EIN: 880121831
UEI: XYWSCNVDKZ44
Audited by: EIDE BAILLY LLP
Oversight agency: 84 [Department of Education]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 12, 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 12, 2023 (1088 days ago).
What is a management decision? →During the testing over return of Title IV calculations, we were unable to see evidence of an independent review over the return of Title IV calculations. Cause: During the year the University was working through the transfer of their operations to another University, relocating their Office for Student Financial Services, as well as staff turnover due to the transfer of operations and evidence of the independent review was not retained. Effect: There was no evidence of an independent review over the return of Title IV calculations. Questioned Costs: None Context/Sampling: Nonstatistical sampling was used. Sample size of 4 was selected out of a total of 10 return of Title IV calculations. Repeat Finding From Prior Year: No Recommendation: We recommend that the University retain evidence of an independent review over return of Title IV funds. Views of Responsible Officials: Management agrees with the finding; however, management disagrees with classifying the issue as a material weakness versus a significant deficiency. Per the financial reports received for FY2022 Student Financial Aid from the Department of Education all funds were properly accounted for per their records.
Show full finding ▾Hide full finding ▴2022-002: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Assistance Listing 84.268 Federal Pell Grant, Assistance Listing 84.063 Federal Work Study Program, Assistance Listing 84.033 Federal Supplemental Education Opportunity Grants, Assistance Listing 84.007 Teacher Education Assistance For College and Higher Education Grants, Assistance Listing 84.379 P268K220568, P063P210568, P033A212492, P007A212492, P379T220568 Special Test and Provisions ? Return of Title IV Funds Material Weakness in Internal Control over Compliance Criteria: Documentation pertaining to the independent review of return of Title IV calculations should be retained to ensure there is evidence of an independent review over the return of Title IV calculations. Condition: During the testing over return of Title IV calculations, we were unable to see evidence of an independent review over the return of Title IV calculations. Cause: During the year the University was working through the transfer of their operations to another University, relocating their Office for Student Financial Services, as well as staff turnover due to the transfer of operations and evidence of the independent review was not retained. Effect: There was no evidence of an independent review over the return of Title IV calculations. Questioned Costs: None Context/Sampling: Nonstatistical sampling was used. Sample size of 4 was selected out of a total of 10 return of Title IV calculations. Repeat Finding From Prior Year: No Recommendation: We recommend that the University retain evidence of an independent review over return of Title IV funds. Views of Responsible Officials: Management agrees with the finding; however, management disagrees with classifying the issue as a material weakness versus a significant deficiency. Per the financial reports received for FY2022 Student Financial Aid from the Department of Education all funds were properly accounted for per their records.
Finding 2022-002 U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Assistance Listing 84.268 Federal Pell Grant, Assistance Listing 84.063 Federal Work Study Program, Assistance Listing 84.033 Federal Supplemental Education Opportunity Grants, Assistance Listing 84.007 Teacher Education Assistance For College and Higher Education Grants, Assistance Listing 84.379 P268K220568, P063P210568, P033A212492, P007A212492, P379T220568 Special Test and Provisions ? Return of Title IV Funds Material Weakness in Internal Control over Compliance Finding Summary: In the current year, there was no evidence of an independent review over the return of Title IV calculations. Responsible Individuals: Maia Rowland, Student Financial Aid Director Corrective Action Plan: This issue will cease to exist in the future due to the acquisition of SNU by UNR. The acquisition of SNU by UNR was effective July 1, 2022. Anticipated Completion Date: This issue will cease to exist in the future due to the acquisition of SNU by UNR. The acquisition of SNU by UNR was effective July 1, 2022.
The quarterly HEERF reports were reported on a cumulative basis rather than the information for only that quarter. Cause: The University did not have internal controls to ensure that the data reported on the quarterly student HEERF reports were quarterly information rather than cumulative. Effect: The information submitted on the quarterly student HEERF reports reported cumulative data rather than only the information for that quarter. Questioned Costs: None Context/Sampling: Nonstatistical sampling was used. Sample size of 3 reports were selected out of a total of 5 reports required to be submitted during the year. Repeat Finding From Prior Year: No Recommendation: We recommend that the University implement a process to ensure that all information submitted for the quarterly reporting is based upon the guidance provided by the Department of Education. Views of Responsible Officials: Management agrees with the finding; however, management disagrees with the classification of the finding as a material weakness versus a significant deficiency.
Show full finding ▾Hide full finding ▴2022-003: U.S. Department of Education Higher Education Emergency Relief Fund COVID-19 ? Higher Education Emergency Relief Fund ? Student Portion, Assistance Listing 84.425E P425E200015 Reporting Material Weakness in Internal Control over Compliance Criteria: Based upon the guidance provided by the Department of Education, the quarterly reports should appear on separate documents by quarter and should not be cumulative. Condition: The quarterly HEERF reports were reported on a cumulative basis rather than the information for only that quarter. Cause: The University did not have internal controls to ensure that the data reported on the quarterly student HEERF reports were quarterly information rather than cumulative. Effect: The information submitted on the quarterly student HEERF reports reported cumulative data rather than only the information for that quarter. Questioned Costs: None Context/Sampling: Nonstatistical sampling was used. Sample size of 3 reports were selected out of a total of 5 reports required to be submitted during the year. Repeat Finding From Prior Year: No Recommendation: We recommend that the University implement a process to ensure that all information submitted for the quarterly reporting is based upon the guidance provided by the Department of Education. Views of Responsible Officials: Management agrees with the finding; however, management disagrees with the classification of the finding as a material weakness versus a significant deficiency.
