EIN: 820200907
UEI: ELJHAMA4CQW5
Data as of August 19, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 27, 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 September 27, 2026 (38 days from today).
What is a management decision? →Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster – Various Assistance Listing Number: Various Federal Award Identification Number and Year: Various Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2024 through June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition: Durning our testing, it was noted that the change in status was reported outside the required 60 day window for 7 of the 40 students tested. Questioned Costs: None Cause: The University did not have a process in place to ensure the student who graduated or withdrew was reported timely. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely and accurately. Repeat Finding: No. Recommendation: We recommend the University reevaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure timely and accurate reporting. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Title: Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure timely and accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar’s Office and the Financial Aid Office jointly reviewed the processes and data-entry practices related to enrollment reporting to ensure they are applied consistently and accurately. A plan has been implemented to provide ongoing training for employees responsible for managing reporting data. In addition, both offices established clearer communication channels to support timely and accurate updates and agreed to conduct an annual review of these processes to maintain continued alignment. Name(s) of the contact person(s) responsible for corrective action: Stephen Field Planned completion date for corrective action plan: 3/18/2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on November 5, 2024. 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, 2025, which was (472 days ago).
What is a management decision? →Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster – Various Assistance Listing Number: Various Federal Award Identification Number and Year: Various Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding: * Significant Deficiency in Internal Control Over Compliance * Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition: During our testing, it was noted the effective date reported on the "Enrollment Level" and "Program Level" report in NSLDS was incorrect for the 2 out of the 40 students tested. Questioned Costs: None Cause: The University's processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. The effective date should be the student's last date of attendance and academically related activity. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the "Campus Level" and "Program Level". Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Title: Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the "Campus Level" and "Program Level". Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have confirmed that both Undergraduate and Graduate processes for enrollment reporting are aligned, we reviewed the processes, and provided updated training to all employees who enter dates in our record-keeping system. We have a plan in place to provide updated and timely training for any new employees responsible for NSLDS reporting data. Name(s) of the contact person(s) responsible for corrective action: Dwight R Berreth Planned completion date for corrective action plan. August 1, 2024
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on November 30, 2023. 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 30, 2024, which was (812 days ago).
What is a management decision? →2023-001 – Satisfactory Academic Progress Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.32(f) requires a student to maintain satisfactory academic progress (SAP) in his or her course of study according to the institution’s published standards of satisfactory academic progress that meet the requirements of 34 CFR 668.34. Condition: During our testing student eligibility, we noted one student of 40 tested that was not meeting the SAP requirements and no appeal was on file to make the student eligible to receive Title IV aid. Questioned Costs: None Cause: The University’s processes and controls did not ensure that SAP was measured prior to disbursing Title IV disbursements. Effect: The student received Title IV aid when they were not eligible to receive the aid. Repeat Finding: No Recommendation: We recommend the University review its SAP review policies to ensure it is completed timely and before Title IV disbursements occur. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.
Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review its SAP review policies to ensure it is completed timely and before Title IV disbursements occur. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Prior to this finding, in November 2022 our Registrar implemented a change in process to require a form when assigning either an L and I grade to a student. This ensures that the correct grade type is used in all cases depending on the nature of the work still outstanding. In doing so, it allows more accurate and timely assess a student’s GPA for SAP status on a regular schedule within the timeline expected for each type of grade when a final grade is determined. The Financial Aid office had also implemented an additional tracking mechanism outside of our ERP system to monitor the SAP status of each student to augment deficiencies in our ERP related to tracking the correct status over time. This tracking occurs regardless of the timing of a FAFSA being completed or the consistency of student enrollment from one semester to the next. This allows us to know the eligibility status of a student prior to awarding and disbursement, and require an appeal when appropriate. This was implemented May 2023. Regardless, as per policy and as we’ve been doing, we will continue to evaluate grade changes at the time of the next regular SAP evaluation period, and enforce the policy based on their status from that point forward. Name(s) of the contact person(s) responsible for corrective action: Dwight R Berreth Planned completion date for corrective action plan: August 2023
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 27, 2023. 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 September 27, 2023, which was (1058 days ago).
