EIN: 620516509
UEI: HMEYL2VB2M57
Audited by: CapinCrouse LLC
Oversight agency: 84 [Department of Education]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 19, 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 19, 2026 (77 days ago).
What is a management decision? →FAC accepted this audit on December 11, 2024 — management decision was due June 11, 2025.
The University did not always return Title IV aid timely when a student failed to begin attendance as evidenced by academic engagement. Criteria: 34 CFR 668.21 Questioned Costs: $5,071 Context: Out of 19 students tested for timely Return to Title IV, there was 1 student identified who did not begin attendance based on their online academic activity. This resulted in questioned costs of $5,071 in unsubsidized federal direct loans that should have been returned to Department of Education within 30 days of the term’s start. This was corrected during the audit. Cause: The University did not properly review students with zero credits who received Title IV aid to determine if students had academic activity to establish attendance. Effect: Title IV funds were not returned timely. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the University reviews online academic activity, in addition to the professor’s evaluation, to confirm the last date of attendance for the student to be able to properly evaluate if an R2T4 is required. The University should also have procedures in place to determine if students actually begin attendance in each class of the term for which they receive Title IV aid. If the last date of attendance cannot be identified, the University should default to the midpoint of the term for the R2T4, in line with the University’s policy and non-attendance taking regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Return of Title IV Funds for Failure to Begin Attendance DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2023-2024 Award Year Condition: The University did not always return Title IV aid timely when a student failed to begin attendance as evidenced by academic engagement. Criteria: 34 CFR 668.21 Questioned Costs: $5,071 Context: Out of 19 students tested for timely Return to Title IV, there was 1 student identified who did not begin attendance based on their online academic activity. This resulted in questioned costs of $5,071 in unsubsidized federal direct loans that should have been returned to Department of Education within 30 days of the term’s start. This was corrected during the audit. Cause: The University did not properly review students with zero credits who received Title IV aid to determine if students had academic activity to establish attendance. Effect: Title IV funds were not returned timely. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the University reviews online academic activity, in addition to the professor’s evaluation, to confirm the last date of attendance for the student to be able to properly evaluate if an R2T4 is required. The University should also have procedures in place to determine if students actually begin attendance in each class of the term for which they receive Title IV aid. If the last date of attendance cannot be identified, the University should default to the midpoint of the term for the R2T4, in line with the University’s policy and non-attendance taking regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Return of Title IV Funds for Failure to Begin Attendance Planned Corrective Action: Management agrees with the auditors' comments, and the following actions will be taken to ensure compliance with Return of Title IV Funds for Failure to Begin Attendance. • The University’s Title IV Aid Committee convened on November 18, 2024, to address strategies for ensuring that appropriate documentation related to the unofficial withdrawal process is accurately collected by the Student Financial Aid Office. • To enhance the process, in addition to contacting professors via email for all students receiving zero credits in a term, two additional fields will be incorporated into the university's grading system. These fields will enable professors to indicate whether a student never attended the course and to record the last date of attendance. Amount Returned to the United States Department of Education: $5,071 • $5,071 was returned for the questioned student identified during the audit on November 20, 2024. It was determined that the student never started the course, and the entire amount of the loan was returned. Person Responsible for Corrective Action Plan: Colby Benefield, Director of Student Financial Aid Anticipated Date of Completion: January 01, 2025
FAC accepted this audit on February 6, 2024 — management decision was due August 6, 2024.
FAC accepted this audit on December 11, 2022 — management decision was due June 11, 2023.
FAC accepted this audit on December 12, 2021 — management decision was due June 12, 2022.