Finding 2022-003 U.S. Department of Education Higher Education Emergency Relief Fund COVID ? 19 Higher Education Emergency Relief Fund ? Student Portion, Assistance Listing 84.425E P425E200015 Reporting Material Weakness in Internal Control over Compliance Finding Summary: In the current year the quarterly HEERF reports were reported on a cumulative basis rather than only reporting the information for that quarter as per the guidance from the Department of Education. Responsible Individuals: Maia Rowland, Student Financial Aid Director Corrective Action Plan: This issue will cease to exist in the future due to the acquisition of SNU by UNR. The acquisition of SNU by UNR was effective July 1, 2022. Anticipated Completion Date: This issue will cease to exist in the future due to the acquisition of SNU by UNR. The acquisition of SNU by UNR was effective July 1, 2022.
FAC accepted this audit on January 6, 2022 — management decision was due July 6, 2022.
The SAS reconciliations were not performed during the year. Cause: The University did not have internal controls to provide for the reconciliation of the SAS data file. Effect: Records maintained by the COD may not agree to the University?s records. Questioned Costs: None Context/Sampling: The SAS monthly reconciliations were not performed for the whole year. Repeat Finding From Prior Year: Yes, see finding 2020-004. Recommendation: We recommend the University implement internal controls to provide for the reconciliation of the SAS data file. Views of Responsible Officials: Management agrees with this finding.
Show full finding ▾Hide full finding ▴2021-003: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Assistance Listing 84.268 Federal Pell Grant, Assistance Listing 84.063 Federal Work Study Program, Assistance Listing 84.033 Federal Supplemental Education Opportunity Grants, Assistance Listing 84.007 Teacher Education Assistance For College and Higher Education Grants, Assistance Listing 84.379 P268K210568, P063P200568, P033A202492, P007A202492, P379T210568 Special Test and Provisions ? Borrower Data and Reconciliation Material Weakness in Internal Control over Compliance Criteria: Each month, the Common Origination and Disbursement (COD) system provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is required to reconcile these files to the institution?s financial records. Condition: The SAS reconciliations were not performed during the year. Cause: The University did not have internal controls to provide for the reconciliation of the SAS data file. Effect: Records maintained by the COD may not agree to the University?s records. Questioned Costs: None Context/Sampling: The SAS monthly reconciliations were not performed for the whole year. Repeat Finding From Prior Year: Yes, see finding 2020-004. Recommendation: We recommend the University implement internal controls to provide for the reconciliation of the SAS data file. Views of Responsible Officials: Management agrees with this finding.
Finding 2021-003 U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, CFDA 84.268 Federal Pell Grant, CFDA 84.063 Federal Work Study Program, CFDA 84.033 Federal Supplemental Education Opportunity Grants, CFDA 84.007 Teacher Education Assistance for College and Higher Education Grants, CFDA 84.379 P268K210568, P036P200568, P033A202492, P007A202492, P379T210568 Special Tests and Provisions ? Borrower Data and Reconciliation Material Weakness in Internal Controls over Compliance Finding Summary: Each month, the Common Origination and Disbursement (COD) system provides institutions with a School Account Statement (SAS) data file which consist of a Cash Summary, Cash Detail, and (optional at the request of the institution) Loan Detail records. The University did not have adequate internal controls to provide for the monthly reconciliation of the SAS data file. Responsible Individuals: Maia Rowland, Director of Student Financial Services Corrective Action Plan: The University has implemented internal controls to provide for the monthly reconciliation of the SAS data file. Reconciliations have been completed and are current. No exceptions were noted with the monthly reconciliations. Anticipated Completion Date: Corrected.
2020-004
During our testing over the student disbursements, we noted three instances in which the students were disbursed Title IV funds 14 days prior to the first day of classes for the payment period or module for which the disbursement was intended. Cause: The University did not have adequate internal controls in ensure Title IV funds were not disbursed prior to the 10 days before the first day of class. Effect: There were three students that were disbursed Title IV funds prior to when they were allowed to be disbursed Title IV funds. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 students ($820,691 in Title IV funds tested) was selected for testing out of a total population of 352 students ($4,830,173 in Title IV funds included in population). For the three students that were disbursed Title IV funds early, a total of $30,426 was disbursed 14 days prior to the first day of classes, rather than 10 days prior to the first day of classes. Repeat Finding From Prior Year: No. Recommendation: We recommend that the University have a process in place to ensure Title IV funds are not disbursed prior to when they are allowed to be disbursed. Views of Responsible Officials: Management agrees with this finding.
Show full finding ▾Hide full finding ▴2021-004: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Assistance Listing 84.268 Federal Pell Grant, Assistance Listing 84.063 Federal Work Study Program, Assistance Listing 84.033 Federal Supplemental Education Opportunity Grants, Assistance Listing 84.007 Teacher Education Assistance For College and Higher Education Grants, Assistance Listing 84.379 P268K210568, P063P200568, P033A202492, P007A202492, P379T210568 Special Test and Provisions ? Disbursements to or on Behalf of Students Significant Deficiency in Internal Control over Compliance Criteria: The earliest in which an institution may disburse any Title IV funds, except federal work study program funds, by either paying the student directly or crediting the student account, is 10 days before the first day of classes of the payment period or module for which the disbursement is intended (34 CFR 668.164 (i)). Condition: During our testing over the student disbursements, we noted three instances in which the students were disbursed Title IV funds 14 days prior to the first day of classes for the payment period or module for which the disbursement was intended. Cause: The University did not have adequate internal controls in ensure Title IV funds were not disbursed prior to the 10 days before the first day of class. Effect: There were three students that were disbursed Title IV funds prior to when they were allowed to be disbursed Title IV funds. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 students ($820,691 in Title IV funds tested) was selected for testing out of a total population of 352 students ($4,830,173 in Title IV funds included in population). For the three students that were disbursed Title IV funds early, a total of $30,426 was disbursed 14 days prior to the first day of classes, rather than 10 days prior to the first day of classes. Repeat Finding From Prior Year: No. Recommendation: We recommend that the University have a process in place to ensure Title IV funds are not disbursed prior to when they are allowed to be disbursed. Views of Responsible Officials: Management agrees with this finding.