What is a management decision? →2022-001: Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425F Award Period: July 01, 2021 - June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The CRF subsections 200.317 through 200.326 address procurement standards within the Uniform Guidance. These standards include elements that should be included in a written procurement policy. Additionally, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215?. Condition: During testing, it was noted there was no documentation to ensure the vendors were not suspended or debarred. In addition, there was no documentation of a second review to ensure the vendors were not suspended or debarred. Questioned Costs: None Context: During testing, it was noted there was no documentation to ensure certain vendors were not suspended or debarred. Cause: The University?s control system to document the prevention of contracting with a suspended and barred vendor was not in place. Effect: The University could have paid a vendor who was suspended or barred at the time of payment. Repeat Finding: Yes, see 2021-001 Recommendation: We recommend documenting the vendor was checked on the SAM.gov website prior to payment. In addition, We also recommend a supervisor review the documentation prior to payment as a second review. Views of Responsible Officials: Management agrees with finding.
2022-001 Higher Education Emergency Relief Funds ? ALN 84.425F Recommendation: We recommend documenting the vendor was checked on the SAM.gov website prior to payment. In addition, We also recommend a supervisor review the documentation prior to payment as a second review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: For previously incurred expenses that later fall under the reimbursement guidelines of a Federal or State Grant, the University will review and insure any expenses we submit for reimbursement are verified through our grant procurement policy controls and if the vendor is suspended or disbarred. Name(s) of the contact person(s) responsible for corrective action: John Greentree, Controller Planned completion date for corrective action plan: Completed as of September 2022
2021-001
2022-002: Outstanding Checks Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Numbers: Various Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Condition: During our testing, we noted two outstanding checks which related to federal funding which were not returned to the Department of Education within the 240 days. Criteria or Specific Requirement: The Department of Education requires an institution must return to ED (notwithstanding any state law, such as a law that allows funds to escheat to the state) any Title IV funds, except FWS program funds, that it attempts to disburse directly to a student or parent but they do not receive. If a check is returned, or an EFT is rejected, the institution may make additional attempts to disburse the funds, provided that the attempts are made no later than 45 days after the funds were returned or rejected. If the institution does not make an additional attempt to disburse the funds, the funds must be returned before the end of the 45day period and no later than 240 days from the date of the initial attempt to disburse the funds (34 CFR 668.164(l)). Questioned Costs: None Context: During our testing, it was noted the University failed to return the funds in a timely manner. Cause: The University?s current process in place was not sufficient to ensure proper maintenance of outstanding checks. Possible Asserted Effect: The University was not in compliance with FSA regulations. Repeat Finding: No Recommendation: We recommend the University reviews outstanding checks regularly to ensure funds are returned to the Department of Education before 240 days of the original disbursement attempt. Views of Responsible Officials: Management agrees with finding.
2022-002 Student Financial Assistance Cluster ? ALN 84.007/84.033/84.038/84.063/84.268/84.379 Recommendation: We recommend the University reviews outstanding checks regularly to ensure funds are returned to the Department of Education before 240 days of the original disbursement attempt. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In the fall of 2021, the University changed banking relationships. Outstanding checks from the former bank were cancelled and a check was issued from the new bank. The reissuance of checks showed a flaw in our 240-day reconciliation tool which focused on the check date rather than the original disbursement date. This was an isolated issue and we have adjusted our 240-day review tool to calculate based on the original disbursement date. Name(s) of the contact person(s) responsible for corrective action: John Greentree, Controller Planned completion date for corrective action plan: Completed as of September 2022
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 28, 2022. 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 March 28, 2023, which was (1241 days ago).
