EIN: 911898417
UEI: VGC5UMKAHMQ7
Data as of August 24, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 16, 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 August 16, 2026 (8 days ago).
What is a management decision? →Student Financial Assistance Cluster Federal Pell Grants, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2024 - 2025 Criteria or Specific Requirement - Special Tests: NSLDS Reporting 34 CFR 690.83(b)(2) and 34 CFR 685.309 Condition - The University's internal controls did not ensure records reported to the National Student Loan Data System (NSLDS) were accurate. Cause - The program CIP Code was changed between academic year 2023-24 and 2024-25 and the update was not reflected in the student information system, Banner. The first of term degree file for Spring 2025 was delayed as the result of issues with the degree file for Fall 2024. Effect or Potential Effect - Incorrect enrollment data was reported to NSLDS. Questioned Costs - None Context - Out of a population of 4,798 status changes of students receiving Pell Grants and/or Direct Student Loans, a sample of 25 students with status changes were selected for testing. Our sample was not, and was not intended to be statistically valid. For 1 of the students tested, the CIP Code reported to NSLDS did not agree to the 2024-25 University course catalog. For 1 of the students tested, the withdrawal status was not reported to NSLDS. For 1 of the students tested, the enrollment change was submitted to Clearinghouse but was not reported to NSLDS. For 3 of the students tested, the certification date was greater than 60 days from the time the University had knowledge of the status change. Identification as a Repeat Finding - N/A Recommendation - The University should review and update their internal controls to ensure proper reporting to NSLDS.
Show full finding ▾Hide full finding ▴Student Financial Assistance Cluster Federal Pell Grants, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2024 - 2025 Criteria or Specific Requirement - Special Tests: NSLDS Reporting 34 CFR 690.83(b)(2) and 34 CFR 685.309 Condition - The University's internal controls did not ensure records reported to the National Student Loan Data System (NSLDS) were accurate. Cause - The program CIP Code was changed between academic year 2023-24 and 2024-25 and the update was not reflected in the student information system, Banner. The first of term degree file for Spring 2025 was delayed as the result of issues with the degree file for Fall 2024. Effect or Potential Effect - Incorrect enrollment data was reported to NSLDS. Questioned Costs - None Context - Out of a population of 4,798 status changes of students receiving Pell Grants and/or Direct Student Loans, a sample of 25 students with status changes were selected for testing. Our sample was not, and was not intended to be statistically valid. For 1 of the students tested, the CIP Code reported to NSLDS did not agree to the 2024-25 University course catalog. For 1 of the students tested, the withdrawal status was not reported to NSLDS. For 1 of the students tested, the enrollment change was submitted to Clearinghouse but was not reported to NSLDS. For 3 of the students tested, the certification date was greater than 60 days from the time the University had knowledge of the status change. Identification as a Repeat Finding - N/A Recommendation - The University should review and update their internal controls to ensure proper reporting to NSLDS.
Personnel turnover within the Office of the Registrar (July 2023) and the AVP for Academic Affairs (June 2024) led to procedural gaps during these transitions. Some of the proccesses and procedures suffered from a lack of transitional clarity. The Office of the Registrar is responsible for updating the STVMAJR screen in Banner which is a manual process. To rectify this, we have created a streamlined process for updates to the curriculum workflow to ensure precise alignment between Banner and CIP codes. This includes a new monthly meeting between the Registrar, Associate Registrar and AVP to review all curriculum updates, modifications, and new programs to prevent future errors. Issues with the Fall 2024 degree file delayed First of Term processing for Spring 2025. A defect introducted by an Ellucian update affected the degree file output and was resolved by updating the Banner page STVACAT (specifically the NSC Credential Level Translation column). This issue is not expected to recur. Spring 2025 First of Term processing was also delayed due to the manual creation of approximately 200 Social Security Numbers for newly admitted international students following the SLATE implementation and Admissions staffing turnover. This process has since been automated through an update to an Argos generator, eliminating the need for manual SSN creation. In addition, the National Student Clearinghouse transmission schedules were updated to allow additional processing time between files and to avoid submissions during the winter break. Specifically, transmissions for Fall Subsequent of Term were moved from January 1 to January 11, Fall Graduates Only (WS) from January 4 to January 18, and the Fall Degree file from January 14 to January 25.