Finding 2021-004 U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, CFDA 84.268 Federal Pell Grant, CFDA 84.063 Federal Work Study Program, CFDA 84.033 Federal Supplemental Education Opportunity Grants, CFDA 84.007 Teacher Education Assistance for College and Higher Education Grants, CFDA 84.379 P268K210568, P036P200568, P033A202492, P007A202492, P379T210568 Special Tests and Provisions - Disbursements to or on Behalf of Students Significant Deficiency in Internal Control over Compliance Finding Summary: The University did not have adequate internal controls to ensure Title IV funds were not disbursed prior to the 10 days before the first day of class. Three instances were noted in which the students were disbursed Title IV funds 14 days prior to the first day of classes for the payment period or module for which the disbursement was intended Responsible Individuals: Maia Rowland, Director of Student Financial Services Corrective Action Plan: The University has implemented internal controls and updated the process to change early disbursement form 14 days to 10 days to comply with Federal regulations. Anticipated Completion Date: Corrected.
During our testing over emergency financial grants to students, we noted seven instances out of 60 students tested, in which the emergency financial grant was applied against the student account rather than being paid directly to the student. Based upon discussions with management, the amount applied to the student account was used to reduce charges and not as a payment on the account; however, the disbursement was not made directly to the student. The University used the Institutional portion of the HEERF I grant to make the additional grants to students. Cause: The University did not have an effective control system in place to ensure that all the requirement under the HEERF grant were being followed. Effect: There were seven students out of 60 tested in which the emergency financial grants to students were not made directly to students. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 students with $54,735 in awards was selected for testing out of a total population of 788 students with $580,160 disbursed out of the student and institutional awards. Repeat Finding From Prior Year: No. Recommendation: We recommend that the University have a process in place to ensure HEERF funds are not disbursed prior to when they are allowed to be disbursed. Views of Responsible Officials: Management agrees with this finding.
Show full finding ▾Hide full finding ▴2021-005: U.S. Department of Education Higher Education Emergency Relief Fund COVID-19 ? Higher Education Emergency Relief Fund ? Student Portion, Assistance Listing 84.425E COVID-19 ? Higher Education Emergency Relief Fund ? Institutional Portion, Assistance Listing 84.425F P425E200015, P425F200904 Activities Allowed or Unallowed Material Weakness in Internal Control over Compliance Criteria: For emergency financial aid grants to students, disbursements made to students must be made directly to students under HEERF I. If Institutional funds are used to make additional grants to students, the Institution must use the guidelines of the student portion of HEERF I when distributing the student awards. Condition: During our testing over emergency financial grants to students, we noted seven instances out of 60 students tested, in which the emergency financial grant was applied against the student account rather than being paid directly to the student. Based upon discussions with management, the amount applied to the student account was used to reduce charges and not as a payment on the account; however, the disbursement was not made directly to the student. The University used the Institutional portion of the HEERF I grant to make the additional grants to students. Cause: The University did not have an effective control system in place to ensure that all the requirement under the HEERF grant were being followed. Effect: There were seven students out of 60 tested in which the emergency financial grants to students were not made directly to students. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 students with $54,735 in awards was selected for testing out of a total population of 788 students with $580,160 disbursed out of the student and institutional awards. Repeat Finding From Prior Year: No. Recommendation: We recommend that the University have a process in place to ensure HEERF funds are not disbursed prior to when they are allowed to be disbursed. Views of Responsible Officials: Management agrees with this finding.
Finding 2021-005 U.S. Department of Education Higher Education Emergency Relief Fund COVID ? 19 Higher Education Emergency Relief Fund ? Student Portion, Assistance Listing 84.425E COVID ? 19 Higher Education Emergency Relief Fund ? Institutional Portion, Assistance Listing 84.425F P425E200015, P425F200904 Activities Allowed or Unallowed Material Weakness in Internal Control over Compliance Finding Summary: The University did not have an effective control system in place to ensure that all the requirements under the HEERF grant were being followed. There were seven instances in which the emergency financial grants to students were not made directly to students but rather applied to their student account balance. Responsible Individuals: Maia Rowland, Director of Student Financial Services and Susan Johnson, Executive Vice President of Finance and Administration Corrective Action Plan: The University has implemented internal controls to ensure that all the requirements under HEERF grants will be followed. Anticipated Completion Date: Corrected.
During our testing over the reporting for the student and institutional portion of the Higher Education Emergency Relief Fund, we noted three reports that were not filed timely. Cause: The University did not have an effective control system in place to ensure that all the requirement under the HEERF grant were being followed. Effect: There were three reports out of the five that were tested that were not submitted within the required timeframe. Questioned Costs: None Context/Sampling: A nonstatistical sample of 5 reports were selected out of a total of 13 reports submitted during the fiscal year. Repeat Finding From Prior Year: No. Recommendation: We recommend that the University have a process in place to ensure that all required reporting is submitted timely. Views of Responsible Officials: Management agrees with this finding.
Show full finding ▾Hide full finding ▴2021-006: U.S. Department of Education Higher Education Emergency Relief Fund COVID-19 ? Higher Education Emergency Relief Fund ? Student Portion, Assistance Listing 84.425E COVID-19 ? Higher Education Emergency Relief Fund ? Institutional Portion, Assistance Listing 84.425F COVID-19 ? Higher Education Emergency Relief Fund ? SIP, Assistance Listing 84.425M P425E200015, P425F200904, P425M200101 Reporting Significant Deficiency in Internal Control over Compliance Criteria: Under the guidance provided by ED, the quarterly reports were required to be posted to the website 10 days after the conclusion of the quarter. Condition: During our testing over the reporting for the student and institutional portion of the Higher Education Emergency Relief Fund, we noted three reports that were not filed timely. Cause: The University did not have an effective control system in place to ensure that all the requirement under the HEERF grant were being followed. Effect: There were three reports out of the five that were tested that were not submitted within the required timeframe. Questioned Costs: None Context/Sampling: A nonstatistical sample of 5 reports were selected out of a total of 13 reports submitted during the fiscal year. Repeat Finding From Prior Year: No. Recommendation: We recommend that the University have a process in place to ensure that all required reporting is submitted timely. Views of Responsible Officials: Management agrees with this finding.
