Milligan UniversityHigher Education

EIN: 620535755

UEI: SGGDBDWNHAM6

Audited by: Blackburn, Childers, & Steagall PLC

Oversight agency: 84 [Department of Education]

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Data as of August 28, 2026

Milligan University10 audit years4 findings1 repeat
10
Audit Years
4
Total Findings
1
Repeat Findings
$10.7M
Federal Awards Expended (FY 2025)

FY 2025-05-31

LOW-RISK AUDITEE$10,697,665 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on October 22, 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 April 22, 2026 (129 days ago).

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2025-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

During the audit, the Return to Title IV calculation for one student failed to include all aid disbursed or able to be disbursed in step one. Therefore, the calculated percentage of aid earned was applied a limited portion of the student’s federal aid, resulting in incorrect fund totals being returned. Questioned Costs: The known monetary error is $220 excess Federal Pell Grant funds being retained on the student’s behalf. During the audit, all students meeting the criteria to warrant a Return to Title IV calculation were tested, so no extrapolation of the monetary error is necessary beyond the identified error. The monetary impact of this deficiency does not exceed the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 9 files for students who withdrew mid-term during the 2024-2025 award year who had received Title IV awards, requiring the University to complete a Return to Title IV calculation. Of these students, this mistake was identified in one instance. Therefore, we consider the error rate as 1 out of the 9 total applicable students, which is 11.11%. Cause and Effect: This error was caused by an oversight by the personnel completing the Return to Title IV calculation, resulting in miscalculation of total Title IV aid earned. Recommendation: The director of financial aid completing any Return to Title IV calculations should ensure that all applicable aid is included in step one of the worksheet. Proper measures may be put into place to verify information input and review the calculation as a whole. View of Responsible Officials: The University concurs with the finding and has provided education and training for the staff responsible for refund calculations. The University will strengthen review procedures of refund calculations in the next award year to ensure compliance with federal guidelines.

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2025‐001 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education - William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal Supplemental Educational Opportunity Grant, ALN #84.007; Teacher Education Assistance for College and Higher Education Grant, ALN #84.379) Criteria: In accordance with the 2024-2025 Federal Student Aid Handbook and 34 CFR 668.22, a school must calculate the amount of earned Title IV funds by applying a percentage to the total amount of Title IV program assistance that was disbursed and that could have been disbursed. Aid included in this calculation to be prorated includes assistance from the Direct Loan, Federal Pell Grant, Iraq and Afghanistan Service Grant, TEACH Grant, and FSEOG programs. Statement of Condition: During the audit, the Return to Title IV calculation for one student failed to include all aid disbursed or able to be disbursed in step one. Therefore, the calculated percentage of aid earned was applied a limited portion of the student’s federal aid, resulting in incorrect fund totals being returned. Questioned Costs: The known monetary error is $220 excess Federal Pell Grant funds being retained on the student’s behalf. During the audit, all students meeting the criteria to warrant a Return to Title IV calculation were tested, so no extrapolation of the monetary error is necessary beyond the identified error. The monetary impact of this deficiency does not exceed the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 9 files for students who withdrew mid-term during the 2024-2025 award year who had received Title IV awards, requiring the University to complete a Return to Title IV calculation. Of these students, this mistake was identified in one instance. Therefore, we consider the error rate as 1 out of the 9 total applicable students, which is 11.11%. Cause and Effect: This error was caused by an oversight by the personnel completing the Return to Title IV calculation, resulting in miscalculation of total Title IV aid earned. Recommendation: The director of financial aid completing any Return to Title IV calculations should ensure that all applicable aid is included in step one of the worksheet. Proper measures may be put into place to verify information input and review the calculation as a whole. View of Responsible Officials: The University concurs with the finding and has provided education and training for the staff responsible for refund calculations. The University will strengthen review procedures of refund calculations in the next award year to ensure compliance with federal guidelines.

