EIN: 710477536
UEI: Q1B4EX3CTZM9
Audited by: Alvarez Mendoza LaBounty CPA
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 January 14, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by July 14, 2026 (47 days ago).
What is a management decision? →FAC accepted this audit on January 7, 2025 — management decision was due July 7, 2025.
In ten (10) of the thirteen (13) files tested that were subject to FWS regulations, we noted that the Institution’s records indicated a conflict between employment time and scheduled class time. The records showed that the student was employed and working hours as a federal work study student while also accumulating hours earned during class. Upon further investigation, many of the conflicts were due to the instructors allowing students to leave class early after completing assignments and presentations or cancelling class altogether. The students associated with this finding are B1, A1, A6, A7, A9, A10, A11, A13, A14, and A15. The instances of noncompliance were a result of a significant deficiency in the internal controls related to scheduling work study students. Cause: The cause was an oversight by staff. Effect: As a result, the Institution did not follow FWS conditions and limitations. Questioned Costs: $0 Prior to the issuance of this audit, $117.88 was refunded to FWS for the 22/23 award year and the Institution issued a corresponding institutional scholarship to each student to make them whole. Recommendation: Due to the error rate of FWS instances of noncompliance, the Institution should review and update its internal controls related to FWS to ensure that students are not working during scheduled class time and enhance communication between Federal Work Study supervisors and registration department to ensure instances of noncompliance do not recur. Views of Responsible Officials: We concur with this finding and have strengthened our controls to prevent future occurrences of non-compliance. Refer to the corrective action plan attached for more details.
Show full finding ▾Hide full finding ▴Finding 2024-001: FEDERAL WORK STUDY- WORKING DURING CLASS TIME Criteria: SFA Regulations state that working during scheduled class time is prohibited. Students are not permitted to work in FWS positions during scheduled class times unless certain exemptions are documented. FSA Handbook Volume 6 page 33 of 145. Condition: In ten (10) of the thirteen (13) files tested that were subject to FWS regulations, we noted that the Institution’s records indicated a conflict between employment time and scheduled class time. The records showed that the student was employed and working hours as a federal work study student while also accumulating hours earned during class. Upon further investigation, many of the conflicts were due to the instructors allowing students to leave class early after completing assignments and presentations or cancelling class altogether. The students associated with this finding are B1, A1, A6, A7, A9, A10, A11, A13, A14, and A15. The instances of noncompliance were a result of a significant deficiency in the internal controls related to scheduling work study students. Cause: The cause was an oversight by staff. Effect: As a result, the Institution did not follow FWS conditions and limitations. Questioned Costs: $0 Prior to the issuance of this audit, $117.88 was refunded to FWS for the 22/23 award year and the Institution issued a corresponding institutional scholarship to each student to make them whole. Recommendation: Due to the error rate of FWS instances of noncompliance, the Institution should review and update its internal controls related to FWS to ensure that students are not working during scheduled class time and enhance communication between Federal Work Study supervisors and registration department to ensure instances of noncompliance do not recur. Views of Responsible Officials: We concur with this finding and have strengthened our controls to prevent future occurrences of non-compliance. Refer to the corrective action plan attached for more details.
Finding2024-001: FEDERAL WORK STUDY-WORKING DURING CLASS TIME Comments on Finding and Recommendation(s): We concur with this finding. Due to the error rate of FWS instances of noncompliance, the Institution should review and update its internal controls related to FWS to ensure that students are not working during scheduled class time and enhance communication between Federal Work Study supervisors and registration department to ensure instances of noncompliance do not recur. Action Taken or Planned: 1} The school IT department is setting up the WorkEasy clock in/clock out system for students to lock students out of being able to clock in during scheduled class times. 2} Supervisors will examine each time card to verify no student has worked during scheduled class hours unless as defined in Volume 6 Chapter 2: Working During Scheduled Class Time Prohibited - "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." Documentation will be provided before the work is approved to be classified and paid as FWS wages earned. 3} Supervisors will be trained and required to sign a policy at the beginning of each award year or upon hire that states students are not permitted to work during scheduled class hours unless they meet one of the documented exceptions in Volume 6 Chapter 2. By signing this policy, supervisors agree that they may be subject to disciplinary action if they fail to abide this policy.
