EIN: 611010545
UEI: LN53C9E23GH6
Audit also covers EIN: 201787893 · unlinked EINs have no separate FAC filing
Audited by: Dean Dorton Allen Ford, PLLC
Cognizant agency: 84 [Department of Education]
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Data as of August 31, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 26, 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 July 26, 2026 (38 days ago).
What is a management decision? →During our testing of 40 official withdrawals, we reviewed the calculation used by the University for the return of funds and noted eight students in which the calculation was improperly calculated. Our testing of 40 official withdrawals included five and three full-term students from the Fall and Spring semesters, respectively, for which the return of funds calculation was improperly calculated due to the University using various incorrect inputs. The incorrect withdrawal date was used for one student, incorrect institutional charges were used for five students, and incorrect total aid disbursed was used for two students. Cause: The University does not have a procedure in place to properly review the inputs used within return of funds calculations. Effect: The provisions of 34 CFR Section 668.22 were not followed and thus a total of eight students had incorrect return of funds calculations, however, four calculations resulted in questioned costs. The other four calculations were performed incorrectly, but students earned over 60% of aid. Questioned Costs: Known questioned costs total net $3,729 in Title IV aid that should have been earned as a result of our testing of 40 official withdrawals. Use of the incorrect withdrawal date resulted in one student who earned an additional $3,429. Use of incorrect institutional charges resulted in no additional funds needing to be returned, but did change the amount the students were responsible for returning. The University returned $600 that should have been the students' responsibility. Use of the incorrect total aid resulted in one student earning $300 less than they should have, if the proper aid had been used. The student attended more than 60% of the term, so no return was required. Recommendation: We recommend that the University review and revise their policies and procedures related to the return of funds calculation. Specifically, the University should: Implement a review process to verify calculations before finalizing returns. Provide training to relevant staff, including those outside of the student financial assistance department, on the proper calculation methods to enhance compliance and accuracy. Views of responsible officials and planned corrective actions: The University agrees with the auditor's finding and recommendations. The following corrective action will be taken: The University has awarded aid in the amount of $3,729 to students which represents student earned aid from an updated R2T4 calculation accounting for the proper use of the withdrawal date, institutional charges and total aid for 2024-25 academic year. The University will review, and revise policies and procedures related to the return of funds calculation. Specifically, the University will: Update procedures to include a review of input items by AVP prior to finalizing returns. Provide training to relevant staff, including staff outside of the Office of Student Financial Assistance, on proper calculation methods to ensure compliance and accuracy of R2T4 calculations. The University is exploring opportunities to automate partially or completely the R2T4 process to support accurate and efficient processing and enhance compliance.
Show full finding ▾Hide full finding ▴Finding 2025-001: Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant, Assistance Listing No. 84.063 Federal Supplemental Education Opportunity Grant, Assistance Listing No. 84.007 Federal Direct Loan Program, Assistance Listing No. 84.268 Criteria: The University must comply with 34 CFR Section 668.22. Condition: During our testing of 40 official withdrawals, we reviewed the calculation used by the University for the return of funds and noted eight students in which the calculation was improperly calculated. Our testing of 40 official withdrawals included five and three full-term students from the Fall and Spring semesters, respectively, for which the return of funds calculation was improperly calculated due to the University using various incorrect inputs. The incorrect withdrawal date was used for one student, incorrect institutional charges were used for five students, and incorrect total aid disbursed was used for two students. Cause: The University does not have a procedure in place to properly review the inputs used within return of funds calculations. Effect: The provisions of 34 CFR Section 668.22 were not followed and thus a total of eight students had incorrect return of funds calculations, however, four calculations resulted in questioned costs. The other four calculations were performed incorrectly, but students earned over 60% of aid. Questioned Costs: Known questioned costs total net $3,729 in Title IV aid that should have been earned as a result of our testing of 40 official withdrawals. Use of the incorrect withdrawal date resulted in one student who earned an additional $3,429. Use of incorrect institutional charges resulted in no additional funds needing to be returned, but did change the amount the students were responsible for returning. The University returned $600 that should have been the students' responsibility. Use of the incorrect total aid resulted in one student earning $300 less than they should have, if the proper aid had been used. The student attended more than 60% of the term, so no return was required. Recommendation: We recommend that the University review and revise their policies and procedures related to the return of funds calculation. Specifically, the University should: Implement a review process to verify calculations before finalizing returns. Provide training to relevant staff, including those outside of the student financial assistance department, on the proper calculation methods to enhance compliance and accuracy. Views of responsible officials and planned corrective actions: The University agrees with the auditor's finding and recommendations. The following corrective action will be taken: The University has awarded aid in the amount of $3,729 to students which represents student earned aid from an updated R2T4 calculation accounting for the proper use of the withdrawal date, institutional charges and total aid for 2024-25 academic year. The University will review, and revise policies and procedures related to the return of funds calculation. Specifically, the University will: Update procedures to include a review of input items by AVP prior to finalizing returns. Provide training to relevant staff, including staff outside of the Office of Student Financial Assistance, on proper calculation methods to ensure compliance and accuracy of R2T4 calculations. The University is exploring opportunities to automate partially or completely the R2T4 process to support accurate and efficient processing and enhance compliance.