What is a management decision? →2021-001: Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425F Award Period: July 01, 2020 - June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The CRF subsections 200.317 through 200.326 address procurement standards within the Uniform Guidance. These standards include elements that should be included in a written procurement policy. Additionally, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215?. Condition: During our testing we noted four vendors tested who were paid over $25,000 where there was no documentation to support the University verified the vendors were not suspended or debarred at the time of purchase. The University stated they completed the review however there was no documentation to support the completion of this step prior to entering into a procured transaction. Per review of the suspension and debarment list at the time of testing, we noted the vendors were neither suspended nor debarred. Questioned Costs: None Context: During testing, it was noted there was no documentation to ensure certain vendors were not suspended or debarred. Cause: The University?s control system to document the prevention of contracting with a suspended and barred vendor was not in place. Effect: The University could have paid a vendor who was suspended or barred at the time of payment. Repeat Finding: No Recommendation: We recommend the University review its existing procurement policies to ensure it is up to date with federal regulations. We also recommend documenting the vendor was checked on the SAM.gov website prior to executing a contract. Additionally, a supervisor review should be performed prior to contracting. This second review should be documented and retained to support the procurement requirements were followed and completed before entering into a covered transaction. Views of Responsible Officials: Management agrees with finding.
Suspension and Debarment Recommendation: We recommend the University review its existing procurement policies to ensure it is up to date with federal regulations. We also recommend documenting the vendor was checked on the SAM.gov website prior to executing a contract. Additionally, a supervisor review should be performed prior to contracting. This second review should be documented and retained to support the procurement requirements were followed and completed before entering into a covered transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In the future if we find that previously incurred expenses fall under the reimbursement guidelines of a Federal or State Grant, we will act to insure any expenses we submit for reimbursement has been verified through our grant procurement policy controls and that the vendor is an suspended or disbarred. Name(s) of the contact person(s) responsible for corrective action: John Greentree, Controller Planned completion date for corrective action plan: Completed as of September 2022
2021-002: HEERF Reporting Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425E, 84.425F Award Period: July 01, 2020 - June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Per Uniform Guidance 2 CFR 200.303, federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the college or university?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Colleges and universities were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition: During our testing we noted the March 31, 2021 quarterly institutional report as well as all FY21 quarterly student reports were not completed/ submitted as required. Questioned Costs: None Context: The University did not have a process to track the reporting requirements. In addition, there was a general lack of guidance from ED on reporting requirements. Cause: The University did not have someone tracking the requirements to ensure that they posted the reporting timely and accurately. Effect: The University did not comply with ED regulations by reporting accurate information as well as retaining support for the information reported to ensure accuracy. Repeat Finding: No Recommendation: We recommend the University review their reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. Views of Responsible Officials: Management agrees with finding.
Recommendation: We recommend the University review their reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: If there are future disbursements of government funds NNU will be certain to document each step in the filing and review process. We will designate a key compliance officer to insure we are meeting the Department of Education filing responsibilities accurately and on time no mater how late or retrospectively the documentation requirements are applied. Name(s) of the contact person(s) responsible for corrective action: John Greentree, Controller Planned completion date for corrective action plan: Completed as of September 2022
2021-003: COD Reporting Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063, 84.268, 84.379 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Condition: During our testing, we noted 4 of the 25 students tested had incorrect Pell disbursement dates reported to the Common Origination and Disbursement (COD) system. In addition, two of these Pell disbursements was not reported within the required 15 days. Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Questioned Costs: None Context: During our testing, it was noted that the University failed to timely and accurately report disbursement dates to COD. Cause: The University does not have a process in place to confirm COD disbursement dates agree to student records and ensure timely reporting. Possible Asserted Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: Yes, see 2020-001 Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. View of Responsible Official: Management agrees with finding.