FAC accepted this audit on January 10, 2024 — management decision was due July 10, 2024.
FAC accepted this audit on December 9, 2022 — management decision was due June 9, 2023.
FAC accepted this audit on November 29, 2021 — management decision was due May 29, 2022.
FINDING 2021-001 ? Late Return of R2T4 CONDITION: The return of $753 of Title IV funds, for a student dropping out of school, was not made within the required 45 days. CRITERIA: 34 CFR 668.22 CONTEXT: Out of twenty-five (25) dropped student files, tested, one (1) student had Title IV funds that was returned late. CAUSE: The Institution?s staff did not follow institutional policies and procedures. In addition, this error was not detected due to the lack of a vigorous internal audit function. EFFECT: The Institution had access to Title IV funds to which it was not entitled. RECOMMENDATION: The Institution has sent all Title IV funds back to the United States Department of Education to reflect the proper amount per the R2T4. The Institution should consider implementing a more rigorous and structured internal audit function for the review of activity and documentation in the student files. VIEW OF RESPONSIBLE OFFICIALS: The Ecclesia College Financial Aid Director agrees with this finding. They had calculated the R2T4 correctly but had previously returned $1,210 (the amount the student had earned from Box 1) rather than the correct amount of $1,963. The Financial Aid Director simply looked at the wrong box which should not have happened. All other R2T4?s were performed correctly and the correct amounts were returned to the United States Department of Education. To ensure this does not occur again, Ecclesia College will submit not only the R2T4 calculations for review to its third party servicer, ECM; it will also submit the student ledger card to validate the correct line field has been used to calculate the return.
Show full finding ▾Hide full finding ▴FINDING 2021-001 ? Late Return of R2T4 CONDITION: The return of $753 of Title IV funds, for a student dropping out of school, was not made within the required 45 days. CRITERIA: 34 CFR 668.22 CONTEXT: Out of twenty-five (25) dropped student files, tested, one (1) student had Title IV funds that was returned late. CAUSE: The Institution?s staff did not follow institutional policies and procedures. In addition, this error was not detected due to the lack of a vigorous internal audit function. EFFECT: The Institution had access to Title IV funds to which it was not entitled. RECOMMENDATION: The Institution has sent all Title IV funds back to the United States Department of Education to reflect the proper amount per the R2T4. The Institution should consider implementing a more rigorous and structured internal audit function for the review of activity and documentation in the student files. VIEW OF RESPONSIBLE OFFICIALS: The Ecclesia College Financial Aid Director agrees with this finding. They had calculated the R2T4 correctly but had previously returned $1,210 (the amount the student had earned from Box 1) rather than the correct amount of $1,963. The Financial Aid Director simply looked at the wrong box which should not have happened. All other R2T4?s were performed correctly and the correct amounts were returned to the United States Department of Education. To ensure this does not occur again, Ecclesia College will submit not only the R2T4 calculations for review to its third party servicer, ECM; it will also submit the student ledger card to validate the correct line field has been used to calculate the return.
FINDING 2021-001 ? Late Return of R2T4 CONDITION: The return of $753 of Title IV funds, for a student dropping out of school, was not made within the required 45 days. CRITERIA: 34 CFR 668.22 CONTEXT: Out of twenty-five (25) dropped student files, tested, one (1) student had Title IV funds that was returned late. CAUSE: The Institution?s staff did not follow institutional policies and procedures. In addition, this error was not detected due to the lack of a vigorous internal audit function. EFFECT: The Institution had access to Title IV funds to which it was not entitled. RECOMMENDATION: The Institution has sent all Title IV funds back to the United States Department of Education to reflect the proper amount per the R2T4. The Institution should consider implementing a more rigorous and structured internal audit function for the review of activity and documentation in the student files. VIEW OF RESPONSIBLE OFFICIALS: The Ecclesia College Financial Aid Director agrees with this finding. They had calculated the R2T4 correctly but had previously returned $1,210 (the amount the student had earned from Box 1) rather than the correct amount of $1,963. The Financial Aid Director simply looked at the wrong box which should not have happened. All other R2T4?s were performed correctly and the correct amounts were returned to the United States Department of Education. To ensure this does not occur again, Ecclesia College will submit not only the R2T4 calculations for review to its third party servicer, ECM; it will also submit the student ledger card to validate the correct line field has been used to calculate the return.