Views of responsible officials and planned corrective actions: The University agrees with the auditor's finding and recommendations. The following corrective action will be taken: The University has awarded aid in the amount of $3,729 to students which represents student earned aid from an updated R2T4 calculation accounting for the proper use of the withdrawal date, institutional charges and total aid for 2024-25 academic year. The University will review, and revise policies and procedures related to the return of funds calculation. Specifically, the University will: Update procedures to include a review of input items by AVP prior to finalizing returns. Provide training to relevant staff, including staff outside of the Office of Student Financial Assistance, on proper calculation methods to ensure compliance and accuracy of R2T4 calculations. The University is exploring opportunities to automate partially or completely the R2T4 process to support accurate and efficient processing and enhance compliance.
During our testing of eligibility for 25 program participants, we noted that four participants did not have evidence of being interviewed prior to being hired. Cause: Until the implementation of a new system and procedure, the University's documentation process for interviews during a portion of the audit period did not include formalized controls to centralize retention and documentation of interview evidence. Interview documentation was maintained through individual staff email accounts and calendar systems lacked standardized filing and retention protocols, resulting in the inability to locate evidence that interviews were conducted for four participants. Effect: The University's internal control was not followed and thus a total of four program participants did not have evidence of being properly interviewed prior to being hired. Questioned Costs: There are no questioned costs. Recommendation: We recommend the University review controls and implement a standardized process and refine its system to ensure ongoing compliance with established controls. Views of responsible officials and planned corrective actions: The University agrees with the auditors' finding and recommendations. The following corrective actions have been taken: During the 2023-2024 academic year, EngageKY implemented a new process for recordkeeping related to the recruitment and selection of Kentucky College Coaches. As part of the implementation, site supervisors and program staff began to use Salesforce to maintain notes from screening interviews and general interviews. The missing documentation referenced in this finding was for individuals hired prior to the new process. EngageKY will continue to use Salesforce to document the recruitment and selection of Kentucky College Coaches.
Show full finding ▾Hide full finding ▴Finding 2025-002: Federal Program: Corporation for National and Community Service: Kentucky Cabinet for Health & Family Services AmeriCorps State & National, Assistance Listing No. 94.006 Criteria: The University must have internal controls in place for compliance as required by 2 CFR Part 200.303. The University requires that interviews be conducted and documented prior to onboarding AmeriCorps members. Condition: During our testing of eligibility for 25 program participants, we noted that four participants did not have evidence of being interviewed prior to being hired. Cause: Until the implementation of a new system and procedure, the University's documentation process for interviews during a portion of the audit period did not include formalized controls to centralize retention and documentation of interview evidence. Interview documentation was maintained through individual staff email accounts and calendar systems lacked standardized filing and retention protocols, resulting in the inability to locate evidence that interviews were conducted for four participants. Effect: The University's internal control was not followed and thus a total of four program participants did not have evidence of being properly interviewed prior to being hired. Questioned Costs: There are no questioned costs. Recommendation: We recommend the University review controls and implement a standardized process and refine its system to ensure ongoing compliance with established controls. Views of responsible officials and planned corrective actions: The University agrees with the auditors' finding and recommendations. The following corrective actions have been taken: During the 2023-2024 academic year, EngageKY implemented a new process for recordkeeping related to the recruitment and selection of Kentucky College Coaches. As part of the implementation, site supervisors and program staff began to use Salesforce to maintain notes from screening interviews and general interviews. The missing documentation referenced in this finding was for individuals hired prior to the new process. EngageKY will continue to use Salesforce to document the recruitment and selection of Kentucky College Coaches.
Views of responsible officials and planned corrective actions: The University agrees with the auditors' finding and recommendations. The following corrective actions have been taken: During the 2023-2024 academic year, EngageKY implemented a new process for recordkeeping related to the recruitment and selection of Kentucky College Coaches. As part of the implementation, site supervisors and program staff began to use Salesforce to maintain notes from screening interviews and general interviews. The missing documentation referenced in this finding was for individuals hired prior to the new process. EngageKY will continue to use Salesforce to document the recruitment and selection of Kentucky College Coaches.