Return calculations were not done correctly consistently, particularly in the fall 2020 semester. Criteria: 34 CFR 668.22 Questioned Costs: $4,171 Context: Out of 20 students tested for official and unofficial withdrawals, 5 did not have an accurate calculation performed. All initial calculations and returns had been performed timely. The system set up for the fall semester was done incorrectly for two programs, leading to four incorrect calculations, including two returns of Pell when they were fully earned. Additionally, for two students, Pell was not first recalculated for the courses in which the student began attendance. The University is in the process of correcting all affected students and manually recalculating the students in these programs in fall 2020. Because of the error rate, this is classified as a material weakness. Cause: Pell was not first recalculated, and the system set up for fall 2020 was not done correctly. Effect: Incorrect amounts of federal funding were returned. There were over-returns of Pell of $2,935, under-returns of Pell of $4,129, under-returns of subsidized loans of $42, and over-returns of unsubsidized loans of $143. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend an individual with appropriate return calculation knowledge review each system set up and recalculate the first few withdrawals manually to ensure the system is functioning as intended. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Incorrect Return of Title IV Funds Calculations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2020-2021 Financial Aid Year Condition: Return calculations were not done correctly consistently, particularly in the fall 2020 semester. Criteria: 34 CFR 668.22 Questioned Costs: $4,171 Context: Out of 20 students tested for official and unofficial withdrawals, 5 did not have an accurate calculation performed. All initial calculations and returns had been performed timely. The system set up for the fall semester was done incorrectly for two programs, leading to four incorrect calculations, including two returns of Pell when they were fully earned. Additionally, for two students, Pell was not first recalculated for the courses in which the student began attendance. The University is in the process of correcting all affected students and manually recalculating the students in these programs in fall 2020. Because of the error rate, this is classified as a material weakness. Cause: Pell was not first recalculated, and the system set up for fall 2020 was not done correctly. Effect: Incorrect amounts of federal funding were returned. There were over-returns of Pell of $2,935, under-returns of Pell of $4,129, under-returns of subsidized loans of $42, and over-returns of unsubsidized loans of $143. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend an individual with appropriate return calculation knowledge review each system set up and recalculate the first few withdrawals manually to ensure the system is functioning as intended. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding Number: 2021-001 Incorrect Return of Title IV Funds Calculations Planned Corrective Action: Management agrees with the auditors' comments, and the following actions will be taken to ensure compliance with Title IV regulations regarding Return of Title IV Funds (R2T4) Calculations. ? The Office of Student Financial Planning (SFP) reviewed the R2T4 calculations from the 2020-2021 award year impacted by the improper setup in Colleague. First, SFP generated a report identifying all students who had an R2T4 calculation during the 2020-2021 award year affected by the improper configuration of Colleague. Then, SFP completed a recalculation for each student utilizing the U.S. Department of Education's (ED) Common Origination and Disbursement (COD) website. In addition to the five records, the auditor identified, this process found nine records in which the R2T4 calculation was incorrect. As a result of the new calculation, SFP corrected records, where additional Title IV aid was required to be sent back to ED. Likewise, Pell Grants returned to ED by the setup error is fixed on the student's account and disbursed in COD. ? For the 2021-2022 award year, SFP reevaluated all R2T4 calculations using the COD website. Additionally, the setup feature that caused the error in 2020-2021 in Colleague is corrected. However, the Office of Student Financial Planning will continue to perform the calculation on the COD website until 100% of Colleague calculations are confirmed. Person Responsible for Corrective Action Plan: Derek Moore, Director Anticipated Date of Completion: 11/10/2021
The NSLDS enrollment status effective date for withdrawals was not accurately sent to NSLDS from the system. Criteria: 34 CFR 685.309(b) Questioned Costs: $0 Context: Out of 76 students tested, 7 students had incorrect effective dates reported for their enrollment status. All of these students were official and unofficial withdrawals. Cause: The system tracks the last date of attendance, but this field was not the field being pulled for NSLDS enrollment reporting. Effect: The incorrect effective date impacts the student?s loan grace period, in school deferment eligibility, beginning loans payments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the student financial aid team and registrar work together, potentially including information technology, to ensure the appropriate fields are captured from the system for NSLDS enrollment reporting. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2020-2021 Financial Aid Year Condition: The NSLDS enrollment status effective date for withdrawals was not accurately sent to NSLDS from the system. Criteria: 34 CFR 685.309(b) Questioned Costs: $0 Context: Out of 76 students tested, 7 students had incorrect effective dates reported for their enrollment status. All of these students were official and unofficial withdrawals. Cause: The system tracks the last date of attendance, but this field was not the field being pulled for NSLDS enrollment reporting. Effect: The incorrect effective date impacts the student?s loan grace period, in school deferment eligibility, beginning loans payments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the student financial aid team and registrar work together, potentially including information technology, to ensure the appropriate fields are captured from the system for NSLDS enrollment reporting. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding Number: 2021-002 Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Management agrees with the auditors' comments, and the following actions will be taken to ensure compliance NSLDS reporting requirements. ? The Office of Student Financial Planning has met with the IT department and Registrar?s office to communicate the importance of submitting the correct withdraw date to NSLDS. Currently, the report that is being generated and sent to NSLDS through the National Student Clearinghouse was using an auto populated field that did not accurately reflect the student?s withdrawal date. ? The IT department and the Registrar?s office has a meeting with Colleague to better understand why the report is not generating the correct date. ? For the 2021-2022 award year, the Office of Student Financial Planning will manually update NSLDS until the report that is generated in Colleague is correct. Person Responsible for Corrective Action Plan: Susan Hopper, Registrar Anticipated Date of Completion: 12/1/2021
FAC accepted this audit on January 17, 2021 — management decision was due July 17, 2021.
