EIN: 620485724
UEI: DZSYVAL2PV73
Data as of August 19, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 3, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 3, 2025, which was (351 days ago).
What is a management decision? →Federal agency: U.S. Department of Commerce Federal program title: Connecting Minority Communities Pilot Program ALN: 11.028 Criteria or specific requirement: 2 CFR § 200.305 Federal payment stipulates a non-federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. Interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Commerce. Condition and Context: The Connecting Minority Communities Pilot Program funds drawn in advance were not limited to immediate cash requirements. Cause: Improper projection of immediate cash needs Effect: Excess cash maintained may not be available for use in other programs. Questioned costs: None Recommendation The College should implement a process to only drawdown funds for its immediate needs. Also, the College should compute interest earned on advance funds and refund the grantor when required.
Management agrees with the finding and recommendation. A process will be put in place to ensure the cash drawn down will be expended within the 30 day timeframe. The Controller will prepare the analysis and the CFO will approve as a part of the month end closing process.
Indirect Cost Federal agency: U.S. Department of Commerce Federal program title: Connecting Minority Communities Pilot Program ALN: 11.028 Criteria: 2 CFR 75.414 Indirect (F&A) costs states indirect (F&A) costs must be classified within two broad categories: “Facilities” and “Administration.” “Facilities” is defined as depreciation on buildings, equipment and capital improvement, interest on debt associated with certain buildings, equipment and capital improvements, and operations and maintenance expenses. “Administration” is defined as general administration and general expenses such as the director's office, accounting, personnel and all other types of expenditures not listed specifically under one of the subcategories of “Facilities” (including cross allocations from other pools, where applicable).” Condition and Context: The internal controls over recording and reporting indirect costs within the accounting system are not in place. Cause: The Institutions accounting system is not properly set up and there is no process for identifying indirect costs when processing transactions. Effect: Indirect costs charged of $36,217 was not clearly identified within the accounting system related the test of major programs and $66,027 related to non-major programs. Questioned costs: None Recommendation: Establish the correct classification of in the chart of accounts in accordance with 200.CFR 75.414 and incorporate a coding process to include recording indirect cost into the correct accounts. During the month-end close process allocate indirect cost to the grant/programs where indirect costs are.
Management agrees with the finding. The College is in the process of identifying an Enterprise Resource Planning system with a finance module to implement that will facilitate accounting for grants and strengthen internal controls. In the interim, management will restructure the general ledger in the current system to identify and classify appropriate costs and allocate through monthly journal entries. Monthly monitoring will take place and adjustments made when needed as a part of the month-end closing process.
Enrollment Status Change Federal agency: U.S. Department of Education Federal program title: Federal Direct Student Loan, Pell Grant, FSEOG ALN: 84.007, 84.063, 84.268 Criteria or specific requirement: Federal regulations 685.309(b)(2) and 682.610(c)(2) require institutions to report to NSLDS changes to a student’s enrollment status to less than half-time within 60 days of the date the school discovers that a student has ceased to be enrolled, or has failed to enroll, at least half-time. Condition and Context: The College did not update the enrollment status for seven of eight (88%) students within 60 days of the date students ceased to be enrolled, or has failed to enroll, at least half-time. Cause: The College’s controls for monitoring student enrollment changes was not operating effectively. Effect: Unreported student enrollment changes could result in incorrect calculation in the return of financial aid. Questioned costs: None Recommendation: Implement a policy to monitor student enrollment changes and update student changes within the required time-frame.
American Baptist College does not dispute this finding. It is the College’s policy to submit all records/documentation by published due dates. To do so, however, the College must have qualified employees to carry out stated requirements. Since July 2024 the College has published a job opening for the Director of Financial Aid but has been unable to fill the position due to limited resources. The College is currently working with a consulting firm to provide financial aid services to the student body and will publish the job position until it is filled.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on August 13, 2024. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by February 13, 2025, which was (553 days ago).
What is a management decision? →Identification and recording of revenues and expenses Criteria Revenues should be recorded in the period in which they are earned. Condition The College did not properly record earned grant revenue and related deferred revenue liabilities. Cause Improper reconciliation and review of revenue and related deferred liabilities allowed expenses that had previously been included in the schedule of expenditures and earned revenue to be duplicated. Effect Total revenue overstated by $578,963. This was the combination of Title IIIB revenue overstated by $797,154 and related deferred revenue liability understated by the same and FUTURE revenue understatement by $218,191 and related accrued asset by the same. Recommendation We recommend the College review and improve its policies, procedures, and controls related to the account reconciliations and review.