During our testing of awarded scholarships for eight students, we noted that two student applications did not have evidence of being reviewed prior to disbursement of the scholarship. Cause: The University does not have a procedure in place to properly review scholarship applications prior to disbursement. Effect: Two students received scholarships that were not properly reviewed prior to disbursement. Questioned Costs: There are no questioned costs. Recommendation: We recommend that the University review and revise their policies and procedures related to reviewing and approving Research & Development grant scholarships prior to disbursement. Specifically, the University should: Implement a review process to verify scholarships are reviewed and approved by Grant Administration prior to disbursement. Provide training to relevant staff on proper documentation procedures to forward to Grant Administration to enhance compliance and accuracy. Views of responsible officials and planned corrective actions: The University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will review and revise policies and procedures related to reviewing and approving Research & Development grant scholarships prior to disbursement. The University will do the following: Implement a review process to verify scholarships are reviewed and approved by Grant Administration prior to disbursement. Provide training to relevant staff on proper documentation procedures to forward to Grant Administration to enhance compliance and accuracy.
Show full finding ▾Hide full finding ▴Finding 2025-003: Federal Program: U.S. National Science Foundation: Research and Development Cluster Office of Integrated Activities, Assistance Listing No. 47.083 Criteria: The University must have internal controls in place for compliance as required by 2 CFR Part 200.303. The University requires review by grant department before disbursement. Condition: During our testing of awarded scholarships for eight students, we noted that two student applications did not have evidence of being reviewed prior to disbursement of the scholarship. Cause: The University does not have a procedure in place to properly review scholarship applications prior to disbursement. Effect: Two students received scholarships that were not properly reviewed prior to disbursement. Questioned Costs: There are no questioned costs. Recommendation: We recommend that the University review and revise their policies and procedures related to reviewing and approving Research & Development grant scholarships prior to disbursement. Specifically, the University should: Implement a review process to verify scholarships are reviewed and approved by Grant Administration prior to disbursement. Provide training to relevant staff on proper documentation procedures to forward to Grant Administration to enhance compliance and accuracy. Views of responsible officials and planned corrective actions: The University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will review and revise policies and procedures related to reviewing and approving Research & Development grant scholarships prior to disbursement. The University will do the following: Implement a review process to verify scholarships are reviewed and approved by Grant Administration prior to disbursement. Provide training to relevant staff on proper documentation procedures to forward to Grant Administration to enhance compliance and accuracy.
Views of responsible officials and planned corrective actions: The University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will review and revise policies and procedures related to reviewing and approving Research & Development grant scholarships prior to disbursement. The University will do the following: Implement a review process to verify scholarships are reviewed and approved by Grant Administration prior to disbursement. Provide training to relevant staff on proper documentation procedures to forward to Grant Administration to enhance compliance and accuracy.
FAC accepted this audit on October 30, 2024 — management decision was due April 30, 2025.
During our audit of official withdrawals, we reviewed the calculation used by the University for the return of funds and noted various incorrect days being used within the calculations: - Incorrect total days for Fall and Spring semesters for full-term students - Incorrect break days for Fall and Spring semesters for full-term students - Incorrect withdrawal date used - Module days being used incorrectly for a full-term student Our testing of 40 official withdrawals included 11 and 12 full-term students from the Fall and Spring semesters, respectively, for which the return of funds calculation was improperly calculated due to the University using incorrect total days and incorrect break days. One student's calculation was incorrect due to the University treating them as a module student, instead of full-term. Additionally, the University used the incorrect withdrawal date for three students. Additional analysis performed by the University on the remaining official withdrawals identified an additional 21 and 25 students within the Fall and Spring semesters, respectively, for which the incorrect total days and incorrect break days were being used in the return of funds calculations. Cause: The University does not have a procedure in place to properly review days used within return of funds calculations. Effect: The provisions of 34 CFR Section 668.22 were not followed and thus a total of 73 students had incorrect return of funds calculations. Questioned Costs: Known questioned costs total $16,857 in Title IV aid that should have been returned as a result of our testing of 40 official withdrawals. Additional analysis performed by the University identified an additional $5,764 in Title IV aid that should have been returned. Recommendation: We recommend that the University review and revise their policies and procedures related to the return of funds calculation. Specifically, the University should: - Ensure the correct definition and calculation of days (end of enrollment period, break days, etc.) is used within the calculations. - Implement a review process to verify calculations before finalizing returns. - Provide training to relevant staff on the proper calculation methods to enhance compliance and accuracy. Views of responsible officials and planned corrective actions: Northern Kentucky University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will return $22,621 in federal student financial aid to United States Department of Education (USED) which represents the updated R2T4 accounting for the correct academic calendar end dates and breaks periods for the 2023-24 academic year. The University provided the external auditors with the current year academic calendar (end of period, break day, etc) for review and validation. The correct definition and calculation of days (end of enrollment period, break days, etc) will be used with return calculations. There will be a review process that will include validation from the AVP to verify calculations before finalizing returns. Training will be provided to all relevant staff on the proper calculation methods to ensure compliance and accuracy which will include the review of the Federal Student Handbook - Volume 5 - Withdrawals and the Return of Title IV Funds and other relevant guidance from USED.