The College did not demonstrate adequate administrative capability over Title IV student financial aid programs to ensure compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $29,539 Context: In our testing, we found several areas of noncompliance. The financial aid system and staffing does not appear to be designed appropriately to support the current level of complexity for financial aid. Effect: Noncompliance with Title IV regulations. Cause: Staffing turnover. Not using the full functionality of the student financial aid system to assist in monitoring compliance with various Title IV regulations. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University reevaluate financial aid staffing and system design to address the issues identified. Views of Responsible Officials and Corrective Action Plan: Management is in agreement with the finding and is in the process of resolving the issue. See attached corrective action plan.
Show full finding ▾Hide full finding ▴2020-001 Administrative Capability Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.268, 84.063, 84.007, 84.033, and 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 19/20 Financial Aid Year Condition: The College did not demonstrate adequate administrative capability over Title IV student financial aid programs to ensure compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $29,539 Context: In our testing, we found several areas of noncompliance. The financial aid system and staffing does not appear to be designed appropriately to support the current level of complexity for financial aid. Effect: Noncompliance with Title IV regulations. Cause: Staffing turnover. Not using the full functionality of the student financial aid system to assist in monitoring compliance with various Title IV regulations. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University reevaluate financial aid staffing and system design to address the issues identified. Views of Responsible Officials and Corrective Action Plan: Management is in agreement with the finding and is in the process of resolving the issue. See attached corrective action plan.
Finding Number: 2020-001 Administrative Capability Planned Corrective Action: Management agrees with the auditors' comments, and the following actions will be taken to improve the situation and ensure compliance with Title IV regulations. ? The Office of Student Financial Planning experienced significant turnover in key positions during the 2019-2020 school year. Due to COVID 19, the ability to hire and train new employees was significantly impacted. ? The following four employees have been added, and we continue to provide ongoing training to each staff member to ensure Title IV Compliance. o Stephen Neu ? Financial Aid Operations Specialist (Loans & VA) ? Hired 03/01/2020 o Frances Lancaster ? Financial Aid Systems Specialist ? Hired 03/18/2020 o Jensen Vinson ? Financial Aid Operations Specialist (Adult Studies) ? Hired 11/03/2020 o Cathy Newman ? Receptionist ? Hired 11/11/2020 ? To provide additional accountability and support from senior level administrators, the Vice President of Enrollment Management and the President of the university are meeting monthly to evaluate Student Financial Planning personnel and ensure that current policies meet Title IV compliance standards. ? The Vice President of Enrollment Management is also providing weekly training covering all aspects of Title IV compliance. ? The Office of Student Financial Planning will evaluate and participate in training opportunities including Federal Student Aid E-Training, FSA Coach Fundamentals, Fundamentals of Federal Student Aid Administration, FSA Conference, and other federal and state training workshops. ? Effective immediately, our Systems Specialist in Student Financial Planning is running a report that will be monitored each week to resolve Institutional Student Information Record comment codes for each student pertaining to exceeded loan limits. ? Additionally, the Director of Student Financial Planning will continue to work with the University Registrar to ensure that all the qualified courses for Title IV aid purposes are added to Colleague and all students receive the correct Pell award. To address eligible students not receiving Pell awards for the summer, the Systems Specialist will work with Information Technology to run a report to identify any student enrolled in the summer that has not been awarded a Pell Grant. ? The Assistant Director of Student Financial Planning has already created a process to monitor unofficial withdrawals implemented in the Spring of 2020. This process has now been completed for the Fall 2019 semester as well. ? The Director of Student Financial Planning has corrected the Satisfactory Academic Progress report to ensure that all students not completing Satisfactory Academic Progress are now required to submit an appeal. Likewise, a new report will be created to monitor students who have taken a break from the institution to be monitored for Satisfactory Academic Progress. Also, the Systems Specialist in Student Financial Planning will collaborate with the University?s Information Technology staff to utilize Colleague to enhance the current Satisfactory Academic Progress process. Person Responsible for Corrective Action Plan: Paige Bates, Director of Student Financial Planning Anticipated Date of Completion: 06/30/2021