COD Reporting Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Due to the occurrence of a similar issue related to the 2019-20 Audit, we had planned implementation of a process change but it was essentially after the completion of the 20-21 school year - July 31, 2021. Thus we implemented process and policy changes in July of 2021 that we continue to work to refine, as needed. We continue comparison of dates between COD and NNU and within our two modules (FA CX and SA JX) on campus. We now also have a process to have Student Accounts notify the Financial Aid office if there is a concern a disbursement process did not work as expected ? thus creating different dates in our system and COD. We continue to refine our processing with comparison reports to mitigate occurrences of disbursement dates not matching with COD. We hired an additional staff person to provide additional capacity for reconciliation of information. We are currently in the process of implementing a new ERP system on our campus. Name(s) of the contact person(s) responsible for corrective action: Dwight Berreth, Financial Aid Director Planned completion date for corrective action plan: July 31, 2021
2020-001
2021-004 Perkins Record Keeping Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Number: 84.038 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 674.19(e) states that institutions must retain original, true and exact copies of promissory and master promissory notes (MPN), repayment records, and cancellation and deferment requests for each Perkins loan made for at least three years from the date on which a loan is assigned to the Secretary, canceled or repaid. In addition, a college or university shall keep the original paper promissory note or original paper MPN and repayment schedules in a locked, fireproof container. Condition: During our testing, the institution was not able to provide listings of borrowers whose loans were assigned, canceled or repaid within the past three years. In addition, it was noted the master promissory notes and repayment schedules were not being kept in a fireproof container. Questioned Costs: None Context: The lists of loans could not be provided. Cause: The University?s current process in place was not sufficient to ensure proper maintenance of promissory notes. Effect: The University was not in compliance with the Perkins recordkeeping regulations. Repeat Finding: No Recommendation: We recommend the University review the requirements of the retention of Perkins documentation and modify their procedures accordingly to comply with the requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with finding.
Perkins Record Keeping Recommendation: We recommend the University review the requirements of the retention of Perkins documentation and modify their procedures accordingly to comply with the requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Being made aware of the required documentation standards, NNU is undertaking a process to digitalize our Perkins records. These records will be certified by the Student Accounts Manager as originals, scanned into a secure electronic file, and saved in redundancy on three data locations under NNU?s IT data storage polices. Name(s) of the contact person(s) responsible for corrective action: Molly Porter, Manager of Student Accounts Planned completion date for corrective action plan: Spring 2023
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on August 11, 2021. 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 February 11, 2022, which was (1651 days ago).
What is a management decision? →COD Reporting Department of Education Student Financial Assistance Cluster 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans 84.379 ? Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2019 to June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Condition: During our testing, we noted 3 of the 25 students tested had incorrect Pell disbursement dates and 2 of 25 students tested had incorrect Loan disbursement dates reported to the Common Origination and Disbursement (COD) system. In addition, one of the disbursements was not reported within the required 15 days and one disbursement was not reported in COD. Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Questioned Costs: None Context: During our testing, it was noted that the University failed to update COD disbursements with errors. Cause: The University does not have a process in place to confirm COD disbursement dates agree to student records. Possible Asserted Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. View of Responsible Official: There is no disagreement with the audit finding.