Show full finding ▾Hide full finding ▴Finding 2024-001: Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant, Assistance Listing No. 84.063 Federal Supplemental Education Opportunity Grant, Assistance Listing No. 84.007 Federal Work Study Program, Assistance Listing No. 84.033 Federal Perkins Loan Program, Assistance Listing No. 84.038 Federal Direct Loan Program, Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. 84.379 Nursing Faculty Loan Program, Assistance Listing No. 93.264 Criteria: The University must comply with 34 CFR Section 668.22. Condition: During our audit of official withdrawals, we reviewed the calculation used by the University for the return of funds and noted various incorrect days being used within the calculations: - Incorrect total days for Fall and Spring semesters for full-term students - Incorrect break days for Fall and Spring semesters for full-term students - Incorrect withdrawal date used - Module days being used incorrectly for a full-term student Our testing of 40 official withdrawals included 11 and 12 full-term students from the Fall and Spring semesters, respectively, for which the return of funds calculation was improperly calculated due to the University using incorrect total days and incorrect break days. One student's calculation was incorrect due to the University treating them as a module student, instead of full-term. Additionally, the University used the incorrect withdrawal date for three students. Additional analysis performed by the University on the remaining official withdrawals identified an additional 21 and 25 students within the Fall and Spring semesters, respectively, for which the incorrect total days and incorrect break days were being used in the return of funds calculations. Cause: The University does not have a procedure in place to properly review days used within return of funds calculations. Effect: The provisions of 34 CFR Section 668.22 were not followed and thus a total of 73 students had incorrect return of funds calculations. Questioned Costs: Known questioned costs total $16,857 in Title IV aid that should have been returned as a result of our testing of 40 official withdrawals. Additional analysis performed by the University identified an additional $5,764 in Title IV aid that should have been returned. Recommendation: We recommend that the University review and revise their policies and procedures related to the return of funds calculation. Specifically, the University should: - Ensure the correct definition and calculation of days (end of enrollment period, break days, etc.) is used within the calculations. - Implement a review process to verify calculations before finalizing returns. - Provide training to relevant staff on the proper calculation methods to enhance compliance and accuracy. Views of responsible officials and planned corrective actions: Northern Kentucky University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will return $22,621 in federal student financial aid to United States Department of Education (USED) which represents the updated R2T4 accounting for the correct academic calendar end dates and breaks periods for the 2023-24 academic year. The University provided the external auditors with the current year academic calendar (end of period, break day, etc) for review and validation. The correct definition and calculation of days (end of enrollment period, break days, etc) will be used with return calculations. There will be a review process that will include validation from the AVP to verify calculations before finalizing returns. Training will be provided to all relevant staff on the proper calculation methods to ensure compliance and accuracy which will include the review of the Federal Student Handbook - Volume 5 - Withdrawals and the Return of Title IV Funds and other relevant guidance from USED.
Northern Kentucky University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will return $22,621 in federal student financial aid to United States Department of Education (USED) which represents the updated R2T4 accounting for the correct academic calendar end dates and breaks periods for the 2023-24 academic year. The University provided the external auditors with the current year academic calendar (end of period, break day, etc) for review and validation. The correct definition and calculation of days (end of enrollment period, break days, etc) will be used with return calculations. There will be a review process that will include validation from the Assistant Vice President, Enrollment Management to verify calculations before finalizing returns. Training will be provided to all relevant staff on the proper calculation methods to ensure compliance and accuracy which will include the review of the Federal Student Handbook - Volume 5 - Withdrawals and the Return of Title IV Funds and other relevant guidance from USED. Anticipated Completion Date: December 31, 2024 Leah Stewart, Assistant Vice President, Enrollment Management
During our testing of 40 official withdrawals, we noted two students for which the National Student Loan Data System (NSLDS) was not notified timely of the correct student status change due to external credits for professional study courses erroneously being included within the students' total credit hours and thus improperly classifying them on the University's roster files. Additional analysis performed by the University on the remaining population of students with external credits identified an additional 12 students for which the NSLDS was not notified timely of the correct student status change. During our testing of three unofficial withdrawals, we noted one Spring semester student for which the NSLDS was not notified timely of the student status change. Additional analysis of all unofficial withdrawals for Spring 2024 resulted in 10 additional students for which the NSLDS was not notified timely of the correct student status change. Cause: The University did not have controls in place to ensure students' classification based upon actual allowable credit hours were being properly reported to the NSLDS. Unofficial withdrawals were also not being monitored to ensure timely reporting to the NSLDS. Effect: The provisions of 34 CFR Section 685.309(b) were not followed and thus a total of 27 students had untimely and incorrect status changes reported to the NSLDS. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: We recommend that the University implement controls to ensure roster files are updated correctly and reviewed before reported to the NSLDS. Views of responsible officials and planned corrective actions: The University agrees with the auditors' finding and recommendation. The following corrective action will be taken: The University Registrar will adhere to: Provisions of 34 CFR Section 685.309(b) will be followed when reporting to NSLDS. The University will develop and implement controls to ensure students’ classification based on actual allowable credit hours are being properly reported to NSLDS. Unofficial withdrawals will be monitored to ensure timely reporting to NSLDS. The University Registrar will work collaboratively with IT to modify the enrollment report to identify students with external credits as well as students who stop attending to allow proper reporting to the NSLDS within the required 30 days.