The University did not review all students with federal aid who had zero passing grades during a semester to determine if unearned Title IV funds were due back to the Department of Education. This resulted in late returns of Title IV funds. Criteria: 34 CFR 668.22(c) Questioned Costs: $12,474 Context: Out of 14 students tested, 6 students did not earn the zero passing grades as they ceased attendance, and a return of funds was required. 2 of these students were enrolled in the fall 2019 term and those funds have been returned as part of the audit process. 1 of these students was enrolled in the spring 2020 term and funds were returned but not timely (returns made in August 2020 and September 2020). 1 student enrolled in the spring term had funds returned late in August 2020 but the correct amount was not returned so an additional $460 should be returned. 1 on-line student enrolled in the spring term did not establish attendance other than logging on and therefore, all aid should have been returned rather than doing a return to Title IV calculation (R2T4). The original amount from the R2T4 was returned by September 2020 but an additional $357 of FDL should be returned. For 1 student enrolled in the spring term, the University incorrectly assessed the student as attending beyond 60% but the student?s date of last attendance as reported by a professor was before the 60% point of the term so an R2T4 should have been completed and $2,621 in FDL returned. Cause: Turnover in staffing. The University is required to review all students who have received federal aid and who had zero passing grades at the end of the semester to determine if the lack of a passing grade is due to nonattendance and requiring an R2T4. The University did not perform this review for the fall semester and was not timely in reviewing the spring term. Effect: Federal funds not earned by the student were not returned timely to the Department of Education. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University put procedures in place to timely review for potential unofficial withdrawals after each term for students with federal aid and no passing grades, returning any unearned aid within the required time frame. For unofficial withdrawals, the University can default to a 50% completion of the term for processing R2T4?s or determine a date of last attendance based on an academically related activity. No return is required if the student attends beyond 60%. We also recommend that the effective date of the student?s withdraw be updated in NSLDS to the last day of attendance. Views of Responsible Officials and Corrective Action Plan: Management is in agreement with the finding and is in the process of correcting the issue. See attached corrective action plan.
Show full finding ▾Hide full finding ▴2020-002 Failure to Monitor Students With Federal Aid Who Unofficially Withdrew Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.063, Pell Grants and 84.268, Federal Direct Loans Federal Award Identification #: 19/20 Financial Aid Year Condition: The University did not review all students with federal aid who had zero passing grades during a semester to determine if unearned Title IV funds were due back to the Department of Education. This resulted in late returns of Title IV funds. Criteria: 34 CFR 668.22(c) Questioned Costs: $12,474 Context: Out of 14 students tested, 6 students did not earn the zero passing grades as they ceased attendance, and a return of funds was required. 2 of these students were enrolled in the fall 2019 term and those funds have been returned as part of the audit process. 1 of these students was enrolled in the spring 2020 term and funds were returned but not timely (returns made in August 2020 and September 2020). 1 student enrolled in the spring term had funds returned late in August 2020 but the correct amount was not returned so an additional $460 should be returned. 1 on-line student enrolled in the spring term did not establish attendance other than logging on and therefore, all aid should have been returned rather than doing a return to Title IV calculation (R2T4). The original amount from the R2T4 was returned by September 2020 but an additional $357 of FDL should be returned. For 1 student enrolled in the spring term, the University incorrectly assessed the student as attending beyond 60% but the student?s date of last attendance as reported by a professor was before the 60% point of the term so an R2T4 should have been completed and $2,621 in FDL returned. Cause: Turnover in staffing. The University is required to review all students who have received federal aid and who had zero passing grades at the end of the semester to determine if the lack of a passing grade is due to nonattendance and requiring an R2T4. The University did not perform this review for the fall semester and was not timely in reviewing the spring term. Effect: Federal funds not earned by the student were not returned timely to the Department of Education. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University put procedures in place to timely review for potential unofficial withdrawals after each term for students with federal aid and no passing grades, returning any unearned aid within the required time frame. For unofficial withdrawals, the University can default to a 50% completion of the term for processing R2T4?s or determine a date of last attendance based on an academically related activity. No return is required if the student attends beyond 60%. We also recommend that the effective date of the student?s withdraw be updated in NSLDS to the last day of attendance. Views of Responsible Officials and Corrective Action Plan: Management is in agreement with the finding and is in the process of correcting the issue. See attached corrective action plan.