Corrective Action Plan

Finding Reference Number: 2025-001 Return to Title IV Funds Summary of Finding: During the R2T4 calculation, all Title IV funds from the Direct Loan, Federal Pell Grant, Iraq and Afghanistan Service Grant, TEACH Grant, and FSEOG programs that were disbursed or able to be disbursed should have be included in determining the amount of earned Title IV funds. In performing the calculation for one student, the institution failed to include all applicable federal aid resulting in $220 of excess Pell grant funds being retained on the student’s behalf. The excess funds of $220 were returned to the DOE in July 2025. Entity’s Corrective Action Plan: The University recognizes the importance of accuracy when performing R2T4 calculations. In this particular situation, the employee who performed the calculation was new in the role and had not previously had responsibility for R2T4 calculations. The University has reassigned this responsibility and has provided education and training for the staff responsible for R2T4 calculations for 2025-26. In addition, the University is requiring a review of each calculation by another member of the financial aid staff with knowledge and training on how to perform the calculations. Anticipated Completion Date: September 1, 2025 Name and Title of Responsible Person: Gus Morgan, Interim Financial Aid Director and VP for Enrollment Services

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2025-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCYQUESTIONED COSTS

During the audit, it was noted that multiples students appear to have been paid for Federal Work Study hours logged and submitted for time the student was scheduled to be in class. The reasons for overlap vary, but no reasonable exemption could be verified. Questioned Costs: The known monetary error is an over-payment of $99. Extrapolation of the error across all students and pay periods that may have been affected estimates total possible monetary error of $3,115. Therefore, the monetary impact of this deficiency does not exceed the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 9 files for students participating in the Federal Work Study program during the 2024-2025 award year, and limited detail testing of an additional 22 students’ Federal Work Study documents pertaining to this specific attribute. For the 31 students tested, auditors vouched class schedules, timecards, and paystubs for two specific pay periods, one in each semester. Of these students for the specific pay periods tested, overlap between submitted work study hours paid and classes scheduled without reasonable exception was identified in the records for five students. Therefore, we consider the error rate as 16.13%. Cause and Effect: In certain cases of conflicting times, class took place as scheduled, but the student was not present, choosing to work instead; other cases appear to be related to students being present in class, but also clocked into their work study position, resulting in payment for hours not worked at all. In all instances, supervisors did not identify the conflicts when reviewing and submitting timesheets for payroll processing and funds were paid to the students for the overlapping times, which is prohibited without an adequate exemption that has been appropriately documented. Recommendation: The University should ensure that proper safeguards, in both software and personnel, are in place to prevent, identify, and remediate such errors to prevent over-payment of federal aid funds. View of Responsible Officials: The University concurs with the finding. The University provided a reminder via email to all students and supervisors each pay period throughout the year that students are not allowed to work during scheduled class times without documentation. Supervisor training was required of all FWS supervisors in August 2025 to emphasize the importance of compliance with this specific aspect of FWS as well as all other federal requirements governing the FWS program. Supervisors are expected to monitor when their students are beginning work and request documentation if clock-in, or any period of their work, falls within a scheduled class period.

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2025‐002 Significant Deficiency: Working During Scheduled Class Time (U.S. Department of Education - Federal Work Study Program, ALN #84.033) Criteria: In accordance with the 2024-2025 Federal Student Aid Handbook, in general, students are not permitted to work in Federal Work Study positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented. Statement of Condition: During the audit, it was noted that multiples students appear to have been paid for Federal Work Study hours logged and submitted for time the student was scheduled to be in class. The reasons for overlap vary, but no reasonable exemption could be verified. Questioned Costs: The known monetary error is an over-payment of $99. Extrapolation of the error across all students and pay periods that may have been affected estimates total possible monetary error of $3,115. Therefore, the monetary impact of this deficiency does not exceed the reporting threshold of $25,000. Perspective Information: The audit included a detailed testing of 9 files for students participating in the Federal Work Study program during the 2024-2025 award year, and limited detail testing of an additional 22 students’ Federal Work Study documents pertaining to this specific attribute. For the 31 students tested, auditors vouched class schedules, timecards, and paystubs for two specific pay periods, one in each semester. Of these students for the specific pay periods tested, overlap between submitted work study hours paid and classes scheduled without reasonable exception was identified in the records for five students. Therefore, we consider the error rate as 16.13%. Cause and Effect: In certain cases of conflicting times, class took place as scheduled, but the student was not present, choosing to work instead; other cases appear to be related to students being present in class, but also clocked into their work study position, resulting in payment for hours not worked at all. In all instances, supervisors did not identify the conflicts when reviewing and submitting timesheets for payroll processing and funds were paid to the students for the overlapping times, which is prohibited without an adequate exemption that has been appropriately documented. Recommendation: The University should ensure that proper safeguards, in both software and personnel, are in place to prevent, identify, and remediate such errors to prevent over-payment of federal aid funds. View of Responsible Officials: The University concurs with the finding. The University provided a reminder via email to all students and supervisors each pay period throughout the year that students are not allowed to work during scheduled class times without documentation. Supervisor training was required of all FWS supervisors in August 2025 to emphasize the importance of compliance with this specific aspect of FWS as well as all other federal requirements governing the FWS program. Supervisors are expected to monitor when their students are beginning work and request documentation if clock-in, or any period of their work, falls within a scheduled class period.