Show full finding ▾Hide full finding ▴Finding 2024-002: Federal Program: U.S. Department of Education Federal Direct Loan Program, CFDA 84.268 Criteria: The University must comply with 34 CFR Section 685.309(b). Condition: During our testing of 40 official withdrawals, we noted two students for which the National Student Loan Data System (NSLDS) was not notified timely of the correct student status change due to external credits for professional study courses erroneously being included within the students' total credit hours and thus improperly classifying them on the University's roster files. Additional analysis performed by the University on the remaining population of students with external credits identified an additional 12 students for which the NSLDS was not notified timely of the correct student status change. During our testing of three unofficial withdrawals, we noted one Spring semester student for which the NSLDS was not notified timely of the student status change. Additional analysis of all unofficial withdrawals for Spring 2024 resulted in 10 additional students for which the NSLDS was not notified timely of the correct student status change. Cause: The University did not have controls in place to ensure students' classification based upon actual allowable credit hours were being properly reported to the NSLDS. Unofficial withdrawals were also not being monitored to ensure timely reporting to the NSLDS. Effect: The provisions of 34 CFR Section 685.309(b) were not followed and thus a total of 27 students had untimely and incorrect status changes reported to the NSLDS. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: We recommend that the University implement controls to ensure roster files are updated correctly and reviewed before reported to the NSLDS. Views of responsible officials and planned corrective actions: The University agrees with the auditors' finding and recommendation. The following corrective action will be taken: The University Registrar will adhere to: Provisions of 34 CFR Section 685.309(b) will be followed when reporting to NSLDS. The University will develop and implement controls to ensure students’ classification based on actual allowable credit hours are being properly reported to NSLDS. Unofficial withdrawals will be monitored to ensure timely reporting to NSLDS. The University Registrar will work collaboratively with IT to modify the enrollment report to identify students with external credits as well as students who stop attending to allow proper reporting to the NSLDS within the required 30 days.
The University agrees with the auditors' finding and recommendation. The following corrective action will be taken: The University Registrar will adhere to: Provisions of 34 CFR Section 685.309(b) will be followed when reporting to NSLDS. The University will develop and implement controls to ensure students’ classification based on actual allowable credit hours are being properly reported to NSLDS. Unofficial withdrawals will be monitored to ensure timely reporting to NSLDS. The University Registrar will work collaboratively with the Information Technology office to modify the enrollment report to identify students with external credits as well as students who stop attending to allow proper reporting to the NSLDS within the required 30 days. Anticipated Completion Date: December 31, 2024 Leah Stewart, Assistant Vice President, Enrollment Management
During the prior year audit, our testing of payroll identified issues with student stipends. As a result of Finding 2023-002, the University identified 14 additional trainee stipends that exceeded the maximum allowable amount for the Fall 2023 semester. Our testing did not identify any additional issues for Spring 2024. Cause: The University did not have controls in place to monitor the total amounts paid to student trainees on the grant. Effect: The guidelines for allowable amounts per the notice of award were not being followed and thus a total of 14 trainees' stipends were incorrectly awarded and paid. Questioned Costs: Known questioned costs totaled $12,777 for Fall 2023 semester and were identified by examining all payments made to student trainees in comparison with maximum allowable amounts. Recommendation: We recommend that the University continue to monitor total payments by student trainee. Views of responsible officials and planned corrective actions: As a result of Finding 2023-002, all student trainees are now paid by stipend. These stipends are set up with payment limits based on the trainee’s level. As noted above, all of the overpayments included in Finding 2024-003 were identified during the prior year’s audit and corrected and repaid at that time. No additional overpayments were identified during the current audit.
