EIN: 741109633
UEI: U4SCDG6B6NM8
Data as of August 27, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on November 5, 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 May 5, 2026 (115 days ago).
What is a management decision? →An error was identified for nineteen out of the forty judgmentally selected students for credit balance testing. For these students (per review of the Student’s account summary), we noted the date the student received their financial aid refund was outside of the 14 days after the first day of class/day in which a credit balance was reflected in the student’s accounts. Questioned costs: None Context: The student’s financial aid refund was not received within 14 days of the first day of class or the day in which a credit balance was triggered. Cause: The process begins with the Financial Aid office disbursing funds prior to the start of classes. Once school starts, the University standard operating procedure is to issue refunds after the add/drop period. While this timeline complies with the allowable window, the high volume of refunds combined with the manual review process resulted in several instances of refunds being made after the required 14 days. Effect: For some students, the financial aid refund was not processed timely. Repeat finding: No Recommendations: We recommend that the University revise existing controls, or add new controls, to ensure refunds are made timely. View of responsible officials: Management acknowledges the audit finding related to the timing of the Title IV credit balance refunds during FY25. Beginning in FY26, the University has transitioned to a new student information system, Workday, which significantly enhances our ability to manage financial aid disbursements and credit balance refunds in compliance with federal regulations. In the new system, financial aid disbursements will occur after the add/drop period, which better aligns with federal compliance timelines. Workday also provides automated reporting capabilities that allow the Student Financial Services office to easily identify students who have received Title IV funds, enabling staff to prioritize those accounts and ensure refunds are issued within the required timeframe. The system automates many manual processes, which increases efficiency and reduces the likelihood of delays. In addition, staff have received training on the new system and procedures, and an internal monitoring process is now in place to ensure continued compliance with refund requirements.
Show full finding ▾Hide full finding ▴Finding 2025-001 Federal program: Student Financial Assistance Cluster ALN# 84.007 Federal Supplemental Education Opportunity Grant Award Year: 2024/2025; ANL# 84.033 Federal Work-Study Program Award Year: 2024/2025; ALN# 84.038 Federal Perkins Loan Program Federal Capital Contributions; ALN# 84.063 Federal Pell Grant Program Award Year: 2024/2025; ALN# 84.268 Federal Direct Student Loans Award Year: 2024/2025 Type of finding: Significant Deficiency and Noncompliance Compliance requirement: Special Tests - Disbursements to and on Behalf of Students Criteria: Under the Code of Federal Regulations (CFR), specifically 34 CFR 668.164, a school must pay a student a Title IV credit balance no later than 14 days after the balance occurred. A credit balance is the remaining amount of federal financial aid after a student's tuition, fees, and other authorized charges have been paid. Per the 2024 Compliance Supplement, when Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed by the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. An institution is permitted to hold credit balances if it obtains a voluntary authorization from the student. Regardless of any authorization obtained by the institution, the institution must pay any remaining loan balance by the end of the loan period and any other remaining Title IV funds by the end of the last payment period in the award year for which the funds were awarded. Condition: An error was identified for nineteen out of the forty judgmentally selected students for credit balance testing. For these students (per review of the Student’s account summary), we noted the date the student received their financial aid refund was outside of the 14 days after the first day of class/day in which a credit balance was reflected in the student’s accounts. Questioned costs: None Context: The student’s financial aid refund was not received within 14 days of the first day of class or the day in which a credit balance was triggered. Cause: The process begins with the Financial Aid office disbursing funds prior to the start of classes. Once school starts, the University standard operating procedure is to issue refunds after the add/drop period. While this timeline complies with the allowable window, the high volume of refunds combined with the manual review process resulted in several instances of refunds being made after the required 14 days. Effect: For some students, the financial aid refund was not processed timely. Repeat finding: No Recommendations: We recommend that the University revise existing controls, or add new controls, to ensure refunds are made timely. View of responsible officials: Management acknowledges the audit finding related to the timing of the Title IV credit balance refunds during FY25. Beginning in FY26, the University has transitioned to a new student information system, Workday, which significantly enhances our ability to manage financial aid disbursements and credit balance refunds in compliance with federal regulations. In the new system, financial aid disbursements will occur after the add/drop period, which better aligns with federal compliance timelines. Workday also provides automated reporting capabilities that allow the Student Financial Services office to easily identify students who have received Title IV funds, enabling staff to prioritize those accounts and ensure refunds are issued within the required timeframe. The system automates many manual processes, which increases efficiency and reduces the likelihood of delays. In addition, staff have received training on the new system and procedures, and an internal monitoring process is now in place to ensure continued compliance with refund requirements.