Finding 2021-006 U.S. Department of Education Higher Education Emergency Relief Fund COVID ? 19 Higher Education Emergency Relief Fund ? Student Portion, Assistance Listing 84.425E COVID ? 19 Higher Education Emergency Relief Fund ? Institutional Portion, Assistance Listing 84.425F COVID ? 19 Higher Education Emergency Relief Fund ? SIP, Assistance Listing 84.425M P425E200015, P425F200904, P425M200101 Reporting Significant Deficiency in Internal Control over Compliance Finding Summary: The University did not have an effective control system in place to ensure that all the requirements under the HEERF grant were being followed. Under the guidance provided by ED, the quarterly reports were required to be posted to the website 10 days after the conclusion of the quarter. Responsible Individuals: Susan Johnson, Executive Vice President of Finance and Administration Corrective Action Plan: The University implemented internal controls to ensure that all the requirements under HEERF grants will be followed. All required quarterly reporting has been completed and the University is current with the required quarterly reports. Anticipated Completion Date: Corrected.
FAC accepted this audit on April 12, 2021 — management decision was due October 12, 2021.
A) The Pell awards did not agree to the Payment and Disbursement Schedule. B) Awards were provided in excess of the student?s financial need. C) A student was not enrolled on at least a half-time basis. Cause: The University did not have adequate internal controls to ensure Pell awards agreed to the Payment and Disbursement Schedules, aid was not awarded in excess of financial need, and that students were enrolled on at least a half-time basis. Effect: Awards were not calculated correctly. Questioned Costs: A) None B) $9,257 Context/Sampling: A nonstatistical sample of 60 students was selected for testing across all assistance programs. Details of the sample and population of students are as follows: ? Sample: 16 students who received Pell disbursements totaling $58,152 ? Population: 159 students received Pell disbursements totaling $578,280 ? Sample: 23 students who received subsidized direct loans totaling $87,815 ? Population: 175 students received subsidized direct loans totaling $743,022 We identified two students in our sample of 16 who received a Pell disbursement that did not match the payment schedule. Total underpayments to the two students was $1,125. We identified two students in our sample who received subsidized direct loans in excess of financial need by a total of $9,257. We identified one student in our sample who received subsidized direct loans of $50, when they were not enrolled in at least half-time. Repeat Finding From Prior Year: Yes, for the Pell disbursement condition. Prior year finding 2019-002. Recommendation: We recommend the University enhance internal controls to ensure Pell awards agree to the Payment and Disbursement Schedules, that need based aid is not awarded in excess of financial need, and that students are enrolled on at least a half-time basis in order to receive assistance. Views of Responsible Officials: Management agrees with this finding.
Show full finding ▾Hide full finding ▴2020-001: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, CFDA 84.268 Federal Pell Grant, CFDA 84.063 Federal Work Study Program, CFDA 84.033 Federal Supplemental Education Opportunity Grants, CFDA 84.007 Teacher Education Assistance For College and Higher Education Grants, CFDA 84.379 Eligibility Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under CFDA 84.268, 84.063, and 84.033 on the Schedule of Expenditures of Federal Awards. Criteria: A) Each year the U.S. Department of Education provides institutions with Payment and Disbursement Schedules for determining Pell awards. Based upon a student?s enrollment status, the maximum annual amount regarding a student?s Pell award is determined (34 CFR 690.62). B) Awards must be coordinated among the various programs and with other federal and non-federal aid to ensure that total aid is not awarded in excess of the student?s financial need (Direct Loan, 34 CFR 685.301) C) A student must be enrolled or accepted for enrollment on at least a half-time basis (34 CFR 374.9(b)) Condition: A) The Pell awards did not agree to the Payment and Disbursement Schedule. B) Awards were provided in excess of the student?s financial need. C) A student was not enrolled on at least a half-time basis. Cause: The University did not have adequate internal controls to ensure Pell awards agreed to the Payment and Disbursement Schedules, aid was not awarded in excess of financial need, and that students were enrolled on at least a half-time basis. Effect: Awards were not calculated correctly. Questioned Costs: A) None B) $9,257 Context/Sampling: A nonstatistical sample of 60 students was selected for testing across all assistance programs. Details of the sample and population of students are as follows: ? Sample: 16 students who received Pell disbursements totaling $58,152 ? Population: 159 students received Pell disbursements totaling $578,280 ? Sample: 23 students who received subsidized direct loans totaling $87,815 ? Population: 175 students received subsidized direct loans totaling $743,022 We identified two students in our sample of 16 who received a Pell disbursement that did not match the payment schedule. Total underpayments to the two students was $1,125. We identified two students in our sample who received subsidized direct loans in excess of financial need by a total of $9,257. We identified one student in our sample who received subsidized direct loans of $50, when they were not enrolled in at least half-time. Repeat Finding From Prior Year: Yes, for the Pell disbursement condition. Prior year finding 2019-002. Recommendation: We recommend the University enhance internal controls to ensure Pell awards agree to the Payment and Disbursement Schedules, that need based aid is not awarded in excess of financial need, and that students are enrolled on at least a half-time basis in order to receive assistance. Views of Responsible Officials: Management agrees with this finding.
Finding 2020-001 Federal Agency Name: U.S. Department of Education Program Name/CFDA #: Student Financial Assistance Cluster Federal Direct Student Loans, CFDA 84.268 Federal Pell Grant, CFDA 84.063 Federal Work Study Program, CFDA 84.033 Federal Supplemental Education Opportunity Grant, CFDA 84.007 Teacher Education Assistance for College and Higher Education Grants, 84.379 Eligibility Material Weakness in Internal Control over Compliance Finding Summary: During the testing over the Student Financial Assistance Cluster, the following errors were noted: A) The Pell awards did not agree to the Payment and Disbursement Schedule. B) Awards were provided in excess of the student?s financial need. C) A student was not enrolled on at least a half-time basis. Responsible Individuals: Maia Rowland, Director of Student Financial Services Corrective Action Plan: SNU will import Pell files and load regularly to review discrepancies to ensure the awards agree to the Payment and Disbursement Schedule and are provided in line with students? financial need. Anticipated Completion Date: Completed.