Show full finding ▾Hide full finding ▴Finding 2024-003, (Repeat of 2023-002): Federal Program: U.S. Department of Health and Human Services Administration Mental and Behavioral Health Education and Training Grants HRSA Opioid-Impacted Family Support Program (OIFSP) Assistance Listing No. 93.732 Federal Award Identification No. 20T26H39452, Award Year 2020 Criteria: Per the U.S. Department of Health and Human Services notice of award, stipends made to Level I and Level II trainees are capped at $5,000 and $7,500 per trainee, respectively. Condition: During the prior year audit, our testing of payroll identified issues with student stipends. As a result of Finding 2023-002, the University identified 14 additional trainee stipends that exceeded the maximum allowable amount for the Fall 2023 semester. Our testing did not identify any additional issues for Spring 2024. Cause: The University did not have controls in place to monitor the total amounts paid to student trainees on the grant. Effect: The guidelines for allowable amounts per the notice of award were not being followed and thus a total of 14 trainees' stipends were incorrectly awarded and paid. Questioned Costs: Known questioned costs totaled $12,777 for Fall 2023 semester and were identified by examining all payments made to student trainees in comparison with maximum allowable amounts. Recommendation: We recommend that the University continue to monitor total payments by student trainee. Views of responsible officials and planned corrective actions: As a result of Finding 2023-002, all student trainees are now paid by stipend. These stipends are set up with payment limits based on the trainee’s level. As noted above, all of the overpayments included in Finding 2024-003 were identified during the prior year’s audit and corrected and repaid at that time. No additional overpayments were identified during the current audit.
As a result of Finding 2023-002, all student trainees are now paid by stipend. These stipends are set up with payment limits based on the trainee’s level. As noted above, all of the overpayments included in Finding 2024-003 were identified during the prior year’s audit and corrected and repaid at that time. No additional overpayments were identified during the current audit. Anticipated Completion Date: Finding was corrected and funds returned in February 2024 Valerie Hardcastle, Vice President and Executive Director, Inst. For Health Innovation
2023-002
During our testing of 40 samples, we noted one student for which incorrect cost of attendance (COA) was used in the student's budget. The student's financial aid was packaged with an incorrect 9 month COA and a proper 5 month expected family contribution (EFC). This resulted in the student appearing to have an unmet need, and as a result, need-based aid was awarded. Cause: Based upon the student's enrollment status, the University had to "on-demand" process them. The University did not have controls in place to ensure the student's aid was packaged appropriately by pro-rating both the student's EFC and COA in the same manner based on anticipated enrollment. Effect: The provisions of 34 CFR 685.301 were not followed and thus a student erroneously received need-based aid. Questioned Costs: Known questioned costs is the total need-based aid, specifically subsidized direct loans, awarded to the student during the year, totaling $2,750. The total likely questioned costs is unknown. Recommendation: We recommend that the University implement controls to ensure student's aid is being packaged and awarded based on the anticipated enrollment of the student, with the correct corresponding EFC. Views of responsible officials and planned corrective actions: The University agrees with the auditor’s findings and recommendation. The following corrective action will be taken: The University will implement controls to ensure student’s aid is being packaged and awarded on the anticipated enrollment of the student, with correct corresponding EFC. The Office of Student Financial Assistance will collaborate with IT to ensure proper training and review of packaging logic accurately reflects the students’ federal student aid eligibility.
Show full finding ▾Hide full finding ▴Finding 2024-004: Federal Program: U.S. Department of Education Student Financial Aid Cluster: Federal Direct Loan Program, Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. 84.379 Criteria: The University must comply with 34 CFR 685.301. Condition: During our testing of 40 samples, we noted one student for which incorrect cost of attendance (COA) was used in the student's budget. The student's financial aid was packaged with an incorrect 9 month COA and a proper 5 month expected family contribution (EFC). This resulted in the student appearing to have an unmet need, and as a result, need-based aid was awarded. Cause: Based upon the student's enrollment status, the University had to "on-demand" process them. The University did not have controls in place to ensure the student's aid was packaged appropriately by pro-rating both the student's EFC and COA in the same manner based on anticipated enrollment. Effect: The provisions of 34 CFR 685.301 were not followed and thus a student erroneously received need-based aid. Questioned Costs: Known questioned costs is the total need-based aid, specifically subsidized direct loans, awarded to the student during the year, totaling $2,750. The total likely questioned costs is unknown. Recommendation: We recommend that the University implement controls to ensure student's aid is being packaged and awarded based on the anticipated enrollment of the student, with the correct corresponding EFC. Views of responsible officials and planned corrective actions: The University agrees with the auditor’s findings and recommendation. The following corrective action will be taken: The University will implement controls to ensure student’s aid is being packaged and awarded on the anticipated enrollment of the student, with correct corresponding EFC. The Office of Student Financial Assistance will collaborate with IT to ensure proper training and review of packaging logic accurately reflects the students’ federal student aid eligibility.
The University agrees with the auditor’s findings and recommendation. The following corrective action will be taken: The University will implement controls to ensure student’s aid is being packaged and awarded on the anticipated enrollment of the student, with correct corresponding EFC. The Office of Student Financial Assistance will collaborate with IT to ensure proper training and review of packaging logic accurately reflects the students’ federal student aid eligibility. Anticipated Completion Date: December 31, 2024 Leah Stewart, Assistant Vice President, Enrollment Management
FAC accepted this audit on January 9, 2024 — management decision was due July 9, 2024.