Corrective Actions: Management acknowledges the audit finding related to the timing of the Title IV credit balance refunds during FY25. Beginning in FY26, the University has transitioned to a new student information system, Workday, which significantly enhances our ability to manage financial aid disbursements and credit balance refunds in compliance with federal regulations. In the new system, financial aid disbursements will occur after the add/drop period, which better aligns with federal compliance timelines. Workday also provides automated reporting capabilities that allow the Student Financial Services office to easily identify students who have received Title IV funds, enabling staff to prioritize those accounts and ensure refunds are issued within the required timeframe. The system automates many manual processes, which increases efficiency and reduces the likelihood of delays. In addition, staff have received training on the new system and procedures, and an internal monitoring process now in place to ensure continued compliance with refund requirements. Contact Clara Wells at cwells1@trinity.edu or (210)999-7333.
FAC accepted this audit on November 6, 2022 — management decision was due May 6, 2023.
Due to the timing of the prior year finding being identified, the award notification report, and first and second quarter reports for FY 2022 were also not posted timely as required. No issues were noted with the accuracy of the disclosure, but the timing was past the required due date. Questioned costs: None Context: The Student Aid grant awards were not reported on the University?s website on a timely basis for the first and second quarters of FY22. Cause: The University established reporting processes according to the compliance supplement. However, in the process of assigning responsibility for each reporting requirement, this requirement of updating the HEERF award disclosures quarterly was missed. Effect: The HEERF Student Aid award information was not reported publicly on the University?s website. As a result, students and other interested parties did not have readily presented access to this data. Repeat finding: Yes ? 2021-001. The finding is limited to the HEERF Student Aid first and second quarter reporting of FY22. Recommendations: We recommend that the University have controls in place to ensure that all required reporting is performed timely. Views of responsible officials: HEERF was issued to institutions of higher education in the spring of 2020 to support students and campus operations in the midst of the COVID-19 pandemic. Quarterly reporting requirements were later established by the Department of Education. Student Aid grant award reporting was overlooked by the responsible official due to confusion of duty with the emergency relief program. When the prior-year finding was identified, a system of controls was established to ensure future compliance and timely reporting. Specifically, the responsible reporting officials for the institutional and student portions of HEERF funding combined report information into a single web posting request prior to the deadline each quarter. This single request provided another check for the posting official to confirm the quarterly report was comprehensive.
Show full finding ▾Hide full finding ▴Finding 2022-001 Federal program: Education Stabilization Fund -Higher Education Emergency Relief Fund (HEERF): COVID-19 CARES Act- Student Aid Portion AL #: 84.425E Award Year: 2021/2022 Type of finding: Deficiency and Noncompliance Compliance requirement: Reporting - Special Reporting Criteria: Under 2 CFR 200.328 and 200.329, Universities must publicly post certain information relating to Student Aid awards on their website no later than 30 days after award, and update that information within 10 days after the end of every calendar quarter by posting a new report. Condition: Due to the timing of the prior year finding being identified, the award notification report, and first and second quarter reports for FY 2022 were also not posted timely as required. No issues were noted with the accuracy of the disclosure, but the timing was past the required due date. Questioned costs: None Context: The Student Aid grant awards were not reported on the University?s website on a timely basis for the first and second quarters of FY22. Cause: The University established reporting processes according to the compliance supplement. However, in the process of assigning responsibility for each reporting requirement, this requirement of updating the HEERF award disclosures quarterly was missed. Effect: The HEERF Student Aid award information was not reported publicly on the University?s website. As a result, students and other interested parties did not have readily presented access to this data. Repeat finding: Yes ? 2021-001. The finding is limited to the HEERF Student Aid first and second quarter reporting of FY22. Recommendations: We recommend that the University have controls in place to ensure that all required reporting is performed timely. Views of responsible officials: HEERF was issued to institutions of higher education in the spring of 2020 to support students and campus operations in the midst of the COVID-19 pandemic. Quarterly reporting requirements were later established by the Department of Education. Student Aid grant award reporting was overlooked by the responsible official due to confusion of duty with the emergency relief program. When the prior-year finding was identified, a system of controls was established to ensure future compliance and timely reporting. Specifically, the responsible reporting officials for the institutional and student portions of HEERF funding combined report information into a single web posting request prior to the deadline each quarter. This single request provided another check for the posting official to confirm the quarterly report was comprehensive.