2019-002
Disbursements were made in the fall semester for the entire year, rather than by academic term (semester). Cause: The University did not have adequate internal controls to ensure amounts were disbursed to students by academic term. Effect: Students received funding in advance. Questioned Costs: $8,362 Context/Sampling: A nonstatistical sample of 40 students from a population of approximately 550 was selected for testing. Amounts were not disbursed by academic term for four students. The four students did not return for the spring semester and received a total of $8,362 in direct loans for the spring semester. Repeat Finding From Prior Year: No. Recommendation: We recommend the University enhance internal controls to ensure amounts are disbursed to students by academic term. Views of Responsible Officials: Management agrees with this finding.
Show full finding ▾Hide full finding ▴2020-002: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, CFDA 84.268 Federal Pell Grant, CFDA 84.063 Federal Work Study Program, CFDA 84.033 Federal Supplemental Education Opportunity Grants, CFDA 84.007 Teacher Education Assistance For College and Higher Education Grants, CFDA 84.379 Special Test and Provisions ? Disbursements to or on Behalf of Students Material Noncompliance and Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under CFDA 84.268 on the Schedule of Expenditures of Federal Awards. Criteria: Disbursements must be made on a payment period basis and the disbursement must be made during the current payment period (34 CFR 668.164). Condition: Disbursements were made in the fall semester for the entire year, rather than by academic term (semester). Cause: The University did not have adequate internal controls to ensure amounts were disbursed to students by academic term. Effect: Students received funding in advance. Questioned Costs: $8,362 Context/Sampling: A nonstatistical sample of 40 students from a population of approximately 550 was selected for testing. Amounts were not disbursed by academic term for four students. The four students did not return for the spring semester and received a total of $8,362 in direct loans for the spring semester. Repeat Finding From Prior Year: No. Recommendation: We recommend the University enhance internal controls to ensure amounts are disbursed to students by academic term. Views of Responsible Officials: Management agrees with this finding.
Finding 2020-002 Federal Agency Name: U.S. Department of Education Program Name/CFDA #: Student Financial Assistance Cluster Federal Direct Student Loans, CFDA 84.268 Federal Pell Grant, CFDA 84.063 Federal Work Study Program, CFDA 84.033 Federal Supplemental Education Opportunity Grant, CFDA 84.007 Teacher Education Assistance for College and Higher Education Grants, 84.379 Special Tests and Provisions ? Disbursements to or on Behalf of Students Material Noncompliance and Material Weakness in Internal Control over Compliance Finding Summary: During the testing over the Student Financial Assistance Cluster, there were disbursements that were made in the fall semester for the entire year, rather than by academic term (semester). Responsible Individuals: Maia Rowland, Director of Student Financial Services Corrective Action Plan: SNU will begin using the ?Reschedule Disbursement Dates? functionality in Banner to confirm that disbursements are made by academic term (semester) as required. Anticipated Completion Date: Completed.
The calculation of aid earned by the student who withdrew was not supported by the underlying information. Cause: The University did not have adequate internal controls to ensure the Title IV aid earned was calculated appropriately. Effect: The aid earned was understated, thus the amount returned to the Department of Education was overstated. Questioned Costs: None Context/Sampling: A nonstatistical sample of four students who withdrew from a population of 14 was selected for testing. The Title IV earned by one student was understated by $2,656. Repeat Finding From Prior Year: No. Recommendation: We recommend the University enhance internal controls to ensure the Title IV aid earned is calculated appropriately and documentation retained. Views of Responsible Officials: Management agrees with this finding.
Show full finding ▾Hide full finding ▴2020-003: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, CFDA 84.268 Federal Pell Grant, CFDA 84.063 Federal Work Study Program, CFDA 84.033 Federal Supplemental Education Opportunity Grants, CFDA 84.007 Teacher Education Assistance For College and Higher Education Grants, CFDA 84.379 Special Test and Provisions ? Return of Title IV Funds Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under CFDA 84.268 on the Schedule of Expenditures of Federal Awards. Criteria: When a recipient of Title IV grant or loan assistance withdraws during a payment period, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. If the amount earned by the student is less than the amount that was disbursed to the student, the difference must be returned (34 CFR 668.22). Condition: The calculation of aid earned by the student who withdrew was not supported by the underlying information. Cause: The University did not have adequate internal controls to ensure the Title IV aid earned was calculated appropriately. Effect: The aid earned was understated, thus the amount returned to the Department of Education was overstated. Questioned Costs: None Context/Sampling: A nonstatistical sample of four students who withdrew from a population of 14 was selected for testing. The Title IV earned by one student was understated by $2,656. Repeat Finding From Prior Year: No. Recommendation: We recommend the University enhance internal controls to ensure the Title IV aid earned is calculated appropriately and documentation retained. Views of Responsible Officials: Management agrees with this finding.
Finding 2020-003 Federal Agency Name: U.S. Department of Education Program Name/CFDA #: Student Financial Assistance Cluster Federal Direct Student Loans, CFDA 84.268 Federal Pell Grant, CFDA 84.063 Federal Work Study Program, CFDA 84.033 Federal Supplemental Education Opportunity Grant, CFDA 84.007 Teacher Education Assistance for College and Higher Education Grants, 84.379 Special Tests and Provisions ? Return of Title IV Funds Significant Deficiency in Internal Control over Compliance Finding Summary: The calculation of aid earned by a student who withdrew was not supported by the underlying information and therefore the amount of aid earned was understated and the amount returned to the Department of Education was overstated. Responsible Individuals: Maia Rowland, Director of Student Financial Services Corrective Action Plan: SNU will implement over-award processing to identify any students that are out of balance. Additionally, the recurring processing of R2T4 on a monthly basis will ensure that all accounts are correctly adjusted. This information will be loaded into the COD website for accuracy. Anticipated Completion Date: Completed.