During our testing of the four quarterly reports, we noted that the report as of September 30, 2022 was not available on the University's website. An incorrectly labeled report was posted indicating it was for the quarter ended September 30, 2022, but actually contained a different quarter's information. Cause: The University did not have controls in place to ensure the accuracy of the reports posted to the University website. Recommendation: We recommend that the University implement oversight procedures to ensure the accuracy of the publicly available reports. Views of responsible officials and planned corrective actions: The University intended to adhere to U.S. Department of Education regulations for the HEERF federal funds. A different report was inadvertently posted on the website. The issue has been corrected and the September 30, 2022 quarterly report has been properly posted to our website.
Show full finding ▾Hide full finding ▴Finding 2023-001: Federal Program: U.S. Department of Education Education Stabilization Fund COVID-19 Higher Education Emergency Relief Fund (HEERF) Institutional Aid, Assistance Listing No. 84.425F Criteria: Per the U.S. Department of Education reporting requirements, HEERF Institutional funds are subject to quarterly public reporting within 10 days of the quarter end. Each quarterly report must be separately available on the University's HEERF reporting webpage. Condition: During our testing of the four quarterly reports, we noted that the report as of September 30, 2022 was not available on the University's website. An incorrectly labeled report was posted indicating it was for the quarter ended September 30, 2022, but actually contained a different quarter's information. Cause: The University did not have controls in place to ensure the accuracy of the reports posted to the University website. Recommendation: We recommend that the University implement oversight procedures to ensure the accuracy of the publicly available reports. Views of responsible officials and planned corrective actions: The University intended to adhere to U.S. Department of Education regulations for the HEERF federal funds. A different report was inadvertently posted on the website. The issue has been corrected and the September 30, 2022 quarterly report has been properly posted to our website.
The University intended to adhere to U.S. Department of Education regulations for the HEERF federal funds. A different report was inadvertently posted on the website. The issue has been corrected as of September 1, 2023 and the September 30, 2022 quarterly report has been properly posted to our website. Leah Stewart, Assistant Vice President, Enrollment Management.
Our testing of 40 payroll selections included testing of eight trainee stipends. Of these eight trainee stipends selected, three were found to exceed the maximum allowable amount per the notice of award, resulting in known questioned costs totaling $7,889. Additional analysis performed by the University on the remaining population identified an additional $39,517 known questioned costs. Cause: The University did not have controls in place to monitor the total amounts paid to student trainees on the grant. Questioned Costs: Known questioned costs totaled $47,406 and were identified by examining all payments made to student trainees in comparison with maximum allowable amounts. Recommendation: We recommend that the University implement procedures to monitor total payments by student trainee and a process be established for discontinuing charges to the grant once the maximum amount has been spent. Views of responsible officials and planned corrective actions: The University concurs with this finding. To ensure that we have proper controls in place to monitor the total amounts paid to student trainees on the grant, we are adjusting the process associated with funds disbursement to student trainees. Going forward, an analysis will be prepared for each proposed position to determine whether, consistent with applicable laws, the position may be paid as a stipend or via other payment rather than as an hourly employee, alleviating the need for reporting hours and easing the transition after the student graduates. In addition, staff in the Provost's office and in Finance will provide additional monitoring of grant costs as needed to ensure compliance.
Show full finding ▾Hide full finding ▴Finding 2023-002: Federal Program: U.S. Department of Health and Human Services Administration Mental and Behavioral Health Education and Training Grants HRSA Opioid-Impacted Family Support Program (OIFSP) Assistance Listing No. 93.732 Criteria: Per the U.S. Department of Health and Human Services notice of award, stipends made to Level I and Level II trainees are capped at $5,000 and $7,500 per trainee, respectively. Condition: Our testing of 40 payroll selections included testing of eight trainee stipends. Of these eight trainee stipends selected, three were found to exceed the maximum allowable amount per the notice of award, resulting in known questioned costs totaling $7,889. Additional analysis performed by the University on the remaining population identified an additional $39,517 known questioned costs. Cause: The University did not have controls in place to monitor the total amounts paid to student trainees on the grant. Questioned Costs: Known questioned costs totaled $47,406 and were identified by examining all payments made to student trainees in comparison with maximum allowable amounts. Recommendation: We recommend that the University implement procedures to monitor total payments by student trainee and a process be established for discontinuing charges to the grant once the maximum amount has been spent. Views of responsible officials and planned corrective actions: The University concurs with this finding. To ensure that we have proper controls in place to monitor the total amounts paid to student trainees on the grant, we are adjusting the process associated with funds disbursement to student trainees. Going forward, an analysis will be prepared for each proposed position to determine whether, consistent with applicable laws, the position may be paid as a stipend or via other payment rather than as an hourly employee, alleviating the need for reporting hours and easing the transition after the student graduates. In addition, staff in the Provost's office and in Finance will provide additional monitoring of grant costs as needed to ensure compliance.