FAC accepted this audit on December 27, 2020 — management decision was due June 27, 2021.
FINDING 2020-001 ? Inaccurate Enrollment Reporting to NSLDS CONDITION: The Institution did not accurately report the enrollment status to NSLDS for various students. CRITERIA: 34 CFR 685.309 CONTEXT: Out of fifty-five (55) student files tested, one (1) active student had inaccurate enrollment status reported to NSLDS. CAUSE: The Institutional staff were not following the Institution?s policies and procedures. EFFECT: Inaccurate and untimely student enrollment status reporting negatively affects the Department of Education?s ability to properly manage its student loan portfolio and may increase its costs. RECOMMENDATION: The Institution has updated the NSLDS records to reflect the correct dates. The Institution should implement a more vigorous internal audit function to focus on routine student file reviews to ensure institutional policies and procedures related to Title IV administration are being followed. VIEWS OF RESPONSIBLE OFFICIALS: The Institution agrees with the auditor?s finding and will implement his recommendation.
Show full finding ▾Hide full finding ▴FINDING 2020-001 ? Inaccurate Enrollment Reporting to NSLDS CONDITION: The Institution did not accurately report the enrollment status to NSLDS for various students. CRITERIA: 34 CFR 685.309 CONTEXT: Out of fifty-five (55) student files tested, one (1) active student had inaccurate enrollment status reported to NSLDS. CAUSE: The Institutional staff were not following the Institution?s policies and procedures. EFFECT: Inaccurate and untimely student enrollment status reporting negatively affects the Department of Education?s ability to properly manage its student loan portfolio and may increase its costs. RECOMMENDATION: The Institution has updated the NSLDS records to reflect the correct dates. The Institution should implement a more vigorous internal audit function to focus on routine student file reviews to ensure institutional policies and procedures related to Title IV administration are being followed. VIEWS OF RESPONSIBLE OFFICIALS: The Institution agrees with the auditor?s finding and will implement his recommendation.
FINDING 2020-001 ? Inaccurate Enrollment Reporting to NSLDS CONDITION: The Institution did not accurately report the enrollment status to NSLDS for various students. CRITERIA: 34 CFR 685.309 CONTEXT: Out of fifty-five (55) student files tested, one (1) active student had inaccurate enrollment status reported to NSLDS. CAUSE: The Institutional staff were not following the Institution?s policies and procedures. EFFECT: Inaccurate and untimely student enrollment status reporting negatively affects the Department of Education?s ability to properly manage its student loan portfolio and may increase its costs. RECOMMENDATION: The Institution has updated the NSLDS records to reflect the correct dates. The Institution should implement a more vigorous internal audit function to focus on routine student file reviews to ensure institutional policies and procedures related to Title IV administration are being followed. VIEWS OF RESPONSIBLE OFFICIALS: The Institution agrees with the auditor?s finding and will implement his recommendation.
FINDING 2020-002- Incorrect Disbursement Dates CONDITION: Disbursement dates per COD did not agree with the disbursement dates listed on the student ledger cards. CRITERIA: 34 CFR 668.164 CONTEXT: Out of fifty-five (55) student files tested, fourteen (14) students had incorrect disbursement dates per COD. CAUSE: The Institution did not follow the policies and procedures in place to review the Title IV activity accurately and timely. EFFECT: The Institution may have disbursed funds that did not comply with the Department of Education?s rules and regulations. RECOMMENDATION: The Institution?s Financial Aid staff recognized that the posting dates did not agree for some disbursements during the first half of the fiscal year. Once the staff recognized the problem, corrective actions were taken. No additional instances of non-compliance were identified during our testing of Title IV disbursements in the second half of the fiscal year. As a result, no recommendation is considered necessary. VIEWS OF RESPONSIBLE OFFICIALS: The Institution agrees with the auditor?s finding.