Corrective Action Plan Audit Finding Reference: 2022-001 Planned Corrective Action: In response to audit finding 2022-001, the University has established a system of controls. When the prior- year finding was identified, the responsible reporting officials for the institutional and student portions of HEERF funding combined report information into a single web posting request prior to the deadline each quarter. This single request provided another check for the posting official to confirm the quarterly report is comprehensive. Date of Remediation: September 2021 Contact Person Responsible: Christina Pikla
2021-001
The original MPN was not retained for one of the 16 judgmentally selected loans that were assigned in the previous three fiscal years and current fiscal year. The University had already identified nine missing MPNs in their loan assignment process, an additional eight to our one finding. We then expanded our sample, excluding these eight known missing MPNs, and tested an additional eight selections, noting no additional errors. Questioned costs: None Context: The University failed to maintain true and exact copies of MPNs. Cause: The University did not have a policy in place prior to 2005 when they began using a third-party servicer to ensure MPNs were retained for students. Effect: Not maintaining the original MPN for a student could cause problems with verifying the existence of the associated loan and any legally required repayment. This could also cause the University to purchase the loan. Repeat finding: No. Recommendations: We recommend that the University have controls in place to ensure that all required documentation is retained in compliance with Perkins Loan requirements. Views of responsible officials: The current policy requires a master promissory note (MPN) to be stored in a locked, fireproof safe. The University acknowledges there may have been gaps in internal controls during the 1970s and 1980s resulting in the missing MPN. Since 2005, MPNs are electronically signed and maintained by ECSI, the third-party servicer. During 2022, Trinity submitted 154 loans to the Department of Education (DOE) for assignment. While the University did not have an MPN for nine of these loans, the DOE accepted all but one loan based on additional documentation provided in lieu of an MPN. To determine potential future exposure, the University reviewed paper files for the 25 borrowers with loans disbursed prior to 2005 and found only three additional borrowers with a missing MPN. If the University were required to purchase these loans from the DOE, the estimated purchase amount would be less than $30,000.
Show full finding ▾Hide full finding ▴Finding 2022-002 Federal program: Student Financial Assistance Cluster AL #: 84.038 Award Year: 2021/2022 Type of finding: Deficiency and Noncompliance Compliance requirement: Special Tests - Perkins Loan Recordkeeping and Record Retention Criteria: Under 34 CFR 674.19.(e), institutions must retain original or true and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan (including Defense, NDSL) made. Additionally, an institution shall retain repayment records, including cancellation and deferment requests for at least three years from the date on which a loan is assigned to the secretary, canceled, or repaid. An institution shall retain disbursement and electronic authentication and signature records for each loan made using an MPN for at least three years from the date the loan is canceled, repaid, or otherwise satisfied. Condition: The original MPN was not retained for one of the 16 judgmentally selected loans that were assigned in the previous three fiscal years and current fiscal year. The University had already identified nine missing MPNs in their loan assignment process, an additional eight to our one finding. We then expanded our sample, excluding these eight known missing MPNs, and tested an additional eight selections, noting no additional errors. Questioned costs: None Context: The University failed to maintain true and exact copies of MPNs. Cause: The University did not have a policy in place prior to 2005 when they began using a third-party servicer to ensure MPNs were retained for students. Effect: Not maintaining the original MPN for a student could cause problems with verifying the existence of the associated loan and any legally required repayment. This could also cause the University to purchase the loan. Repeat finding: No. Recommendations: We recommend that the University have controls in place to ensure that all required documentation is retained in compliance with Perkins Loan requirements. Views of responsible officials: The current policy requires a master promissory note (MPN) to be stored in a locked, fireproof safe. The University acknowledges there may have been gaps in internal controls during the 1970s and 1980s resulting in the missing MPN. Since 2005, MPNs are electronically signed and maintained by ECSI, the third-party servicer. During 2022, Trinity submitted 154 loans to the Department of Education (DOE) for assignment. While the University did not have an MPN for nine of these loans, the DOE accepted all but one loan based on additional documentation provided in lieu of an MPN. To determine potential future exposure, the University reviewed paper files for the 25 borrowers with loans disbursed prior to 2005 and found only three additional borrowers with a missing MPN. If the University were required to purchase these loans from the DOE, the estimated purchase amount would be less than $30,000.
