context: These new GLBA requirements were applicable beginning on June 9, 2023 and we identified that the organization does not meet the compliance requirements outlined in the GLBA Safeguards Rule. Specifically, discrepancies were identified in requirement B.3, pertaining to the implementation of periodic review and implementation of user access controls, encryption controls, the use of multi-factor authentication, and change management policy. Furthermore, it was noted that the written information security program (WISP) lacked any mention of penetration testing or vulnerability scans. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.
Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend that the College review the updated GLBA requirements and ensure their written information security program (WISP) includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: Non-compliance with GLBA Action taken in response to finding: Management has already taken action and developed a written information security plan and will implement the written policy that includes all the required elements. Name(s) of the contact person(s) responsible for corrective action: Brant Wright Planned completion date for corrective action plan: December 31, 2023
FAC accepted this audit on November 29, 2022 — management decision was due May 29, 2023.
The University is updating NSLDS records for students manually but does not ensure that roster files updates are complete and timely. During our testing, we noted 7 out of the 12 rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. Questioned costs: None. Context: 7 out of 12 enrollment rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. Cause: Lack of appropriate policy and procedure in place regarding enrollment roster certifying for the year under audit. Effect: Non-compliance with federal regulations which could lead to untimely reporting of enrollment information to NSLDS. Repeat Finding: Yes, 2021-003 Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters disbursed to the university. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 (b) outlines that upon receipt of the Enrollment report from the Secretary a school must update all information included in the report to the secretary within the manner and format prescribed and within the time frame prescribed by the secretary (15 days) and error records are resubmitted within 10 days. Condition: The University is updating NSLDS records for students manually but does not ensure that roster files updates are complete and timely. During our testing, we noted 7 out of the 12 rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. Questioned costs: None. Context: 7 out of 12 enrollment rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. Cause: Lack of appropriate policy and procedure in place regarding enrollment roster certifying for the year under audit. Effect: Non-compliance with federal regulations which could lead to untimely reporting of enrollment information to NSLDS. Repeat Finding: Yes, 2021-003 Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters disbursed to the university. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
2022-001 Enrollment Roster Reporting Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters disbursed to the University. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: Turnover with key personnel within the Registrar office Action taken in response to finding: After significant turnover of the Registrar and staff, Piedmont University has a new experienced Registrar starting on November 14, 2022. The University is also in the process of filling the other vacancies within the department. Once the Registrar is in place, she will work in collaboration with the offices of student accounts and financial aid, in crafting written procedures that determine consistent and appropriate changes in registration status and a procedure for determining the appropriate effective dates for changes in status. Further steps will be taken to confirm that registration status fields and effective dates entered in the SIS by the registrar's office align with the financial aid office's NSLDS report fields for affected students. Name(s) of the contact person(s) responsible for corrective action: Whitney Merinar Planned completion date for corrective action plan: June 30, 2023
2021-003
Incorrect or untimely reporting by the University of students? changes in status during the 2021-2022 award year under audit. Questioned costs: None. Context: 8 of the 60 students tested noted one or more discrepancies, as follows: ? ? 1 student?s status was incorrectly reported to NSDLS. ? 8 students? last date of attendance or graduation date were not reported correctly to NSLDS. ? 5 students were not reported timely to NSLDS, within 60 days. Cause: Lack of appropriate policy and procedure in place regarding NSLDS enrollment reporting for the year under audit. Effect: Non-compliance with federal regulations which could lead to untimely and incorrect reporting of enrollment information to NSLDS. Repeat Finding: Yes, 2021-004 Recommendation: We recommend that the University review their enrollment reporting policies and procedures to ensure accurate reporting. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Show full finding ▾Hide full finding ▴Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level as well as the program begin date. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer Condition: Incorrect or untimely reporting by the University of students? changes in status during the 2021-2022 award year under audit. Questioned costs: None. Context: 8 of the 60 students tested noted one or more discrepancies, as follows: ? ? 1 student?s status was incorrectly reported to NSDLS. ? 8 students? last date of attendance or graduation date were not reported correctly to NSLDS. ? 5 students were not reported timely to NSLDS, within 60 days. Cause: Lack of appropriate policy and procedure in place regarding NSLDS enrollment reporting for the year under audit. Effect: Non-compliance with federal regulations which could lead to untimely and incorrect reporting of enrollment information to NSLDS. Repeat Finding: Yes, 2021-004 Recommendation: We recommend that the University review their enrollment reporting policies and procedures to ensure accurate reporting. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
2022-002 Enrollment Status Reporting Recommendation: We recommend that the University review their enrollment reporting policies and procedures to ensure accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: Turnover with key personnel within the Registrar office. Action taken in response to finding: After significant turnover of the Registrar and staff, Piedmont University has a new experienced Registrar starting on November 14, 2022. The University is also in the process of filling the other vacancies within the department. Once the Registrar is in place, the National Student Clearinghouse data origination file will be reviewed to ensure that the correct program start and end dates are collected and reported to the NSC. A process for communicating program changes with effective dates will be implemented in collaboration with the financial aid office to ensure the consistency of reported dates to NSLDS Name(s) of the contact person(s) responsible for corrective action: Whitney Merinar Planned completion date for corrective action plan: June 30, 2023 If the U.S. Department of Education has questions regarding this plan, please call Brant Wright at 706-778-8500 ext.1457.