Show full finding ▾Hide full finding ▴FINDING 2020-002- Incorrect Disbursement Dates CONDITION: Disbursement dates per COD did not agree with the disbursement dates listed on the student ledger cards. CRITERIA: 34 CFR 668.164 CONTEXT: Out of fifty-five (55) student files tested, fourteen (14) students had incorrect disbursement dates per COD. CAUSE: The Institution did not follow the policies and procedures in place to review the Title IV activity accurately and timely. EFFECT: The Institution may have disbursed funds that did not comply with the Department of Education?s rules and regulations. RECOMMENDATION: The Institution?s Financial Aid staff recognized that the posting dates did not agree for some disbursements during the first half of the fiscal year. Once the staff recognized the problem, corrective actions were taken. No additional instances of non-compliance were identified during our testing of Title IV disbursements in the second half of the fiscal year. As a result, no recommendation is considered necessary. VIEWS OF RESPONSIBLE OFFICIALS: The Institution agrees with the auditor?s finding.
FINDING 2020-002- Incorrect Disbursement Dates CONDITION: Disbursement dates per COD did not agree with the disbursement dates listed on the student ledger cards. CRITERIA: 34 CFR 668.164 CONTEXT: Out of fifty-five (55) student files tested, fourteen (14) students had incorrect disbursement dates per COD. CAUSE: The Institution did not follow the policies and procedures in place to review the Title IV activity accurately and timely. EFFECT: The Institution may have disbursed funds that did not comply with the Department of Education?s rules and regulations. RECOMMENDATION: The Institution?s Financial Aid staff recognized that the posting dates did not agree for some disbursements during the first half of the fiscal year. Once the staff recognized the problem, corrective actions were taken. No additional instances of non-compliance were identified during our testing of Title IV disbursements in the second half of the fiscal year. As a result, no recommendation is considered necessary. VIEWS OF RESPONSIBLE OFFICIALS: The Institution agrees with the auditor?s finding.
FAC accepted this audit on November 19, 2019 — management decision was due May 19, 2020.
FINDING 2019-001 ? Cyber Security Deficiency CONDITION: The Institution has not yet implemented an information security program. It is in the process of performing the risk assessments and documenting the safeguards for each identified risk. CRITERIA: 16 CFR 314.4(b) CAUSE: The Institution was not aware of the requirement. EFFECT: Student financial records, which includes sensitive personal identifiable information pertaining to the administration of Title IV funds are possibly at risk to unauthorized access. RECOMMENDATION: 2019-001-a - The Institution should complete the implementation of its information security program as soon as possible. 2019-001-b ? The Institution should consider attending additional training courses to better understand ED rules and regulations. MANAGEMENT RESPONSE: The Institution agrees with the auditor?s finding. The Institution has not yet implemented an information security program. It is in the process of performing the risk assessments and documenting the safeguards for each identified risk.
Show full finding ▾Hide full finding ▴FINDING 2019-001 ? Cyber Security Deficiency CONDITION: The Institution has not yet implemented an information security program. It is in the process of performing the risk assessments and documenting the safeguards for each identified risk. CRITERIA: 16 CFR 314.4(b) CAUSE: The Institution was not aware of the requirement. EFFECT: Student financial records, which includes sensitive personal identifiable information pertaining to the administration of Title IV funds are possibly at risk to unauthorized access. RECOMMENDATION: 2019-001-a - The Institution should complete the implementation of its information security program as soon as possible. 2019-001-b ? The Institution should consider attending additional training courses to better understand ED rules and regulations. MANAGEMENT RESPONSE: The Institution agrees with the auditor?s finding. The Institution has not yet implemented an information security program. It is in the process of performing the risk assessments and documenting the safeguards for each identified risk.