The University concurs with this finding. To ensure that we have proper controls in place to monitor the total amounts paid to student trainees on the grant, we are adjusting the process associated with funds disbursement to student trainees. Going forward, an analysis will be prepared for each proposed position to determine whether, consistent with applicable laws, the position may be paid as a stipend or via other payment rather than as an hourly employee, alleviating the need for reporting hours and easing the transition after the student graduates. In addition, staff in the Provost's office and in Finance will provide additional monitoring of grant costs as needed to ensure compliance. Valerie Hardcastle, Vice President and Exec Director, Inst. Health Innovation. To be completed by March 31, 2024.
FAC accepted this audit on March 27, 2023 — management decision was due September 27, 2023.
U.S Department of Education ? Student Financial Assistance Cluster CFDA No. 84.007, Federal Supplemental Educational Opportunity Grant Program CFDA No. 84.033, Federal Work Study Program CFDA No. 84.038, Federal Perkins Loan Program CFDA No. 84.379, Teacher Educational Assistance for College and Higher Education Grants CFDA No. 93.264, Nursing Faculty Loan Program CFDA No. 84.268, Federal Direct Student Loan Program CFDA No. 84.063, Federal Pell Grant Program Program Year 2021-2022 Criteria or specific requirement ? Special Tests and Provisions ? Return of Title IV Funding (34 CFR 668.22) Condition ?Upon a student?s withdrawal from the program, the University is required to determine whether student financial aid should be refunded to the Department of Education. Questioned Costs ? There were no questioned costs as a result of this finding. Context ? From a sample of 40 return of Title IV funds tested (population of 406 students with return of title IV funds), two students had funds that were not timely returned. Our sampling method was not, and was not intended to be, statistically valid. Effect ? Amounts of Title IV funds to be returned to the Department of Education were not returned timely. Cause ? Delayed notification of student withdrawal dates to the parties responsible for the completion of the Return to Title IV calculation hindered the timely return of funds. Identification as a repeat finding ? No. Recommendation ? We recommend further training of individuals responsible for Title IV refunds to decrease the lag time between official withdrawal notification and the return of funds.
Show full finding ▾Hide full finding ▴U.S Department of Education ? Student Financial Assistance Cluster CFDA No. 84.007, Federal Supplemental Educational Opportunity Grant Program CFDA No. 84.033, Federal Work Study Program CFDA No. 84.038, Federal Perkins Loan Program CFDA No. 84.379, Teacher Educational Assistance for College and Higher Education Grants CFDA No. 93.264, Nursing Faculty Loan Program CFDA No. 84.268, Federal Direct Student Loan Program CFDA No. 84.063, Federal Pell Grant Program Program Year 2021-2022 Criteria or specific requirement ? Special Tests and Provisions ? Return of Title IV Funding (34 CFR 668.22) Condition ?Upon a student?s withdrawal from the program, the University is required to determine whether student financial aid should be refunded to the Department of Education. Questioned Costs ? There were no questioned costs as a result of this finding. Context ? From a sample of 40 return of Title IV funds tested (population of 406 students with return of title IV funds), two students had funds that were not timely returned. Our sampling method was not, and was not intended to be, statistically valid. Effect ? Amounts of Title IV funds to be returned to the Department of Education were not returned timely. Cause ? Delayed notification of student withdrawal dates to the parties responsible for the completion of the Return to Title IV calculation hindered the timely return of funds. Identification as a repeat finding ? No. Recommendation ? We recommend further training of individuals responsible for Title IV refunds to decrease the lag time between official withdrawal notification and the return of funds.
Views of responsible officials and planned corrective action plan ? Northern Kentucky University will meet the requirements outlined by the U.S. Department of Education for treatment of Federal Aid funds (R2T4) when a student ceases to be enrolled prior to the end of a period of enrollment. The following corrective action will be taken by NKU to ensure compliance: ? The University will return funds within 45 days. ? The University will review its Return of Funds procedures to ensure compliance.
FAC accepted this audit on October 31, 2021 — management decision was due May 1, 2022.
FAC accepted this audit on May 23, 2021 — management decision was due November 23, 2021.
FAC accepted this audit on January 12, 2020 — management decision was due July 12, 2020.
FAC accepted this audit on October 18, 2018 — management decision was due April 18, 2019.
FAC accepted this audit on November 2, 2017 — management decision was due May 2, 2018.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on October 25, 2016 — management decision was due April 25, 2017.
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