EIN: 620497990
UEI: XJ3RAMR9JH25
Audited by: CapinCrouse LLC
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 December 2, 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 June 2, 2026 (89 days ago).
What is a management decision? →FAC accepted this audit on October 10, 2024 — management decision was due April 10, 2025.
FAC accepted this audit on November 2, 2023 — management decision was due May 2, 2024.
The University did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The University has not implemented multi-factor authentication on all systems containing personally identifiable information (PII), implemented formalized employee training program, documented in data retention policies disposal of PII, or provided a written, annual report to the board covering all required elements. Cause: The University has not codified and documented all informal practices occurring for compliance with GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University allocate sufficient resources to codify and document compliance with all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The University has not implemented multi-factor authentication on all systems containing personally identifiable information (PII), implemented formalized employee training program, documented in data retention policies disposal of PII, or provided a written, annual report to the board covering all required elements. Cause: The University has not codified and documented all informal practices occurring for compliance with GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University allocate sufficient resources to codify and document compliance with all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: 16 CFR 314.4(c)(1-8) – The university currently secures a large majority of its systems and data following best practice guidelines including Single Sign On (SSO), Multifactor Authentication (MFA), and Passwordless Authentication. However, there are a few systems remaining that have not yet been fully protected by these systems. The University will work to identify and migrate all systems containing PII to its authentication security systems. 16 CFR 314.(e) – The university currently provides security training through several avenues throughout the year. However, there is not currently a formal training plan. The university will create a formal training plan to include in-person and online annual training as well as smaller and more frequent refresher training throughout the year. 16 CFR 314.4(i) – The university currently advises the Cabinet on all matters concerning security effectiveness, however, no formal presentation has been given to the Board of Trustees. The university will create a formal report to present to the Board of Trustees beginning with their Fall 2023 meeting. Other finding: Moving forward, the university will enforce its data retention policies and dispose of all PII once the retention date has been reached. Person Responsible for Corrective Action Plan: (Dr. John Eberle, Chief Information Officer) Anticipated Date of Completion: May 2024
FAC accepted this audit on October 30, 2022 — management decision was due April 30, 2023.
When students withdrew either officially or unofficially, the College did not always return unearned Title IV aid timely due to late dates of determination. Additionally, there were several returns with the wrong information used in the calculation, causing the wrong amounts to be returned to Title IV. Criteria: 34 CFR 668.22 Questioned Costs: $1,042 Context: Out of 35 students tested for timely returns, there were 11 students who had a date of determination beyond 14 days. These delays resulted in 5 students with returns of Title IV funds totaling $10,565 ranging from 12 to 108 days late. Additionally, out of 35 students tested for proper R2T4 calculation, there were 5 students that had an incorrect R2T4 calculation, resulting in the wrong amount of funds returned. The errors included the wrong total number of calendar days, last date of attendance, and amounts actually disbursed. This resulted in $1,559 of unsubsidized loans being returned that were not required to be returned and $1,042 in additional Pell grants that need to be returned by the University. Cause: Due to the complexity of the new modular regulations, turn over in staffing, and delays from other offices, the University was not able to comply with Title IV regulations for timely and accurate returns. Effect: Noncompliance with new R2T4 regulations regarding withdrawals for modular students, late returns to Title IV, and inaccurate amounts returned to Title IV. Identification as repeat finding, if applicable: 2021-001 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review modular students? R2T4 calculations and returns to help ensure that internal controls over such process can operate effectively and achieve compliance. Additionally, we recommend the University work with other University offices to review Title IV regulations for attendance taking schools to work to achieve compliance on the timeliness of returns to Title IV. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Incorrect and Untimely Return of Title IV (R2T4) Funds Calculations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2021-22 Financial Aid Year Condition: When students withdrew either officially or unofficially, the College did not always return unearned Title IV aid timely due to late dates of determination. Additionally, there were several returns with the wrong information used in the calculation, causing the wrong amounts to be returned to Title IV. Criteria: 34 CFR 668.22 Questioned Costs: $1,042 Context: Out of 35 students tested for timely returns, there were 11 students who had a date of determination beyond 14 days. These delays resulted in 5 students with returns of Title IV funds totaling $10,565 ranging from 12 to 108 days late. Additionally, out of 35 students tested for proper R2T4 calculation, there were 5 students that had an incorrect R2T4 calculation, resulting in the wrong amount of funds returned. The errors included the wrong total number of calendar days, last date of attendance, and amounts actually disbursed. This resulted in $1,559 of unsubsidized loans being returned that were not required to be returned and $1,042 in additional Pell grants that need to be returned by the University. Cause: Due to the complexity of the new modular regulations, turn over in staffing, and delays from other offices, the University was not able to comply with Title IV regulations for timely and accurate returns. Effect: Noncompliance with new R2T4 regulations regarding withdrawals for modular students, late returns to Title IV, and inaccurate amounts returned to Title IV. Identification as repeat finding, if applicable: 2021-001 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review modular students? R2T4 calculations and returns to help ensure that internal controls over such process can operate effectively and achieve compliance. Additionally, we recommend the University work with other University offices to review Title IV regulations for attendance taking schools to work to achieve compliance on the timeliness of returns to Title IV. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV Funds (R2T4) Planned Corrective Action: Monthly meetings have been scheduled for the academic year to review completed R2T4?s. The director of financial aid and director of student financial services are also conducting additional training with staff to go over the areas of non-compliance that occurred. We have met with leadership on campus to address the issues with attendance tracking so that timely return of Title IV funds can be completed. Reminders have been sent to professors on attendance policies and procedures. These reminders include updated training materials. We have developed additional reports that will allow the University to monitor if attendance is being tracked by individual professors. Areas of non-compliance will be reported to the vice president for academic affairs and accreditation for follow up. Person Responsible for Corrective Action Plan: Kevin Reed, Director of Financial Aid, and Kylie Pruitt, Director of Student Financial Services Anticipated Date of Completion: October 15, 2022
2021-001
FAC accepted this audit on November 30, 2021 — management decision was due May 30, 2022.