Congressional Directives, ALN 93.493 U.S. Department of Health and Human Services Program Year 2024 - 2025 Criteria or Specific Requirement - Reporting 2 CFR 200.329 Condition - Semi-annual performance reports submitted to the U.S. Department of Health and Human Services (HRSA) portal were not submitted timely. Cause - The University experienced uncertainty regarding the expected submission timeline for the required performance report. Effect or Potential Effect - The University submitted the performance report to HRSA after the deadline. Questioned Costs - None Context - Out of the population of two semi-annual performance reporting requirements for the fiscal year, a sample of one report was selected for testing. Our sample was not, and was not intended to be statistically valid. The performance report tested was not submitted in a timely manner. Identification as a Repeat Finding - N/A Recommendation - The University should review and update their internal controls to ensure performance reports are submitted in a timely manner.
Show full finding ▾Hide full finding ▴Congressional Directives, ALN 93.493 U.S. Department of Health and Human Services Program Year 2024 - 2025 Criteria or Specific Requirement - Reporting 2 CFR 200.329 Condition - Semi-annual performance reports submitted to the U.S. Department of Health and Human Services (HRSA) portal were not submitted timely. Cause - The University experienced uncertainty regarding the expected submission timeline for the required performance report. Effect or Potential Effect - The University submitted the performance report to HRSA after the deadline. Questioned Costs - None Context - Out of the population of two semi-annual performance reporting requirements for the fiscal year, a sample of one report was selected for testing. Our sample was not, and was not intended to be statistically valid. The performance report tested was not submitted in a timely manner. Identification as a Repeat Finding - N/A Recommendation - The University should review and update their internal controls to ensure performance reports are submitted in a timely manner.
To enhance compliance and oversight, the Northeastern State University Grant Office has implemented a mandatory dualphase training protocol for all Principal Investigators (PIs). Starting Fiscal Year 2026, all PIs are required to complete an inital compliance training upon award initiation. Furthermore, to address findings regarding reporting timelines, the university will conduct annual refresher training for all PIs with active awards. This annual session will specifically emphasize regulatory requirements for the timely submission of technical and financial reports.
FAC accepted this audit on March 12, 2025 — management decision was due September 12, 2025.
Student Financial Assistance Cluster Federal Pell Grants, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2023 - 2024 Criteria or Specific Requirement - Reporting 34 CFR 690.83 Condition - The University's internal controls did not ensure origination records reported to the Common Origination and Disbursement (COD) System were accurate. Questioned costs - None Context - Out of a population of 4,125 students receiving Pell Grants and/or Direct Student Loans, a sample of 25 students were selected for testing. Our sample was not, and was not intended to be statistically valid. For 16 of the students tested, the enrollment date reported to COD differed from the enrollment date in the student information system, Banner. Effect - Incorrect origination record data was reported to COD. Cause - The University incorrectly reported the enrollment date to COD for Pell recipients. Identification as a repeat finding - N/A Recommendation - The University should review and update their internal controls to ensure accurate origination record data is accurately reported to COD.
Show full finding ▾Hide full finding ▴Student Financial Assistance Cluster Federal Pell Grants, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2023 - 2024 Criteria or Specific Requirement - Reporting 34 CFR 690.83 Condition - The University's internal controls did not ensure origination records reported to the Common Origination and Disbursement (COD) System were accurate. Questioned costs - None Context - Out of a population of 4,125 students receiving Pell Grants and/or Direct Student Loans, a sample of 25 students were selected for testing. Our sample was not, and was not intended to be statistically valid. For 16 of the students tested, the enrollment date reported to COD differed from the enrollment date in the student information system, Banner. Effect - Incorrect origination record data was reported to COD. Cause - The University incorrectly reported the enrollment date to COD for Pell recipients. Identification as a repeat finding - N/A Recommendation - The University should review and update their internal controls to ensure accurate origination record data is accurately reported to COD.