Finding Number: 2020-002 Failure to Monitor Students With Federal Aid Who Unofficially Withdrew Planned Corrective Action: Management agrees with the auditors' comments, and the following actions will be taken to improve the situation and ensure compliance with Title IV regulations. ? The Assistant Director of Student Financial Planning is now running a report and contacting faculty members to determine a last date of attendance for all students who have grades of all F?s for a given term. For the 2019-2020 school year this process was completed for the Spring 2020 and Summer terms prior to the audit, but the all F?s list for the Fall 2019 term was not conducted. Following the audit, 49 students in the Fall 2019 term were identified to have all F?s. o 14 of the 49 students did not receive any federal aid o 19 of the 49 students earned the F?s o 16 of the 49 students have had their last date of attendance calculated, and their aid was returned. Amount Returned to the United States Department of Education: $37,233.75 ? The returned funds include all aid identified by the auditor and those identified by the institution during a 100% file review. o $13,671 returned on 12/16/2020 o $10,081.75 returned on 12/18/2020 o $12,141 returned on 01/8/2021 o $1,340 returned on 01/14/2021 Person Responsible for Corrective Action Plan: Sabra Perez, Assistant Director of Student Financial Planning Anticipated Date of Completion: 01/15/2021
Pell was not awarded to students based on eligibility. Criteria: 34 CFR 690 Subpart F and G Questioned Costs: $0 Context: Out of 25 students tested, 3 students were not awarded Pell for enrollment in the summer 2020 term, resulting in under awarding of $4,634. 1 other student was disbursed Pell for three quarters time enrollment but the student ended up attending fulltime and therefore, was under awarded Pell by $744. Effect: Students were not awarded Pell grants based on eligibility. Cause: The University didn?t review Pell eligibility based on enrollment status changes. Summer Pell under awarding was an oversight by financial aid counselors. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University put procedures in place to review Pell eligibility in all terms especially when there are enrollment changes. Views of Responsible Officials and Corrective Action Plan: Management agrees with the findings and is in the process of addressing the issue. See corrective action plan.
Show full finding ▾Hide full finding ▴2020-003 Inaccurate Pell Awards Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.063, Pell Grants Federal Award Identification #: 19/20 Financial Aid Year Condition: Pell was not awarded to students based on eligibility. Criteria: 34 CFR 690 Subpart F and G Questioned Costs: $0 Context: Out of 25 students tested, 3 students were not awarded Pell for enrollment in the summer 2020 term, resulting in under awarding of $4,634. 1 other student was disbursed Pell for three quarters time enrollment but the student ended up attending fulltime and therefore, was under awarded Pell by $744. Effect: Students were not awarded Pell grants based on eligibility. Cause: The University didn?t review Pell eligibility based on enrollment status changes. Summer Pell under awarding was an oversight by financial aid counselors. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University put procedures in place to review Pell eligibility in all terms especially when there are enrollment changes. Views of Responsible Officials and Corrective Action Plan: Management agrees with the findings and is in the process of addressing the issue. See corrective action plan.