The SAS reconciliations were not performed during the year. Cause: The University did not have internal controls to provide for the reconciliation of the SAS data file. Effect: Records maintained by the COD may not agree to the University?s records. Questioned Costs: None Context/Sampling: The SAS monthly reconciliations were not performed for the whole year. Repeat Finding From Prior Year: No. Recommendation: We recommend the University implement internal controls to provide for the reconciliation of the SAS data file. Views of Responsible Officials: Management agrees with this finding.
Show full finding ▾Hide full finding ▴2020-004: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, CFDA 84.268 Federal Pell Grant, CFDA 84.063 Federal Work Study Program, CFDA 84.033 Federal Supplemental Education Opportunity Grants, CFDA 84.007 Teacher Education Assistance For College and Higher Education Grants, CFDA 84.379 Special Test and Provisions ? Borrower Data and Reconciliation Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under CFDA 84.268 on the Schedule of Expenditures of Federal Awards. Criteria: Each month, the Common Origination and Disbursement (COD) system provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is required to reconcile these files to the institution?s financial records. Condition: The SAS reconciliations were not performed during the year. Cause: The University did not have internal controls to provide for the reconciliation of the SAS data file. Effect: Records maintained by the COD may not agree to the University?s records. Questioned Costs: None Context/Sampling: The SAS monthly reconciliations were not performed for the whole year. Repeat Finding From Prior Year: No. Recommendation: We recommend the University implement internal controls to provide for the reconciliation of the SAS data file. Views of Responsible Officials: Management agrees with this finding.
Finding 2020-004 Federal Agency Name: U.S. Department of Education Program Name/CFDA #: Student Financial Assistance Cluster Federal Direct Student Loans, CFDA 84.268 Federal Pell Grant, CFDA 84.063 Federal Work Study Program, CFDA 84.033 Federal Supplemental Education Opportunity Grant, CFDA 84.007 Teacher Education Assistance for College and Higher Education Grants, 84.379 Special Tests and Provisions ? Borrower Data and Reconciliation Material Weakness in Internal Control over Compliance Finding Summary: The Student Account Statement (SAS) data file reconciliations were not performed during the year. Responsible Individuals: Maia Rowland, Director of Student Financial Services Corrective Action Plan: SNU will process files to reconcile accounts and make the internal systems current. This process will be done on a monthly basis to keep in line with the Federal Student Aid requirement. Anticipated Completion Date: Completed.
FAC accepted this audit on October 27, 2019 — management decision was due April 27, 2020.
The calculation of the Pell award for the 2018-2019 award year was not updated by the College when a new Payment and Disbursement Schedule was published by the U.S. Department of Education after the start of the fall term. Cause: Sierra Nevada College did not have adequate internal controls to identify that a new Payment and Disbursement Schedule had been published by the U.S. Department of Education after the start of the fall term. Effect: Pell awards were not calculated appropriately. Questioned Costs: None. Context/Sampling: A nonstatistical sample of students was selected for testing across all assistance programs. Details of the sample and population of students in relation to the Federal Pell Grant are as follows: ? Sample: 35 students who received Pell disbursements totaling $154,541 ? Population: 357 students received Pell disbursements totaling $681,949 We identified three students in our sample of 35 who received a Pell disbursement that did not match the payment schedule. In addition, the College identified seven other students with the same error that were not included in our sample of 35 but were within the population of 357. Total underpayments to the ten students was $3,276.Repeat Finding From Prior Year: No. Recommendation: We recommend the College enhance internal controls to identify when a new Payment and Disbursement Schedule has been published and apply the most recent schedule to student awards to ensure the most accurate information is used in student awards. Views of Responsible Officials: Management agrees with this finding.
Show full finding ▾Hide full finding ▴2019-002: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, CFDA 84.268 Federal Pell Grant, CFDA 84.063 Federal Work Study Program, CFDA 84.033 Federal Supplemental Education Opportunity Grants, CFDA 84.007 Teacher Education Assistance For College and Higher Education Grants, CFDA 84.379 Eligibility Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under CFDA 84.063 on the Schedule of Expenditures of Federal Awards. Criteria: Each year the U.S. Department of Education provides institutions with Payment and Disbursement Schedules for determining Pell awards. Based upon a student?s enrollment status, the maximum annual amount regarding a student?s Pell award is determined. Condition: The calculation of the Pell award for the 2018-2019 award year was not updated by the College when a new Payment and Disbursement Schedule was published by the U.S. Department of Education after the start of the fall term. Cause: Sierra Nevada College did not have adequate internal controls to identify that a new Payment and Disbursement Schedule had been published by the U.S. Department of Education after the start of the fall term. Effect: Pell awards were not calculated appropriately. Questioned Costs: None. Context/Sampling: A nonstatistical sample of students was selected for testing across all assistance programs. Details of the sample and population of students in relation to the Federal Pell Grant are as follows: ? Sample: 35 students who received Pell disbursements totaling $154,541 ? Population: 357 students received Pell disbursements totaling $681,949 We identified three students in our sample of 35 who received a Pell disbursement that did not match the payment schedule. In addition, the College identified seven other students with the same error that were not included in our sample of 35 but were within the population of 357. Total underpayments to the ten students was $3,276.Repeat Finding From Prior Year: No. Recommendation: We recommend the College enhance internal controls to identify when a new Payment and Disbursement Schedule has been published and apply the most recent schedule to student awards to ensure the most accurate information is used in student awards. Views of Responsible Officials: Management agrees with this finding.