2021-004
FAC accepted this audit on March 15, 2022 — management decision was due September 15, 2022.
During our testing, we noted one student whose amount of Pell to be returned to ED was calculated incorrectly by the University. Questioned costs: Known questioned costs totaled $258. Likely questioned costs are approximately $1,000 for the entire population of R2T4s performed by the University. Context: 1 out of 25 returns tested. Cause: There was a calculation error in University?s system used to calculate the amount to be returned. Effect: The students? return of funds calculation was not performed correctly and the return of funds back to the federal government was for the incorrect amount. Repeat Finding: No Recommendation: We recommend that the University utilize the Department of Education template for calculating R2T4s to eliminate errors in the amounts to be returned. We also recommend an additional level of review is added to ensure R2T4s are accurate. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Show full finding ▾Hide full finding ▴2021?001 Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.007 ? Supplemental Educational Opportunity Grant Program, 84.268 ? Federal Direct Student Loans, 84.063 ? Pell Grant Program Award Period: July 1, 2020 through June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22 outlines all applicable guidelines for the Return to Title IV (R2T4) Calculation Process as well as the applicable timeframe that those determinations and calculations must be performed. Condition: During our testing, we noted one student whose amount of Pell to be returned to ED was calculated incorrectly by the University. Questioned costs: Known questioned costs totaled $258. Likely questioned costs are approximately $1,000 for the entire population of R2T4s performed by the University. Context: 1 out of 25 returns tested. Cause: There was a calculation error in University?s system used to calculate the amount to be returned. Effect: The students? return of funds calculation was not performed correctly and the return of funds back to the federal government was for the incorrect amount. Repeat Finding: No Recommendation: We recommend that the University utilize the Department of Education template for calculating R2T4s to eliminate errors in the amounts to be returned. We also recommend an additional level of review is added to ensure R2T4s are accurate. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
2021-001 Return to Title IV (R2T4) Calculation Process Recommendation: We recommend that the University utilize the ED template for calculating R2T4s to eliminate errors in the amounts to be returned. We also recommend an additional level of review is added to ensure R2T4s are accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding : R2T4 calculations are processed using Ellucian Software, Colleague. In calculating the R2T 4 for this student, her loans were being picked up as anticipated in the calculation. However, the student had not completed Entrance Counseling or an MPN. Her loans were not originated at the point of withdrawal. With her federal aid being reported higher than actual, the software calculated her earned aid higher than it should have been. Action taken in response to finding : The University will use the ED template along with the Ellucian software to determine the correct federal aid is being calculated in the R2T4 . Also, instead of two levels of review, there will be three levels of review including final approval by the Financial Aid Director. Name(s) of the contact person(s) responsible for corrective action : Linda O'Sullivan Planned completion date for corrective action plan : Corrective action plan was put into place on November 9, 2021.