The College does not dispute this finding. The finding pertains to the College’s efforts to renovate its historic library to make it more accessible and user-friendly. To fund the project's initial phase, the renovations required the aggregation and carry-over of Title IIIB funds over multiple fiscal year periods. Before the commencement of construction, the Title IIIB program officer was informed of the College’s intent to dedicate the aggregated funds to the project. There was no indication from the Department of Education that such use would be an inappropriate practice. Because no blueprints or other construction documents were available for the mid-1950s era building, the College, and the construction professionals it utilized, anticipated that the project would experience unknown conditions and unanticipated material and equipment supply delays during the construction period that would increase the cost of the project. Some unknown conditions included a significant floor height discrepancy between building sections and extensive rock formations in the excavation area. The recording and reconciliation errors noted by the auditor above reflect the College’s attempt to ensure that it had sufficient cash on hand during the project to meet both anticipated and unanticipated expenses. Additionally, a second phase of the library modernization project involving HVAC, window system, and flooring upgrades was planned even before the beginning of the initial phase of construction. While few of the second-phase improvements were ultimately included in the initial stage, the College has proceeded with the remaining second-phase enhancements, including replacing existing windows and flooring. These items will be expensed in the next quarter (October-December 2022). The College now recognizes that the approach described above is unallowable, and will confine its future drawdowns of federal funds to actual, not speculative, expenditures. The Board will implement the above procedure immediately.
Cash Management Criteria or specific requirement: 2 CFR § 200.305 Federal payment stipulates a non-federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. Interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services. Condition and Context: The Title IIIB funds drawn in advance were not limited to immediate cash requirements. Cause: Due to the improper reconciliation of deferred revenue liability, although the college was drawing for immediate current payments, some of the construction related payments included in the current drawdowns had previously been obligated and included in the computation of the previous year’s expenditures and earned revenue. Effect: The School has drawn down funds above its immediate cash requirements. Questioned costs: None Recommendation The Institution follow controls to properly ensure that funds drawn have been used before drawing additional funds in order to minimize the time between receipt of funds from the granting agency and disbursement of those funds. The institution also needs to compute interest earned on advance funds and remit it to the grantor when required.
In the response for Finding# 2022-001, the College described the events that led to the excess funds on hand. The institution did not any earn interest on these funds. The College now recognizes that the approach used in Finding# 2022-01 is unallowable and will confine its future drawdowns of federal funds to actual, not speculative, expenditures. The Board will implement the above procedure immediately.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on April 26, 2022. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by October 26, 2022, which was (1394 days ago).
What is a management decision? →Finding # 2021-001 Status Change Reporting Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster CFDA Number: 84.007,84.033, 84.063, 84.268 Criteria The Code of Federal Regulations, 34 CFR 685.309(b) stipulates upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Condition: All two students who graduated were tested and both did not have timely status changes reported to NSLDS. Cause: The College did not follow its procedures for updating enrolment and reviewing submissions for accuracy. Effect: The NSLDS system is not updated with the student information, which can cause over awarding should the student transfer to another institution and the students, may not properly enter the repayment period. Questioned Costs: None Repeat Finding: Yes 2020-002. Recommendation: We recommend the College continue to review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS as required by regulations described above. View of Responsible Official (s) and Planned Corrective Action: American Baptist College does not dispute this finding. The College is in agreement with this finding and the recommendation provided. Although the college has improved our status reporting to 100%, we are still working toward consistency and efficiency in the established procedures as mentioned in the previous year audit corrective action. The Registrar and Financial Aid Office will continue to seek and participate in training relevant to this process and will continue working together to ensure compliance with this requirement. In addition to our previous corrective action plan, we will include in our weekly meetings reports of any changes to any student?s enrollment and update the Enrollment Report in that space to ensure we avoid this type of finding in the future.
Finding # 2021-001 Status Change Reporting Corrective Action American Baptist College does not dispute this finding. The College is in agreement with this finding and the recommendation provided. Although the college has improved our status reporting to 100%, we are still working toward consistency and efficiency in the established procedures as mentioned in the previous year audit corrective action. The Registrar and Financial Aid Office will continue to seek and participate in training relevant to this process and will continue working together to ensure compliance with this requirement. In addition to our previous corrective action plan, we will include in our weekly meetings reports of any changes to any student?s enrollment and update the Enrollment Report in that space to ensure we avoid this type of finding in the future. Anticipated Completion Date June 30, 2022 Name of Contact Person Kristie McQuiddy-Law, Director, Student Financial Aid Services
2020-001
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 2021. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 30, 2021, which was (1785 days ago).
What is a management decision? →Finding # 2020-002 Status Change Reporting Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster CFDA Number: 84.007,84.033, 84.063, 84.268 Criteria The Code of Federal Regulations, 34 CFR 685.309(b) stipulates upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Condition: Out of the fifteen students selected for testing, all fifteen did not have timely status changes reported to NSLDS. Cause: The College did not follow its procedures for updating enrolment and reviewing submissions for accuracy. Effect: The NSLDS system is not updated with the student information, which can cause over awarding should the student transfer to another institution and the students, may not properly enter the repayment period. Questioned Costs: None Repeat Finding: No similar finding was identified during the prior year. Recommendation: We recommend the College continue to review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS as required by regulations described above. View of Responsible Official (s) and Planned Corrective Action: The College is in agreement with and has already addressed this finding by providing the current Director of Financial Aid and the Registrar with training in December 2020 on enrollment reporting. As a result of that training, the enrollment report was updated and brought current according to the school's reporting schedule. Also, an updated procedure has been created as a reference to support this requirement and a scheduled reminders have been placed on the work calendars of the Director of Financial Aid and the Registrar to ensure compliance.