Banner aid year is set up prior to academic year schedule dates being available. Default dates associated with terms on STVTERM are used prior to official dates being established for the upcoming academic/aid year. Once dates are established by the institution, Student Financial Services staff (Functional Technologist, Vicki Ryals and Title IV Reporting Specialist, Heather McWilliams) and management (Director, Cindy Bendabout and Assistant Director, Kriston Gerler) will audit the following forms for accurate SAY/ AY periods: • RORTPRD • RORSAYR • RFRDEFA • RPRLOPT • RPROPTS • RORPRDS • RPRLPRD Audit of dates in Banner will be performed prior to originations being established for aid year. This will ensure accurate information is reported in Banner and COD for student records.
Student Financial Assistance Cluster Federal Pell Grants, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2023 - 2024 Criteria or Specific Requirement - Special Tests: Gramm-Leach-Bliley Act - Student Information Security 16 CFR 314.4(c)(1) - (8), 16 CFR 314.4(e) Condition - The University does not have a written information security program that addresses all required elements of the Gramm-Leach-Bliley Act. Questioned costs - None Context - On December 9, 2021, the Federal Trade Commission issued final regulations for 16 CFR Part 314 to implement the Gramm-Leach-Bliley Act information safeguarding standards that institutions must implement. The regulations established minimum standards that institutions must meet. Institutions were required to be in compliance with the revised requirements no later than June 9, 2023. The University's written information security program did not contain 9 of the 14 elements required by the revised Gramm-Leach-Bliley Act regulations. Effect - The University's written information security program does not address all required written statement elements of the Gramm-Leach-Bliley Act. Cause - The University did not update its written information security program by June 9, 2023 for the revised requirements of 16 CFR Part 314. Identification as a repeat finding - N/A Recommendation - The University should revise its written information security program to be compliant with the current requirements of 16 CFR Part 314.
Show full finding ▾Hide full finding ▴Student Financial Assistance Cluster Federal Pell Grants, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2023 - 2024 Criteria or Specific Requirement - Special Tests: Gramm-Leach-Bliley Act - Student Information Security 16 CFR 314.4(c)(1) - (8), 16 CFR 314.4(e) Condition - The University does not have a written information security program that addresses all required elements of the Gramm-Leach-Bliley Act. Questioned costs - None Context - On December 9, 2021, the Federal Trade Commission issued final regulations for 16 CFR Part 314 to implement the Gramm-Leach-Bliley Act information safeguarding standards that institutions must implement. The regulations established minimum standards that institutions must meet. Institutions were required to be in compliance with the revised requirements no later than June 9, 2023. The University's written information security program did not contain 9 of the 14 elements required by the revised Gramm-Leach-Bliley Act regulations. Effect - The University's written information security program does not address all required written statement elements of the Gramm-Leach-Bliley Act. Cause - The University did not update its written information security program by June 9, 2023 for the revised requirements of 16 CFR Part 314. Identification as a repeat finding - N/A Recommendation - The University should revise its written information security program to be compliant with the current requirements of 16 CFR Part 314.
Northeastern State University will make changes to our information security policy during the Spring 2025 semester to reflect all 14 elements of the GLBA standard. While there is a GLBA policy pending in the policy committee for campus approval, there is a desire to keep the information security policy as the central document for NSU's cybersecurity policy. The current information security policy is being worked on by NSU's ITS department in conjunction with an external vendor who is supplying our virtual Chief Information Security Officer. This work is expected to be completed by the end of March and will be submitted to our campus policy committee in April for approval of the modified document which will contain all 14 of the elements as specified in the GLBA standard and brought to our attention during the annual audit.