Corrective Action Plan

Finding Reference Number: 2025-002 Working During Scheduled Class Time Summary of Finding: Students are not permitted to work in Federal Work Study positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community workstudy experience with exemptions being appropriately documented. The University had a few instances in which appropriate documentation for exemptions had not been obtained by the supervisors. The known error is $99 with extrapolation of the error across the population at $3,115. Entity’s Corrective Action Plan: The University understands the federal guidelines and provided reminders to all students and supervisors, via email, that students are not permitted to work during scheduled class times; the reminders were sent at the end of each pay period throughout the 2024-25 year. In August 2025, the University provided a required training session for all work study supervisors and reviewed the importance of compliance with this specific aspect of managing FWS as well as all other federal requirements governing the Federal Work Study Program. Supervisors and students continue to receive bi-monthly reminders of this policy. Supervisors are expected to monitor when their students are working and to know their students’ class schedules. They are expected to request documentation if clock-in times, or any period of their work shift, falls within a scheduled class time. Additionally, for 2025-26, the Human Resource Office is developing a review process to determine that appropriate documentation has been obtained if a student meets one of the eligible exemption criteria. Anticipated Completion Date: November 1, 2025 Name and Title of Responsible Person: Gus Morgan, Interim Financial Aid Director and VP for Enrollment Services and Rebecca Proffitt, Payroll and Student Employment Coordinator

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FY 2024-05-31

LOW-RISK AUDITEE$11,349,725 federal awards expendedNo findings recorded this year

FAC accepted this audit on October 10, 2024 — management decision was due April 10, 2025.

FY 2023-05-31

LOW-RISK AUDITEE$11,610,942 federal awards expendedNo findings recorded this year

FAC accepted this audit on November 30, 2023 — management decision was due May 30, 2024.

FY 2022-05-31

LOW-RISK AUDITEE$13,924,229 federal awards expendedNo findings recorded this year

FAC accepted this audit on October 20, 2022 — management decision was due April 20, 2023.

FY 2021-05-31

LOW-RISK AUDITEE$13,220,794 federal awards expendedNo findings recorded this year

FAC accepted this audit on November 3, 2021 — management decision was due May 3, 2022.

FY 2020-05-31

LOW-RISK AUDITEE$12,252,954 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 7, 2021 — management decision was due October 7, 2021.

FY 2019-05-31

LOW-RISK AUDITEE$11,260,595 federal awards expendedNo findings recorded this year

FAC accepted this audit on October 3, 2019 — management decision was due April 3, 2020.

FY 2018-05-31

LOW-RISK AUDITEE$10,970,291 federal awards expendedNo findings recorded this year

FAC accepted this audit on September 5, 2018 — management decision was due March 5, 2019.

FY 2017-05-31

LOW-RISK AUDITEE$9,758,751 federal awards expended

FAC accepted this audit on October 12, 2017 — management decision was due April 12, 2018.

2016-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2016-001OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-001

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FY 2016-05-31

LOW-RISK AUDITEE$9,476,364 federal awards expended

FAC accepted this audit on September 27, 2016 — management decision was due March 27, 2017.

2016-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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