COD Reporting CFDA No: 84.063; 84.268; 84.379 Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: NNU understands that we have an ERP system deficiency with how our FA CX and SA JX modules sometimes interface and report changes to anticipated disbursement dates when aid actually disburses. We have historically done monthly reconciliation with COD only on the required area of disbursed dollars. We are exploring a new ERP to implement for the future. In the interim, we have added comparison of dates within the SA JX module and COD to our monthly reconciliation process. We will manually update the dates in COD when discrepancies are found. Name(s) of the contact person(s) responsible for corrective action: Dwight Berreth Planned completion date for corrective action plan: July 31, 2021
Past Due Notices Sent Untimely or Not Sent Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: 84.038 ? Federal Perkins Loans Award Period: July 1, 2019 to June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: The Code of Federal Regulation, 34 CFR 674.43 requires first overdue notice to a borrower within 15 days after the due date of the payment if the servicer has not received a payment, a request for deferment or a request for postponement or for cancellation. Further, a borrower shall receive a second overdue notice within 30 days after the first overdue notice is sent and a final demand letter within 15 days after the second overdue notice. The University at this time must inform the borrower that unless the institution receives a payment or a request for deferment, postponement, or cancellation within 30 days of the later, it will refer the account for collection or litigation and will report the default to a credit bureau. Condition: The University utilizes University Accounting Service, LLC (UAS) for its third party Perkins Loan servicing. This is a very common practice for colleges and universities in order to provide the most efficient and effective means to not only collect loans but meet the federal regulations for servicing student Perkins Loans. In auditing the compliance features for the loan servicing, CLA utilizes the external compliance report performed for UAS by other auditors. We noted within the UAS compliance audit report for the year ended June 30, 2020, there was a finding for not sending past due notices within the required timeframes or not sending past due notices at all. The audit did not specify the students that were not contacted within the required guidelines and UAS is one of the largest third party servicer for federal student loans. Therefore, we do not know if there were any Northwest Nazarene University students that were impacted by the non-compliance noted at UAS. Questioned Costs: None Context: We noted the University?s third party servicer, UAS, failed to comply with notifying students of past due notices nothing 2 of 50 students were sent past due notices late and 1 of 50 were not sent proper past due notices. Cause: UAS, the third-party servicer, did not have controls in place to ensure they complied with Department of Education Rules and Regulations in regards to timely notice of past due payments. Given the University relies on UAS to meet their compliance responsibilities and there was not testing completed specifically for the University to determine if the non-compliance is specific to them, this is a finding for the University. Effect: UAS is not in compliance with all statutory or regulatory provisions as it pertains to the notification of students with past due payments. Any finding UAS receives that is not mitigated with additional testing (with results of no errors specific to the college or university), that finding becomes a finding of the institutions they service. Repeat Finding: No Recommendation: We recommend that the University implement a thorough review process of all third-party servicer contracts to make sure they comply with all Department of Education Rules and Regulations. View of Responsible Official: There is no disagreement with the audit finding.
Perkins Compliance CFDA No: 84.038 Recommendation: We recommend that the University implement a thorough review process of all third-party servicer contracts to make sure they comply with all Department of Education Rules and Regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: NNU has discontinued the contract with the Perkins servicer. We have also begun and substantially completed the Perkins Liquidation process. NNU does review third-servicer contracts to ensure they are in compliance with the Department of Education Rules and Regulations and we will make sure that, if at a time the servicer falls out of compliance, we can exit the relationship. Name(s) of the contact person(s) responsible for corrective action: Angie Battershell Planned completion date for corrective action plan: April 2021
National Students Loan Data System (NSLDS) Reporting Department of Education Student Financial Assistance Cluster 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Student Loans Award Period: July 1, 2019 to June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. Condition: During our testing of 40 students, we noted seven instances of late reporting of student status changes. Questioned Costs: None Context: During our testing it was noted that the University failed to report to student status changes to NSLDS on a timely basis. Cause: The College?s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause over-awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the University review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS as required by regulations. View of Responsible Official: There is no disagreement with the audit finding.
NSLDS Reporting CFDA No: 84.063, 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that students? statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: NNU has implemented processes and personnel to respond to all error reports sent to us requiring action within 10 days to ensure that is done within 10 days. Our Registrar uses the NSC system to manually update Enrollment Reporting errors to expedite and ensure accurate updates are ready for upload to NSLDS. We will also add a monthly review of the NSLDS SCHER1 and the NSC to discover errors that may not have been sent to us needing a 10-day response. Name(s) of the contact person(s) responsible for corrective action: Ann Thompson-Crabb Planned completion date for corrective action plan: July 31, 2021
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on October 28, 2019. 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 28, 2020, which was (2305 days ago).
What is a management decision? →Gramm-Leach-Bliley Act Requirements Federal Agency Department of Education Award Period: July 1, 2018 to June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Condition: Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Questioned Costs: None Context: During our audit procedures, it was noted that the University did not designate an individual to coordinate the information security program; performed a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures and documented safeguards for identified risks. Cause: The University has not identified an individual designated to assure compliance with the requirements of the GLBA. The University did not perform an IT risk assessment tailored specifically to the organization, identify risks, or address risks identified as required by the GLBA. Possible Asserted Effect: Personal information could be vulnerable without safeguards in place. Repeat Finding: No Recommendation: We recommend that the University designate an individual to perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. View of Responsible Official: There is no disagreement with the audit finding.