Student Financial Assistance Cluster Federal Pell Grants, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2023 - 2024 Criteria or Specific Requirement - Special Tests: Return of Title IV Funds 34 CFR 668.22 Condition - Return of Title IV funds were not calculated correctly and funds were not returned within the required time frame. Questioned costs - $1,104 Context - Out of a population of 423 official and unofficial withdrawals of students who received Student Financial Assistance, a sample of 25 students were selected for testing. Our sample was not, and was not intended to be statistically valid. For one of the student withdrawals tested, the calculation of funds to be returned by the University was calculated incorrectly. For another student withdrawal tested, the funds were not returned to the lender within the required time frame and the credit to the student's account was not made within the required time frame. Effect - The incorrect amount of funds were returned, funds were not returned within the required time frame, and a student's account was not credited within the required timeframe. Cause - The University did not use the correct amount of institutional charges when calculating the required return for one student. The University did not return funds within the required time frame for one student. Identification as a repeat finding - N/A Recommendation - The University should update their controls to ensure inputs used to calculate the return are accurate and agree to instututional records. The University should review its processes for ensuring return of funds are returned in a timely manner.
Show full finding ▾Hide full finding ▴Student Financial Assistance Cluster Federal Pell Grants, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2023 - 2024 Criteria or Specific Requirement - Special Tests: Return of Title IV Funds 34 CFR 668.22 Condition - Return of Title IV funds were not calculated correctly and funds were not returned within the required time frame. Questioned costs - $1,104 Context - Out of a population of 423 official and unofficial withdrawals of students who received Student Financial Assistance, a sample of 25 students were selected for testing. Our sample was not, and was not intended to be statistically valid. For one of the student withdrawals tested, the calculation of funds to be returned by the University was calculated incorrectly. For another student withdrawal tested, the funds were not returned to the lender within the required time frame and the credit to the student's account was not made within the required time frame. Effect - The incorrect amount of funds were returned, funds were not returned within the required time frame, and a student's account was not credited within the required timeframe. Cause - The University did not use the correct amount of institutional charges when calculating the required return for one student. The University did not return funds within the required time frame for one student. Identification as a repeat finding - N/A Recommendation - The University should update their controls to ensure inputs used to calculate the return are accurate and agree to instututional records. The University should review its processes for ensuring return of funds are returned in a timely manner.
Instructions for preparing R2T4 records include the appropriate steps for calculating institutional charges. A clerical error transpired and boxes that should have been unchecked were not. We have conducted training with Student Financial Services staff (Counselors: Katie Spencer, Isaac Palmer, Trace Taylor) or management (Director, Cindy Bendabout and Assistant Director, Kriston Gerler) who will be checking for accuracy of records prior to preparing letters for students. Title IV Reporting Specialist (Heather McWilliams) will audit previous week R2T4 records using the automated WD report that is generated weekly on Monday evening. This will ensure that withdrawn students are identified, R2T4 calculations are performed, and funds are returned in a timely manner.
Student Financial Assistance Cluster Federal Pell Grants, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2023 - 2024 Criteria or Specific Requirement - Special Tests: Enrollment Reporting 34 CFR 668.41(a) Condition - Published program length was not reported to the National Student Loan Data System (NSLDS) based on the definition of "normal time" to completion according to the regulations at 34 CFR 668.41(a). Questioned costs - None Context - Out of a population of 5,277 status changes of students receiving Pell Grants and/or Direct Student Loans, a sample of 25 students with status changes were selected for testing. Our sample was not, and was not intended to be statistically valid. For five of the students tested, the published program length reported to NSLDS did not agree to the program length based on the institution's determination of how long, in years, the program is designed for a full-time student to complete. Effect - Incorrect program-level record data was reported to NSLDS. Cause - The published program length for a Masters credential level was reported as 2.5 years regardless of the program length as determined by the institution for how long, in years, the program is designed for a full-time student to complete. Identification as a repeat finding - N/A Recommendation - The University should review and update controls in place to ensure proper reporting of published program length to NSLDS.