During our testing, we noted one student did not receive exit counseling within the required 30 days of a student ceasing attendance. Questioned costs: None Context: 1 out of 40 students tested. Cause: The College?s processes and controls did not ensure that exit counseling was completed or did not retain proper support to indicate this process took place. Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate. Repeat Finding: No Recommendation: We recommend the University review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Show full finding ▾Hide full finding ▴2021?002 Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.268 ? Federal Direct Student Loans Award Period: July 1, 2020 through June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.304 requires exit counseling be performed for all students who received Direct Subsidized Loan, Direct Unsubsidized Loan and/or Direct PLUS Loans, and ceases at least half-time study at the school. Condition: During our testing, we noted one student did not receive exit counseling within the required 30 days of a student ceasing attendance. Questioned costs: None Context: 1 out of 40 students tested. Cause: The College?s processes and controls did not ensure that exit counseling was completed or did not retain proper support to indicate this process took place. Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate. Repeat Finding: No Recommendation: We recommend the University review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Recommendation: We recommend the University review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling . Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding : Exit counseling was not sent to a student that voided his registration on December 21, 2020 prior to spring semester 2021 beginning. A report of students exiting the University was processed on December 21, 2020. Then another report was processed on February 1, 2021 . These two lists were compared. The students not picked up on first report were added to the list. All students not returning were emailed exit counseling instructions to their personal email address. The student was not noted as not enrolled on either report. Action taken in response to finding : To account for all students exiting and meeting the Exit Counseling requirement several measures were put in place: 1. Exit counseling information is provided on the withdrawal form . Student must initial they read the information. 2. Exit counseling is emailed at least four times after exiting . The first email occurs between terms if the student has not registered for classes for the preceding semester. Up to three additional emails will be sent to the student's personal email if student has not completed exit counseling. 3. Notification of the Exit Counseling requirement is noted at the bottom of every R2T4 letter to the student notifying of federal funds returned. 4 . Students are notified to the Exit Counseling requirement on every federal loan disbursement notice. This notification is a pro-active communication that will not replace notification of the Exit Counseling requirement the University must send out once a student exits the school. However, it does inform the student exit counseling will be required if they should leave school. Name(s) of the contact person(s) responsible for corrective action : Linda O'Sullivan Planned completion date for corrective action plan: Action took place November 8, 2021
The University is updating NSLDS records for students manually but does not ensure that roster files updates are complete and timely. During our testing, we noted 6 out of the 12 rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. Questioned costs: None. Context: 6 out of 12 enrollment rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. Cause: Lack of appropriate policy and procedure in place regarding enrollment roster certifying for the year under audit. Effect: Non-compliance with federal regulations which could lead to untimely reporting of enrollment information to NSLDS. Repeat Finding: No Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters disbursed to the university. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Show full finding ▾Hide full finding ▴2021?003 Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: Various Award Period: July 1, 2020 through June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 (b) outlines that upon receipt of the Enrollment report from the Secretary a school must update all information included in the report to the secretary within the manner and format prescribed and within the time frame prescribed by the secretary (15 days) and error records are resubmitted within 10 days. Condition: The University is updating NSLDS records for students manually but does not ensure that roster files updates are complete and timely. During our testing, we noted 6 out of the 12 rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. Questioned costs: None. Context: 6 out of 12 enrollment rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. Cause: Lack of appropriate policy and procedure in place regarding enrollment roster certifying for the year under audit. Effect: Non-compliance with federal regulations which could lead to untimely reporting of enrollment information to NSLDS. Repeat Finding: No Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters disbursed to the university. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Enrollment Roster Reporting Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to Enrollment rosters disbursed to the university. Explanation of disagreement with audit finding : There is no disagreement with the audit finding. Reason for finding : The institutional effective dates for changes in students' enrollment status are not consistent with NSDLS effective dates. Action taken in response to finding : The registrar 's office, in collaboration with the offices of student accounts and financial aid, are crafting written procedures that determine consistent and appropriate changes in registration status (e.g., void, drop, or withdraw), and a procedure for determining the appropriate effective dates for changes in status. Further steps will be taken to confirm that registration status fields and effective dates entered in the SIS by the registrar's office align with the financial aid office's NSLDS report fields for affected students. Name(s) of the contact person(s) responsible for corrective action : Janice Hartsoe Planned completion date for corrective action plan: June 30, 2022