2019-002 U.S. Department of Education Student Financial Assistance Cluster Federal Direct Student Loans, CFDA 84.268 Federal Pell Grant, CFDA 84.063 Federal Work Study Program, CFDA 84.033 Federal Supplemental Education Opportunity Grant, CFDA 84.007 Teacher Education Assistance for College and Higher Education Grants, CFDA 84.379 Eligibility Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under CFDA 84.063 on the Schedule of Expenditures of Federal Awards. Criteria: Each year the U.S. Department of Education provides institutions with Payment and Disbursement Schedules for determining Pell awards. Based upon a student?s enrollment status, the maximum annual amount regarding a student?s Pell award is determined. Condition: The calculation of the Pell award for the 2018-2019 award year was not updated by the College when a new Payment and Disbursement Schedule was published by the U.S. Department of Education after the start of the fall term. Cause: Sierra Nevada College did not have adequate internal controls to identify that a new Payment and Disbursement Schedule had been published by the U.S. Department of Education after the start of the fall term. Effect: Pell awards were not calculated appropriately. Questioned Costs: None Context/Sampling: A nonstatistical sample of students was selected for testing across all assistance programs. Details of the sample and population of students in relation to the Federal Pell Grant are as follows: Sample: 35 students who received Pell disbursements totaling $154,541 Population: 357 students received Pell disbursements totaling $681,949 We identified three students in our sample of 35 who received a Pell disbursement that did not match the payment schedule. In addition, the College identified seven other students with the same error that were not included in our sample of 35 but were within the population of 357. Total underpayments to the ten students was $3,276. Repeat Finding From Prior Year: No Recommendation: We recommend the College enhance internal controls to identify when a new Payment and Disbursement Schedule has been published and apply the most recent schedule to student awards to ensure the most accurate information is used in student awards. Views of Responsible Officials: Management agrees with this finding. Corrective Action Taken or to Be Taken: When a new Payment and Disbursement Schedule is published after the start of a term, the Financial Services Advisor will apply the schedule to all applicable undergraduate student awards. This process is recalculating Pell awards that are packaged/pending in Banner. Any student with a changed Pell grant amount will be added to a spreadsheet kept on the financial aid shared drive. The Director of Financial Aid will then provide a second review of each account to make sure the new schedule has been applied prior to processing Pell awards. Each new recipient going forward will have the new schedule applied to his or her award. The Director will sign off on the Pell grant report from Banner, showing each student?s new Pell grant amount. Anticipated Completion Date: 9/16/19 Person Responsible for Corrective Action: Judy Roberts
Errors were identified on Institutional Student Information Records (ISIR) that were not submitted for correction to the central processor. Cause: Sierra Nevada College did not have adequate internal controls to ensure errors identified on the ISIR were corrected, regardless of the impact on the financial aid calculation. Effect: ISIR?s that were flagged for verification by the U.S. Department of Education were not corrected. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 13 ISIR?s from a population of 85 selected for verification was selected for testing. Errors were identified on three ISIR?s that were not corrected. However, none of the errors impacted the aid awarded to students. Repeat Finding From Prior Year: No. Recommendation: We recommend the College enhance internal controls to ensure errors identified on the ISIR are corrected, regardless of the impact on the aid awarded to students. Views of Responsible Officials: Management agrees with this finding.
Show full finding ▾Hide full finding ▴2019-003: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, CFDA 84.268 Federal Pell Grant, CFDA 84.063 Federal Work Study Program, CFDA 84.033 Federal Supplemental Education Opportunity Grants, CFDA 84.007 Teacher Education Assistance For College and Higher Education Grants, CFDA 84.379 Special Tests and Provisions - Verification Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under the Student Financial Assistance Cluster on the Schedule of Expenditures of Federal Awards. Criteria: An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information. The institution shall require each applicant whose application is selected by the U.S. Department of Education to verify the information required for the Verification Tracking Group to which the applicant is assigned. The OMB Compliance Supplement requires institutions to obtain acceptable documentation to verify the information required for the Verification Tracking Group to which the applicant is assigned and if necessary, submit data corrections to the central processor. Condition: Errors were identified on Institutional Student Information Records (ISIR) that were not submitted for correction to the central processor. Cause: Sierra Nevada College did not have adequate internal controls to ensure errors identified on the ISIR were corrected, regardless of the impact on the financial aid calculation. Effect: ISIR?s that were flagged for verification by the U.S. Department of Education were not corrected. Questioned Costs: None. Context/Sampling: A nonstatistical sample of 13 ISIR?s from a population of 85 selected for verification was selected for testing. Errors were identified on three ISIR?s that were not corrected. However, none of the errors impacted the aid awarded to students. Repeat Finding From Prior Year: No. Recommendation: We recommend the College enhance internal controls to ensure errors identified on the ISIR are corrected, regardless of the impact on the aid awarded to students. Views of Responsible Officials: Management agrees with this finding.