Corrective Action Plan Audit Finding Reference: 2022-002 Planned Corrective Action: In response to audit finding 2022-002, the current policy requires a master promissory note (MPN) to be stored in a locked, fireproof safe. We acknowledge there may have been gaps in internal controls during the 1970s and 1980s resulting in the missing MPN. Since 2005, MPNs are electronically signed and maintained by ECSI, our third-party servicer. During 2022, Trinity submitted 154 loans to the Department of Education (DOE) for assignment. While the University did not have an MPN for nine of these loans, the DOE accepted all but one loan based on additional documentation provided in lieu of an MPN. To determine potential future exposure, the University reviewed paper files for the 25 borrowers with loans disbursed prior to 2005 and found only three additional borrowers with a missing MPN. If the University were required to purchase these loans from the DOE, the estimated purchase amount would be less than $30,000. Date of Remediation: October 2022 Contact Person Responsible: Clara Wells
FAC accepted this audit on November 1, 2021 — management decision was due May 1, 2022.
Upon review of the University?s disclosure of Student Aid awards, we noted that they were posted at year-end rather than on a quarterly basis. No issues were noted with the accuracy of the disclosure, but the timing was past the required due date. Questioned Costs: None Context: The Student Aid grant awards were not reported on the University?s website on a timely basis. Cause: The University established reporting processes according to the compliance supplement. However, in the process of assigning responsibility for each reporting requirement, this requirement of updating the HEERF award disclosures quarterly was missed. Effect: The HEERF Student Aid award information was not reported publicly on the University?s website. As a result, students and other interested parties did not have readily presented access to this data. Repeat Finding: No. The finding is limited to the HEERF Student Aid quarterly reporting. Recommendations: We recommend that the University have controls in place to ensure that all required reporting is performed timely.
Show full finding ▾Hide full finding ▴Finding 2021-001 Federal Program: Education Stabilization Fund -Higher Education Emergency Relief Fund (HEERF): COVID-19 CARES Act- Student Aid Portion AL #: 84.425E Federal Award Number: Not Applicable - Award Year: 2020/2021 Type of Finding: Deficiency and Noncompliance - Reporting Compliance Requirement: Reporting - Special Reporting Criteria: Per the Compliance Supplement Addendum 2020 4-84.425-HEERF, University?s must publicly post certain information relating to Student Aid awards on their website no later than 30 days after award, and update that information every quarter by posting a new report. Condition: Upon review of the University?s disclosure of Student Aid awards, we noted that they were posted at year-end rather than on a quarterly basis. No issues were noted with the accuracy of the disclosure, but the timing was past the required due date. Questioned Costs: None Context: The Student Aid grant awards were not reported on the University?s website on a timely basis. Cause: The University established reporting processes according to the compliance supplement. However, in the process of assigning responsibility for each reporting requirement, this requirement of updating the HEERF award disclosures quarterly was missed. Effect: The HEERF Student Aid award information was not reported publicly on the University?s website. As a result, students and other interested parties did not have readily presented access to this data. Repeat Finding: No. The finding is limited to the HEERF Student Aid quarterly reporting. Recommendations: We recommend that the University have controls in place to ensure that all required reporting is performed timely.
Corrective Action Plan Audit Finding Reference: 2021-001 Planned Corrective Action: In response to audit finding 2021-001, the University has established a system of controls. Specifically, the responsible reporting officials for the institutional and student portions of HEERF funding will combine report information into a single web posting request prior to the deadline each quarter. This single request will provide another check for the posting official to confirm the quarterly report is comprehensive. Date of Remediation: September 2021 Contact Person Responsible: Christina Pikla
FAC accepted this audit on November 18, 2019 — management decision was due May 18, 2020.