Incorrect or untimely reporting by the University of students? changes in status during the 2020-2021 award year under audit. Questioned costs: None. Context: 10 of the 40 students tested noted one or more discrepancies, as follows: ? 2 students? status was incorrectly reported to NSDLS. ? 5 students? last date of attendance or graduation date were not reported correctly to NSLDS. ? 1 student was not reported timely to NSLDS, within 60 days. ? 4 students? program start date per NSLDS did not match the institution?s records. Cause: Lack of appropriate policy and procedure in place regarding NSLDS enrollment reporting for the year under audit. Effect: Non-compliance with federal regulations which could lead to untimely and incorrect reporting of enrollment information to NSLDS. Repeat Finding: No. Recommendation: We recommend that the University review their enrollment reporting policies and procedures to ensure accurate reporting. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Show full finding ▾Hide full finding ▴2021-004 Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: Various Award Period: July 1, 2020 through June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level as well as the program begin date. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer Condition: Incorrect or untimely reporting by the University of students? changes in status during the 2020-2021 award year under audit. Questioned costs: None. Context: 10 of the 40 students tested noted one or more discrepancies, as follows: ? 2 students? status was incorrectly reported to NSDLS. ? 5 students? last date of attendance or graduation date were not reported correctly to NSLDS. ? 1 student was not reported timely to NSLDS, within 60 days. ? 4 students? program start date per NSLDS did not match the institution?s records. Cause: Lack of appropriate policy and procedure in place regarding NSLDS enrollment reporting for the year under audit. Effect: Non-compliance with federal regulations which could lead to untimely and incorrect reporting of enrollment information to NSLDS. Repeat Finding: No. Recommendation: We recommend that the University review their enrollment reporting policies and procedures to ensure accurate reporting. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Recommendation: We recommend that the University review their enrollment reporting policies and procedures to ensure accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding : Academic program begin dates are not consistently aligned with term start dates. Students who interrupt their enrollment at the university prior to the start of their term of non-enrollment (both students who notified the institution of their withdrawal and those who did not) were either not reported to NSDLS as withdrawn or their reported withdrawal date was not in alignment with the term dates of nonenrollment. A process will be implemented to identify students (both those who notify the institution and those who do not) who interrupt their enrollment at the university and to report these "institutional withdrawals" consistently to the National Student Clearinghouse. Action taken in response to finding : The National Student Clearinghouse data origination file will be reviewed to ensure that the correct program start and end dates are collected and reported to the NSC. A process for communicating program changes with effective dates will be implemented in collaboration with the financial aid office to ensure the consistency of reported dates to NSLDS . Name(s) of the contact person(s) responsible for corrective action: Janice Hartsoe Planned completion date for corrective action plan: June 30, 2022
The University did not upload a 3/31/2021 student report for CRRSA funding. Questioned costs: None. Context: 1 out of 2 student reports tested. Cause: The University did not have someone tracking the requirements to ensure that they posted the reporting timely and accurately. Effect: Non-compliance with federal regulations which could lead to untimely and incorrect reporting. Repeat Finding: No. Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Show full finding ▾Hide full finding ▴2021?005 Federal Agency: Department of Education Federal Program Title: Education Stabilization Fund CFDA Number: 84.425E Award Period: July 1, 2020 through June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the institution?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This requirement was changed to quarterly on 8/31/2020. Condition: The University did not upload a 3/31/2021 student report for CRRSA funding. Questioned costs: None. Context: 1 out of 2 student reports tested. Cause: The University did not have someone tracking the requirements to ensure that they posted the reporting timely and accurately. Effect: Non-compliance with federal regulations which could lead to untimely and incorrect reporting. Repeat Finding: No. Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding : The University did not upload a 03/31/2021 student report for CRRSA funding. The requirement for CRRSA student report came out on May 6, 2021. Two reports were posted after this date: June 10, 2021 and June 20, 2021 . It was not noted that retro-active reports were required for student reporting . Action taken in response to finding :The March 31, 2021 quarterly report has been added to the Piedmont website . https ://www .piedmont.edu/wp-content/uploads/2022/02/HEERF-II-FundingRepo rt -March - 31 - 2021 .pdf Name(s) of the contact person(s) responsible for corrective action : Linda O 'Sullivan Planned completion date for corrective action plan: February 22, 2022
The University could not produce documentation to show that they verified that vendors had not been suspended or debarred. Questioned costs: None. Context: The University did not maintain documentation for suspension and debarment on 2 out of 2 vendors selected for testing. Cause: While the University has suspension and debarment procedures in place, they do not document that the check had been completed. Effect: The University could enter a covered transaction with a vendor who is suspended or debarred and not be in compliance with HEERF requirements. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter
Show full finding ▾Hide full finding ▴2021?006 Federal Agency: Department of Education Federal Program Title: Education Stabilization Fund CFDA Number: 84.425E, 84.425F Award Period: July 1, 2020 through June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they verified that vendors had not been suspended or debarred. Questioned costs: None. Context: The University did not maintain documentation for suspension and debarment on 2 out of 2 vendors selected for testing. Cause: While the University has suspension and debarment procedures in place, they do not document that the check had been completed. Effect: The University could enter a covered transaction with a vendor who is suspended or debarred and not be in compliance with HEERF requirements. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter
Recommendation: We recommend the University document suspension and debarment procedures going forward for any disbursements with vendors greater than $25,000. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: Lack of adequate documentation to support debarment procedures. Action taken in response to finding : Document debarment procedures and collect certification from vendors being paid more than $25,000. Name(s) of the contact person(s) responsible for corrective action: Kristi Williams Planned completion date for corrective action plan: January 12, 2022
FAC accepted this audit on April 29, 2021 — management decision was due October 29, 2021.
FAC accepted this audit on November 12, 2019 — management decision was due May 12, 2020.
FAC accepted this audit on November 11, 2019 — management decision was due May 11, 2020.
FAC accepted this audit on January 24, 2018 — management decision was due July 24, 2018.
FAC accepted this audit on February 26, 2017 — management decision was due August 26, 2017.
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