Finding # 2020-002 Status Change Reporting Corrective Action The College is in agreement with and has already addressed this finding by providing the current Director of Financial Aid and the Registrar with training in December 2020 on enrollment reporting. As a result of that training, the enrollment report was updated and brought current according to the school's reporting schedule. Also, an updated procedure has been created as a reference to support this requirement and a scheduled reminders have been placed on the work calendars of the Director of Financial Aid and the Registrar to ensure compliance. Anticipated Completion Date June 30, 2021 Name of Contact Person Kristie McQuiddy-Law, Director, Student Financial Aid Services
Finding # 2020-003 Exit Counseling Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster CFDA Number: 84.007,84.033, 84.063, 84.268 Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.304(b)(i) requires a school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school .The exit counseling must be in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions. Condition and Context: A review of students who graduated shows not all graduates received exist counseling. Of the thirteen students were tested, three did not receive exit counseling. Cause: Institution did not monitor the completion exit counseling. Effect: The School is not in compliance with counseling borrowers compliance requirements. Questioned costs: None Repeat Finding: No similar finding was identified during the prior year. Recommendation We recommend that the College review policies and adhere to procedures over the applicable counseling compliance requirements to ensure these requirements are met in accordance with federal regulations. Views of Responsible Official(s) and Planned Corrective Action The College is in agreement with this finding and the current Director of Financial Aid and the Registrar have created a "Graduation Application" that all students must complete and have signed by the appropriate College authorized official confirming that all federal and institutional requirements are completed prior to the conferral of the student's earned degree or the student?s participation in any graduation activities or ceremonies. This graduation application will serve as a "graduation checklist" to ensure that the student has met and/or completed all requirements necessary to graduate from the College, including loan exit counseling for applicable students.
Finding # 2020-003 Exit Counseling Corrective Action The College is in agreement with this finding and the current Director of Financial Aid and the Registrar have created a "Graduation Application" that all students must complete and have signed by the appropriate College authorized official confirming that all federal and institutional requirements are completed prior to the conferral of the student's earned degree or the student's participation in any graduation activities or ceremonies. This graduation application will serve as a "graduation checklist" to ensure that the student has met and/or completed all requirements necessary to graduate from the College, including loan exit counseling for applicable students. With respect to the Financial Aid portion of this checklist, the Director of Financial Aid will not sign any graduation application until he/she has confirmation that the student has completed the exit counseling either online or in-person (using the Direct Loan Exit Counseling Guide as a source), and confirmed that the student has met with the Director of Financial Aid or other authorized financial aid administrator upon completion of the exit counseling. This will ensure that no student will be allowed to receive a degree or participate in any graduation activities until all items and signature requirements have been completed. Anticipated Completion Date June 30, 2021 Name of Contact Person Kristie McQuiddy-Law, Director, Student Financial Aid Services
Finding # 2020-004 Cash Management Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster CFDA Number: 84.031B Criteria or specific requirement: 2 CFR ? 200.305 stipulates a non-federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. Interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually. Condition and Context: The Title III funds drawn in advance were not limited to immediate cash requirements. Cause: The Institution did not interpret the compliance requirement of immediate cash requirements appropriately. As a result the institution did not evaluate cash balances for cash management requirements, including the calculation of interest earnings. Effect: The School is not in compliance with cash management requirements. Questioned costs: None Recommendation The Institution follow controls to minimize the time between receipt of funds from the granting agency and disbursement of those funds. The institution also needs to compute interest earned on advance funds and remit it to the grantor when required. Views of Responsible Official(s) and Planned Corrective Action As of January 2021, the College implemented ?as needed? drawdowns for reimbursements to the Institution. The exception would be immediate cash requirements for large construction projects. A summary report of expenses will accompany the Drawdown Authorization form for the President, Title III Director, and Senior Management to review and approve with signatures before the Bursar executes the G5 draw. For construction projects, quotes and/or invoices will be presented with the Drawdown Authorization form. This enhanced process will also limit our exposure and non-compliance for ?excessive draws?.
Finding # 2020-004 Cash Management Corrective Action As of January 2021, the College implemented "as needed" drawdowns for reimbursements to the Institution. The exception would be immediate cash requirements for large construction projects. A summary report of expenses will accompany the Drawdown Authorization form for the President, Title III Director, and Senior Management to review and approve with signatures before the Bursar executes the G5 draw. For construction projects, quotes and/or invoices will be presented with the Drawdown Authorization form. This enhanced process will also limit our exposure and non-compliance for "excessive draws". Anticipated Completion Date June 30, 2021 Name of Contact Person: Brooke Bell, Assistant Vice President of Business Affairs
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 26, 2019. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by August 26, 2019, which was (2551 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
2017-002
GSA_MIGRATION
GSA_MIGRATION
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 20, 2017. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by June 20, 2018, which was (2983 days ago).
What is a management decision? →Management decision deadline — for entities that funded this organization
The FAC accepted this audit on April 3, 2017. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by October 3, 2017, which was (3243 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
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