2019-001 Gramm-Leach-Bliley Act Requirements CFDA No: 84.007; 84.033; 84.038; 84.063; 84.268; 84.379 Recommendation: It was recommended the University designate an individual to perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is working to identify the individual responsible for ownership of the risk assessment and the individuals that will aid in that exercise and response to the risk assessment, including training for campus personnel. Name(s) of the contact person(s) responsible for corrective action: Todd Baker, Director of IT Planned completion date for corrective action plan: February 2020
Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: 84.038 ? Federal Perkins Loans Award Period: July 1, 2018 to June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: The Code of Federal Regulation, 34 CFR 674.42 requires contact to a borrower for the first time 90 days after the commencement of any grace period. The University at this time shall remind the borrower of his or her responsibility to comply with the terms of the loan. The University is then required at 150 days and 240 days to send subsequent notices to notify the borrower of the first required payment. Condition: The University utilizes University Accounting Service, LLC (UAS) for its third party Perkins Loan servicing. This is a very common practice for colleges and universities in order to provide the most efficient and effective means to not only collect loans but also meet the federal regulations for servicing student Perkins Loans. In auditing the compliance features for the loan servicing, CliftonLarsonAllen utilizes the external compliance report performed for UAS by other auditors. We noted within the UAS compliance audit report for the year ended June 30, 2019, there was a finding for not contacting the student within the required timeframes. The audit did not specify the students that were not contacted within the required guidelines and UAS is one of the largest third party servicer for federal student loans. Therefore, we do not know if there were any Northwest Nazarene University students that were impacted by the non-compliance noted at UAS. Questioned Costs: None Context: We noted the University?s third party servicer, UAS, failed to comply with notifying students of their grace period as required noting 2 of 50 students were noncompliant. Cause: UAS, the third-party servicer, did not have controls in place to ensure they complied with Department of Education Rules and Regulations in regards to timely engagement with students with federal loans. Given the University relies on UAS to meet their compliance responsibilities and there was not testing completed specifically for the University to determine if the non-compliance is specific to them, this is a finding for the University. Effect: UAS is not in compliance with all statutory or regulatory provisions as it pertains to the notification of students exiting its grace period. Any finding UAS receives that is not mitigated with additional testing (with results of no errors specific to the college or university), that finding becomes a finding of the institutions they service. Repeat Finding: No Recommendation: We recommend that the University implement a thorough review process of all third-party servicer contracts to make sure they comply with all Department of Education Rules and Regulations. View of Responsible Official: There is no disagreement with the audit finding.
2019-002 Grace Period Notifications 84.038 Recommendation: It was recommended the University designate implement a thorough review process of all third-party servicer contracts to make sure they comply with all Department of Education Rules and Regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is already obtaining copies of the contracts and SSAE 16 reports. As a result of this new finding we will implement an internal audit procedure of reviewing correspondence from the third-party servicer to the loan holders. Name(s) of the contact person(s) responsible for corrective action: Heather John, Assistant Controller Planned completion date for corrective action plan: February 2020
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on November 5, 2018. 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, 2019, which was (2664 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 9, 2018. 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 9, 2018, which was (2964 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
2016-003
GSA_MIGRATION
GSA_MIGRATION
2016-002
GSA_MIGRATION
GSA_MIGRATION
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on November 28, 2016. 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 28, 2017, which was (3371 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
2015-002
GSA_MIGRATION
GSA_MIGRATION
2015-004
GSA_MIGRATION
GSA_MIGRATION
2015-005
GSA_MIGRATION
GSA_MIGRATION
2015-007
GSA_MIGRATION
GSA_MIGRATION
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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