Finding Number: 2020-003 Inaccurate Pell Awards Planned Corrective Action: Management agrees with the auditors' comments, and the following actions will be taken to improve the situation and ensure compliance with Title IV regulations. ? The Systems Specialist of Student Financial Planning created a report including students who are Pell eligible, enrolled for at least 3 hours in the summer, and not awarded Pell. o Initial report has identified 126 potential students who were Pell eligible (including the three students identified by the auditor) and enrolled in the summer who were not awarded Pell. The Director of Student Financial Planning will need to manually check this list to complete a 100% file review to determine the proper amount of Pell that should have been awarded during the summer of 2020. o Potential amount under awarded identified during a 100% file review: $150,702 o The Pell award year for 2019-2020 is closed so it will need to be reopened to process the additional Pell amounts. ? The award analysis (FCAR) report in Colleague was run for the 2019-2020 school year to identify any students who were under awarded Pell for the Fall and Spring terms. Four students (including the student identified in the audit) were identified as under paid. o All four students are nursing majors who were enrolled in two courses with duplicate titles. o Amount under awarded for Fall and Spring: $8,355 ? To ensure ongoing compliance and guarantee students receive the proper amount of Pell, the FCAR will be run each month. ? The Director of Student Financial Planning will work the Office of Information Technology and the Systems Specialist of Student Financial Planning to ensure all potential students who are enrolled in the summer will be evaluated for Pell. Person Responsible for Corrective Action Plan: Paige Bates, Director of Student Financial Planning Anticipated Date of Completion: 03/01/2021
Students were over awarded FDL in excess of aggregate loan limits. Criteria: 34 CFR 685.203 (d) and (e) Questioned Costs: $6,416 Context: Out of 60 students tested, 3 students were disbursed FDL in excess of aggregate loan limits in the prior year making them ineligible for Title IV aid in 19/20 resulting in overawards of $3,073 in Pell and $3,343 in FDL. 1 student was overawarded loans in excess of aggregate loan limits for the 19/20 aid year but ended up reducing their request for loans in the spring term which kept the student under the aggregate loan limits. Effect: Disbursing FDL in excess of eligibility impacts eligibility for all Title IV aid unless the overaward is resolved. Cause: Turnover in personnel, ISIR comments regarding aggregate loan limits not properly resolved. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend procedures be put in place to adequately resolve ISIR comment codes that indicate student is close to or at loan limits. Views of Responsible Officials and Corrective Action Plan: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.
Show full finding ▾Hide full finding ▴2020-004 Over Awarding Federal Direct Loans (FDL) in Excess of Aggregate Loan Limits Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.268 Federal Direct Student Loans Federal Award Identification #: 19/20 Financial Aid Year Condition: Students were over awarded FDL in excess of aggregate loan limits. Criteria: 34 CFR 685.203 (d) and (e) Questioned Costs: $6,416 Context: Out of 60 students tested, 3 students were disbursed FDL in excess of aggregate loan limits in the prior year making them ineligible for Title IV aid in 19/20 resulting in overawards of $3,073 in Pell and $3,343 in FDL. 1 student was overawarded loans in excess of aggregate loan limits for the 19/20 aid year but ended up reducing their request for loans in the spring term which kept the student under the aggregate loan limits. Effect: Disbursing FDL in excess of eligibility impacts eligibility for all Title IV aid unless the overaward is resolved. Cause: Turnover in personnel, ISIR comments regarding aggregate loan limits not properly resolved. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend procedures be put in place to adequately resolve ISIR comment codes that indicate student is close to or at loan limits. Views of Responsible Officials and Corrective Action Plan: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.
Finding Number: 2020-004 Over Awarding Federal Direct Loans (FDL) in Excess of Aggregate Loan Limits Planned Corrective Action: Management agrees with the auditors' comments, and the following actions will be taken to improve the situation and ensure compliance with Title IV regulations. ? Created a report that identified anyone with a comment code of 254, 255, 256, 257, 258, 260, 392, & 393. The following students were detected on the report for 2019-2020 and had loans disbursed that had exceeded their loan limits. ? Reviewed the comment codes in Colleague to ensure that they were properly populating the communications screen (CRI). ? Provided additional training to staff to ensure that proper documentation was collected before resolving the comment code in Colleague. ? Two of the students identified on the audit had their funds returned on 11/20/20. ? After completing a review of 100% of the files for 2019-2020, another 40 students were identified as having one of the above comment codes. o 26 students were deemed to be eligible for aid o 10 students were within the aggerate limit and funds have been reallocated o 4 students were ineligible and funds were returned Amount Returned to the United States Department of Education: $21,659 ? The returned funds include all aid identified by the auditor and those identified by the institution during a 100% file review. o $21,659 returned on 01/14/2021 Person Responsible for Corrective Action Plan: Stephen Neu, Financial Aid Operations Specialist (Loans & VA) Anticipated Date of Completion: 01/15/2021
Students not meeting SAP when they ceased attendance were awarded Title IV aid when they were readmitted though the student was ineligible. Criteria: 34 CFR 668.34 Questioned Costs: $10,469 Context: When reviewing for potential unofficial withdraws due to no passing grades in the term, 2 students were identified as not meeting SAP and therefore ineligible for aid. 1 student was not meeting SAP for pace and the other student was not meeting SAP for GPA or pace. Effect: Awarding aid to ineligible students. Cause: The University did not evaluate SAP for students re-admitted after a break in enrollment. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University have procedures in place to review for SAP eligibility when students are readmitted after a break enrollment. Views of Responsible Officials and Corrective Action Plan: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.