2019-003 U.S. Department of Education Student Financial Assistance Cluster Federal Direct Student Loans, CFDA 84.268 Federal Pell Grant, CFDA 84.063 Federal Work Study Program, CFDA 84.033 Federal Supplemental Education Opportunity Grant, CFDA 84.007 Teacher Education Assistance for College and Higher Education Grants, CFDA 84.379 Special Tests and Provisions - Verification Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under the Student Financial Assistance Cluster on the Schedule of Expenditures of Federal Awards. Criteria: An institution is required to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information. The institution shall require each applicant whose application is selected by the U.S. Department of Education to verify the information required for the Verification Tracking Group to which the applicant is assigned. The OMB Compliance Supplement requires institutions to obtain acceptable documentation to verify the information required for the Verification Tracking Group to which the applicant is assigned and if necessary, submit data corrections to the central processor. Condition: Errors were identified on Institutional Student Information Records (ISIR) that were not submitted for correction to the central processor. Cause: Sierra Nevada College did not have adequate internal controls to ensure errors identified on the ISIR were corrected, regardless of the impact on the financial aid calculation. Effect: ISIR?s that were flagged for verification by the U.S. Department of Education were not corrected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 13 ISIR?s from a population of 85 selected for verification was selected for testing. Errors were identified on three ISIR?s that were not corrected. However, none of the errors impacted the aid awarded to students. Repeat Finding From Prior Year: NoRecommendation: We recommend the College enhance internal controls to ensure errors identified on the ISIR are corrected, regardless of the impact on the aid awarded to students. Views of Responsible Officials: Management agrees with this finding. Corrective Action Taken or to Be Taken: When a student is selected for verification, the Director of Financial Aid will create a file with the Verification Paperwork and attach a ?Verification Checklist? to the front of each file. This will assist in making sure all appropriate paperwork is received and the information matches what is in Banner. This information must also be updated in COD so that the ISIR files match. The Financial Services Advisor will do a second review of the verification checklist to ensure that all the data is correctly checked and all pertinent changes made to the file. The advisor will initial the checklist and it will remain with the student?s file. Anticipated Completion Date: Immediate Person Responsible for Corrective Action: Judy Roberts
The College did not have a designed individual in place to oversee compliance with the Gramm-Leach-Bliley Act until June 24, 2019. Therefore the required elements, as noted above, were not complied with during the year ended June 30, 2019. Cause: The College did not have a control process in place to ensure that they were in compliance with the Gramm-Leach-Bliley Act. Effect: The College?s information security program may not be as robust and secure as it could be. Questioned Costs: None. Context/Sampling: No sampling was used, this requirement was tested in its entirety. Repeat Finding From Prior Year: No. Recommendation: We recommend the College implement internal controls to comply with the requirements of the Gramm-Leach-Bliley Act. Views of Responsible Officials: Management agrees with this finding.
Show full finding ▾Hide full finding ▴2019-004: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, CFDA 84.268 Federal Pell Grant, CFDA 84.063 Federal Work Study Program, CFDA 84.033 Federal Supplemental Education Opportunity Grants, CFDA 84.007 Teacher Education Assistance For College and Higher Education Grants, CFDA 84.379 Special Tests and Provisions ? Gramm-Leach-Bliley Act ? Student Information Security Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under the Student Financial Assistance Cluster on the Schedule of Expenditures of Federal Awards. Criteria: The Gramm-Leach-Bliley Act requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. 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. Under an institutions? Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, the Institution must protect student financial aid information, with particular attention to information provided to institutions by the Department of Education or otherwise obtained in support of the administration of the federal student financial aid programs. The OMB Compliance Supplement requires institutions to designate an individual to coordinate the information security program and perform a risk assessment that addresses: ? Employee training and management ? Information systems, including network and software design, as well as information processing, storage, transmission and disposal ? Detecting, preventing and responding to attacks, intrusions, or other systems failures In addition, the institution must document a safeguard for each risk identified during the risk assessment. Condition: The College did not have a designed individual in place to oversee compliance with the Gramm-Leach-Bliley Act until June 24, 2019. Therefore the required elements, as noted above, were not complied with during the year ended June 30, 2019. Cause: The College did not have a control process in place to ensure that they were in compliance with the Gramm-Leach-Bliley Act. Effect: The College?s information security program may not be as robust and secure as it could be. Questioned Costs: None. Context/Sampling: No sampling was used, this requirement was tested in its entirety. Repeat Finding From Prior Year: No. Recommendation: We recommend the College implement internal controls to comply with the requirements of the Gramm-Leach-Bliley Act. Views of Responsible Officials: Management agrees with this finding.
2019-004 U.S. Department of Education Student Financial Assistance Cluster Federal Direct Student Loans, CFDA 84.268 Federal Pell Grant, CFDA 84.063 Federal Work Study Program, CFDA 84.033 Federal Supplemental Education Opportunity Grant, CFDA 84.007 Teacher Education Assistance for College and Higher Education Grants, CFDA 84.379 Special Tests and Provisions ? Gramm-Leach-Bliley Act ? Student Information Security Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under the Student Financial Assistance Cluster on the Schedule of Expenditures of Federal Awards. Criteria: The Gramm-Leach-Bliley Act requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. 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. Under an institutions? Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, the Institution must protect student financial aid information, with particular attention to information provided to institutions by the Department of Education or otherwise obtained in support of the administration of the federal student financial aid programs. The OMB Compliance Supplement requires institutions to designate an individual to coordinate the information security program and perform a risk assessment that addresses: ? Employee training and management ? Information systems, including network and software design, as well as information processing, storage, transmission and disposal ? Detecting, preventing and responding to attacks, intrusions, or other systems failures In addition, the institution must document a safeguard for each risk identified during the risk assessment. Condition: The College did not have a designed individual in place to oversee compliance with the Gramm-Leach-Bliley Act until June 24, 2019. Therefore, the required elements, as noted above, were not complied with during the year ended June 30, 2019. Cause: The College did not have a control process in place to ensure that they were in compliance with the Gramm- Leach-Bliley Act. Effect: The College?s information security program may not be as robust and secure as it could be. Questioned Costs: None Context/Sampling: No sampling was used, this requirement was tested in its entirety. Repeat Finding From Prior Year: No Recommendation: We recommend the College implement internal controls to comply with the requirements of the Gramm- Leach-Bliley Act. Views of Responsible Officials: Management agrees with this finding. Corrective Action Taken or to Be Taken: Management will take the necessary steps to create a comprehensive information security program beginning with developing, implementing and maintaining a comprehensive written plan containing administrative, technical and physical safeguards. The plan will include the following important features: designated employees to coordinate the program; reasonably foreseeable internal and external risks to security, confidentiality and integrity of customer information; design and implement information safeguards to control identified risk and regularly test; oversee service providers; and periodically re-evaluate the plan. Additionally, SNC will create a clear incident response plan and educate employees on GLBA compliance. Anticipated Completion Date: 3/1/20 Person Responsible for Corrective Action: Maia Rowland
FAC accepted this audit on January 1, 2019 — management decision was due July 1, 2019.
FAC accepted this audit on March 14, 2018 — management decision was due September 14, 2018.
FAC accepted this audit on December 21, 2016 — management decision was due June 21, 2017.
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