FINDING 2019-001 ? Cyber Security Deficiency CONDITION: The Institution has not yet implemented an information security program. It is in the process of performing the risk assessments and documenting the safeguards for each identified risk. CRITERIA: 16 CFR 314.4(b) CAUSE: The Institution was not aware of the requirement. EFFECT: Student financial records, which includes sensitive personal identifiable information pertaining to the administration of Title IV funds are possibly at risk to unauthorized access. RECOMMENDATION: 2019-001-a - The Institution should complete the implementation of its information security program as soon as possible. 2019-001-b ? The Institution should consider attending additional training courses to better understand ED rules and regulations. MANAGEMENT RESPONSE: The Institution agrees with the auditor?s finding. The Institution has not yet implemented an information security program. It is in the process of performing the risk assessments and documenting the safeguards for each identified risk. VIEW OF RESPONSIBLE OFFICIALS: The Institution agrees with the auditors? finding and plan on implementing a vigorous internal auditing function.
Finding 2019-002 ? Late Return of Title IV Funds CRITERIA: 34 CFR 668.22 CONDITION: The return of Title IV funds, as a result of the student dropping out of school, was not made within the required 45 days. CONTEXT: The auditor discovered the errors during detail testing of accounts receivable. Students were not part of the sample. No issues were found relating to this matter in the sample pulled. CAUSE: The Institution?s staff did not follow institutional policies and procedures. In addition, this error was not detected due to the lack of vigorous internal audit function. EFFECT: The Institution had access to Title IV funds to which it was not entitled. RECOMMENDATION: The Institution should consider implementing a more rigorous and structured internal audit function for the review of activity and documentation in the student files. The Institution has since returned all of the Title IV funds due to the Department of Education. MANAGEMENT RESPONSE: The Institution agrees with the Auditor?s finding. The Institution has returned all of the Title IV funds due to the Department of Education.
Show full finding ▾Hide full finding ▴Finding 2019-002 ? Late Return of Title IV Funds CRITERIA: 34 CFR 668.22 CONDITION: The return of Title IV funds, as a result of the student dropping out of school, was not made within the required 45 days. CONTEXT: The auditor discovered the errors during detail testing of accounts receivable. Students were not part of the sample. No issues were found relating to this matter in the sample pulled. CAUSE: The Institution?s staff did not follow institutional policies and procedures. In addition, this error was not detected due to the lack of vigorous internal audit function. EFFECT: The Institution had access to Title IV funds to which it was not entitled. RECOMMENDATION: The Institution should consider implementing a more rigorous and structured internal audit function for the review of activity and documentation in the student files. The Institution has since returned all of the Title IV funds due to the Department of Education. MANAGEMENT RESPONSE: The Institution agrees with the Auditor?s finding. The Institution has returned all of the Title IV funds due to the Department of Education.
Finding 2019-002 ? Late Return of Title IV Funds CRITERIA: 34 CFR 668.22 CONDITION: The return of Title IV funds, as a result of the student dropping out of school, was not made within the required 45 days. CONTEXT: The auditor discovered the errors during detail testing of accounts receivable. Students were not part of the sample. No issues were found relating to this matter in the sample pulled. CAUSE: The Institution?s staff did not follow institutional policies and procedures. In addition, this error was not detected due to the lack of vigorous internal audit function. EFFECT: The Institution had access to Title IV funds to which it was not entitled. RECOMMENDATION: The Institution should consider implementing a more rigorous and structured internal audit function for the review of activity and documentation in the student files. The Institution has since returned all of the Title IV funds due to the Department of Education. MANAGEMENT RESPONSE: The Institution agrees with the Auditor?s finding. The Institution has returned all of the Title IV funds due to the Department of Education.
FAC accepted this audit on November 15, 2018 — management decision was due May 15, 2019.
FAC accepted this audit on December 4, 2017 — management decision was due June 4, 2018.
GSA_MIGRATION
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GSA_MIGRATION
2016-003
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on February 23, 2017 — management decision was due August 23, 2017.
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
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GSA_MIGRATION
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