Show full finding ▾Hide full finding ▴2020-005 Failure to Monitor Satisfactory Academic Progress (SAP) for Students With Breaks in Enrollment Significant Deficiency DEPARTMENT OF EDUCATION CFDA #: 84.268 Federal Direct Student Loans and 84.063 Pell Grants Federal Award Identification #: 19/20 Financial Aid Year Condition: Students not meeting SAP when they ceased attendance were awarded Title IV aid when they were readmitted though the student was ineligible. Criteria: 34 CFR 668.34 Questioned Costs: $10,469 Context: When reviewing for potential unofficial withdraws due to no passing grades in the term, 2 students were identified as not meeting SAP and therefore ineligible for aid. 1 student was not meeting SAP for pace and the other student was not meeting SAP for GPA or pace. Effect: Awarding aid to ineligible students. Cause: The University did not evaluate SAP for students re-admitted after a break in enrollment. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University have procedures in place to review for SAP eligibility when students are readmitted after a break enrollment. Views of Responsible Officials and Corrective Action Plan: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.
Finding Number: 2020-005 Failure to Monitor Satisfactory Academic Progress (SAP) for Students With Breaks in Enrollment Planned Corrective Action: Management agrees with the auditors' comments, and the following actions will be taken to improve the situation and ensure compliance with Title IV regulations. ? Created a report to identify all new incoming students with a GPA below 2.0 for each term. o Three undergraduate students were identified on SAP monitoring after a break in enrollment for 2019-2020. o One graduate student was identified as not meeting SAP after a break in enrollment for 2019-2020. Amount Returned to the United States Department of Education: $7,185 ? The returned funds include all aid identified by the auditor and those identified by the institution during a 100% file review. ? One of the students identified for this finding was also identified in finding 2020-004 and the returned funds are only documented in the previous finding. o $7,185 returned on 12/14/2020 Person Responsible for Corrective Action Plan: Paige Bates, Director of Student Financial Planning Anticipated Date of Completion: 01/15/2021
The University did not sufficiently comply with all requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: Risk assessment, appropriate vendor management, and safeguards are not documented. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Cause: The University was not aware of GLBA requirements. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding and is in the process of addressing the issue. See corrective action plan.
Show full finding ▾Hide full finding ▴2020-006 Gramm-Leach-Bliley-Act Compliance (GLBA) Significant Deficiency DEPARTMENT OF EDUCATION CFDA #: 84.268, 84.063, 84.007, 84.033 and 84.379 Federal Award Identification #: 19/20 Award Year Condition: The University did not sufficiently comply with all requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: Risk assessment, appropriate vendor management, and safeguards are not documented. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Cause: The University was not aware of GLBA requirements. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding and is in the process of addressing the issue. See corrective action plan.
Finding Number: 2020-006 Gramm-Leach-Bliley Act Compliance (GLBA) Planned Corrective Action: Management agrees with the auditors' comments, and the following actions will be taken to improve the situation and ensure compliance with Title IV regulations. ? Union University is currently working to develop, implement, and maintain a written Information Security Program to ensure that risks to student information have been sufficiently identified and that appropriate mitigating safeguards are designed and implemented. As identified and recommended in the audit, this plan will include: o Developing, implementing, and maintaining a written Information Security Program; designating the employee(s) responsible for coordinating the program; identifying and assessing the risks to student information, designing and implementing an information safeguards program, selecting appropriate service providers that are capable of maintaining appropriate safeguard, and periodically evaluating and updating our security program. Person Responsible for Corrective Action Plan: Jim R. Avery, Associate Vice President for Information Technology Anticipated Date of Completion: 01/15/2021
FAC accepted this audit on January 5, 2020 — management decision was due July 5, 2020.
FAC accepted this audit on April 29, 2019 — management decision was due October 29, 2019.
GSA_MIGRATION
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GSA_MIGRATION
2017-002
FAC accepted this audit on March 13, 2018 — management decision was due September 13, 2018.
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
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Show full finding ▾Hide full finding ▴FAC accepted this audit on January 29, 2017 — management decision was due July 29, 2017.
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