Twenty-five students were selected for Enrollment Reporting testing from a population of forty-two students who withdrew from the University. During our testing of this compliance requirement, we noted that one student out of the twenty-five judgmentally selected students tested did not have their withdrawal date reported to the NSLDS within thirty days. Questioned Costs: None Context: A student who was administratively withdrawn and had received federal loans was not reported to the NSLDS within the required time period. Cause: The following finding resulted in the failure to report one student to the NSLDS within the required time frame: ? The Dean of Students administratively withdrew a student in March. The Dean's assistant typically notifies the Registrar?s office, but the Dean sent the notification instead, and the email was overlooked. Two months later, it was brought to the Registrar?s attention that this student had been withdrawn. The Registrar?s office then acted immediately to communicate the unprocessed student to the Student Financial Aid office and report the change of status to the NSLDS. The status change was submitted approximately two weeks after the deadline. Effect: Lenders are not able to correctly assess when students should begin their grace period or enter loan repayment. Repeat Finding : No.Recommendations: We recommend that the University implement enhanced monitoring controls to ensure that all required reporting is done timely and accurately. We also recommend that the University conduct regular reviews of system-generated reports of administratively withdrawn students to ensure compliance.
Show full finding ▾Hide full finding ▴Finding 2019-001 Federal Program: U.S. Department of Education - Student Financial Assistance Cluster CFDA: 84.268 Federal Award Number: Not Applicable Award Year: 2018/2019 Type of Finding: Deficiency and Noncompliance - Special Tests and Provisions Compliance Requirement: Special Tests and Provisions ? Enrollment Reporting Criteria: Under 34 CFR 682.610, the University is required to report to the Secretary of the Department of Education when a student who has received a loan ceases to be enrolled on at least a half-time basis. The method for this reporting is the National Student Loan Data System (NSLDS). Per the NSLDS Enrollment Reporting Guide, students who withdraw from all courses or graduate are to be reported to NSLDS within thirty days as withdrawn as of the graduation date or the last date that attendance can be verified. Condition: Twenty-five students were selected for Enrollment Reporting testing from a population of forty-two students who withdrew from the University. During our testing of this compliance requirement, we noted that one student out of the twenty-five judgmentally selected students tested did not have their withdrawal date reported to the NSLDS within thirty days. Questioned Costs: None Context: A student who was administratively withdrawn and had received federal loans was not reported to the NSLDS within the required time period. Cause: The following finding resulted in the failure to report one student to the NSLDS within the required time frame: ? The Dean of Students administratively withdrew a student in March. The Dean's assistant typically notifies the Registrar?s office, but the Dean sent the notification instead, and the email was overlooked. Two months later, it was brought to the Registrar?s attention that this student had been withdrawn. The Registrar?s office then acted immediately to communicate the unprocessed student to the Student Financial Aid office and report the change of status to the NSLDS. The status change was submitted approximately two weeks after the deadline. Effect: Lenders are not able to correctly assess when students should begin their grace period or enter loan repayment. Repeat Finding : No.Recommendations: We recommend that the University implement enhanced monitoring controls to ensure that all required reporting is done timely and accurately. We also recommend that the University conduct regular reviews of system-generated reports of administratively withdrawn students to ensure compliance.
To ensure future compliance and accurate reporting, there is a need to develop a more standardized process for communicating withdrawals, both administrative and otherwise, which removes the possibility for emails to be missed or not received due to technical issues. This involves improvements to existing systems and procedures in both the Financial Aid and Registrar?s office. Recent enhancements to strengthen internal controls include: 1) correspondence relating to administrative withdrawals is now being sent by the Dean of Students to the Registrar?s office mailbox, which is monitored by five staff members, rather than just one individual, and 2) the Registrar?s office will request from the Dean of Students a monthly report of administrative withdrawals initiated by that office, and each student?s NSLDS record will be verified for compliance.
FAC accepted this audit on October 29, 2017 — management decision was due April 29, 2018.
GSA_MIGRATION
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GSA_MIGRATION
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