The University returned Title IV funds for two modular student withdrawals that did not require funds to be returned based on the completion rate. Both students completed past the 49% required by the new modular withdrawal guidance that was early implemented by the University. Criteria: 34 CFR 668.22(a)(1) Questioned Costs: $0 Context: Out of 25 R2T4s tested, one student had $1,081 in Pell returned and one student had $3,033 in unsubsidized federal direct loans returned though the students were eligible to retain their Title IV funds. Cause: Implementation of new guidance and lack of review over individual R2T4 calculations due to staffing. Effect: Noncompliance with new R2T4 regulations regarding withdrawals from modular programs. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review modular students? R2T4 calculations and returns to help ensure that internal controls over such process can operate effectively and achieve compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴2021-001 Return of Title IV Funds (R2T4) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.063 and 84.268 Federal Award Identification #: 20/21 Financial Aid Year Condition: The University returned Title IV funds for two modular student withdrawals that did not require funds to be returned based on the completion rate. Both students completed past the 49% required by the new modular withdrawal guidance that was early implemented by the University. Criteria: 34 CFR 668.22(a)(1) Questioned Costs: $0 Context: Out of 25 R2T4s tested, one student had $1,081 in Pell returned and one student had $3,033 in unsubsidized federal direct loans returned though the students were eligible to retain their Title IV funds. Cause: Implementation of new guidance and lack of review over individual R2T4 calculations due to staffing. Effect: Noncompliance with new R2T4 regulations regarding withdrawals from modular programs. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review modular students? R2T4 calculations and returns to help ensure that internal controls over such process can operate effectively and achieve compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding Number: 2021-001 Return of Title IV Funds (R2T4) Planned Corrective Action: We have completed additional training on the new regulations with financial aid staff. We have scheduled monthly meetings to review R2T4s completed. We will continue with the review and ongoing training process in this area. Person Responsible for Corrective Action Plan: Kevin Reed, Director of Financial Aid and Kylie Pruitt, Director of Student Financial Services Anticipated Date of Completion: 11/4/2021
Verification was completed inaccurately for one student. Criteria: 34 CFR 668.56 Questioned Costs: $0 Context: Out of 16 tested for verification, one student had an incorrect number in household and number in family reported that caused a change in expected family contribution resulting in a $2,700 under award in the student?s Pell grant. Cause: Verification is completed manually by a member of the financial aid department. There was no review process to ensure that students selected for verification to catch any discrepancies due to staffing issues. Effect: Need based aid is impacted directly by the results of verification. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University periodically review verification completed for students with need-based aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴2021-002 Verification DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 20/21 Financial Aid Year Condition: Verification was completed inaccurately for one student. Criteria: 34 CFR 668.56 Questioned Costs: $0 Context: Out of 16 tested for verification, one student had an incorrect number in household and number in family reported that caused a change in expected family contribution resulting in a $2,700 under award in the student?s Pell grant. Cause: Verification is completed manually by a member of the financial aid department. There was no review process to ensure that students selected for verification to catch any discrepancies due to staffing issues. Effect: Need based aid is impacted directly by the results of verification. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University periodically review verification completed for students with need-based aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding Number: 2021-002 Verification Planned Corrective Action: We will review this finding with staff as a reminder to double check verification documents. We will also conduct periodic reviews for students selected for verification to ensure accuracy. Person Responsible for Corrective Action Plan: Kevin Reed, Director of Financial Aid and Kylie Pruitt, Director of Student Financial Services Anticipated Date of Completion: 12/1/2021
FAC accepted this audit on January 10, 2021 — management decision was due July 10, 2021.
FAC accepted this audit on October 24, 2019 — management decision was due April 24, 2020.
FAC accepted this audit on November 28, 2018 — management decision was due May 28, 2019.
GSA_MIGRATION
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GSA_MIGRATION
2017-001
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on August 31, 2017 — management decision was due March 3, 2018.
GSA_MIGRATION
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GSA_MIGRATION
2016-002
FAC accepted this audit on August 31, 2016 — management decision was due March 3, 2017.
GSA_MIGRATION
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GSA_MIGRATION
2015-001
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