Show full finding ▾Hide full finding ▴Student Financial Assistance Cluster Federal Pell Grants, ALN 84.063 Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2023 - 2024 Criteria or Specific Requirement - Special Tests: Enrollment Reporting 34 CFR 668.41(a) Condition - Published program length was not reported to the National Student Loan Data System (NSLDS) based on the definition of "normal time" to completion according to the regulations at 34 CFR 668.41(a). Questioned costs - None Context - Out of a population of 5,277 status changes of students receiving Pell Grants and/or Direct Student Loans, a sample of 25 students with status changes were selected for testing. Our sample was not, and was not intended to be statistically valid. For five of the students tested, the published program length reported to NSLDS did not agree to the program length based on the institution's determination of how long, in years, the program is designed for a full-time student to complete. Effect - Incorrect program-level record data was reported to NSLDS. Cause - The published program length for a Masters credential level was reported as 2.5 years regardless of the program length as determined by the institution for how long, in years, the program is designed for a full-time student to complete. Identification as a repeat finding - N/A Recommendation - The University should review and update controls in place to ensure proper reporting of published program length to NSLDS.
The Registrar’s Office has already conducted an audit of the NSU Graduate programs to determine the length of each program. The Registrar (Amy Dunn) will provide the Assistant Director of Institutional Effectiveness (Morgan Grovenburg) with a spreadsheet of programs with their program length by February 14, 2025, and the Assistant Director of Institutional Effectiveness (Morgan Grovenburg) will make sure future submissions to the Student Clearinghouse match. The Registrar (Amy Dunn) and her team will input the correct program lengths in Banner (SFACPLR) by March 14, 2025.
Connecting Minority Communities Pilot Program, ALN 11.028 U.S. Department of Commerce Program Year 2023 - 2024 Criteria or Specific Requirement - Reporting 2 CFR 200.329 Condition - The University was unable to substantiate amounts reported on semi-annual performance reports and an amount reported was for the incorrect reporting period. Questioned costs - None Context - Out of the population of two semi-annual performance reporting requirements for the fiscal a year, a sample of one report was selected for testing. Our sample was not, and was not intended to be statistically valid. For three agency specific key line items tested, the University was unable to provide documentation to substantiate the amounts reported. For one agency specific key line item tested, the amount reported was for the incorrect reporting period. Effect - Certain agency specific key line items reported were not substantiated with appropriate documentation and one key line item was reported for the incorrect reporting period. Cause - The University did not maintain supporting documentation for amounts reported in the semi-annual performance report and improper report parameters were used to generate amounts reported. Identification as a repeat finding - N/A Recommendation - The University should maintain adequate supporting documentation used in the preparation of performance reports and should review the supporting documentation used in preparation of the reports to ensure it is for the appropriate reporting period.
Show full finding ▾Hide full finding ▴Connecting Minority Communities Pilot Program, ALN 11.028 U.S. Department of Commerce Program Year 2023 - 2024 Criteria or Specific Requirement - Reporting 2 CFR 200.329 Condition - The University was unable to substantiate amounts reported on semi-annual performance reports and an amount reported was for the incorrect reporting period. Questioned costs - None Context - Out of the population of two semi-annual performance reporting requirements for the fiscal a year, a sample of one report was selected for testing. Our sample was not, and was not intended to be statistically valid. For three agency specific key line items tested, the University was unable to provide documentation to substantiate the amounts reported. For one agency specific key line item tested, the amount reported was for the incorrect reporting period. Effect - Certain agency specific key line items reported were not substantiated with appropriate documentation and one key line item was reported for the incorrect reporting period. Cause - The University did not maintain supporting documentation for amounts reported in the semi-annual performance report and improper report parameters were used to generate amounts reported. Identification as a repeat finding - N/A Recommendation - The University should maintain adequate supporting documentation used in the preparation of performance reports and should review the supporting documentation used in preparation of the reports to ensure it is for the appropriate reporting period.
The grants and contract personnel will review current semi-annual performance reports and compare them to current document/backup before submitting the reports. Grants and contract personnel will ensure that documentation for all reports be in compliance with 2 CFR 200 and the University's adopted federal grant program policy and procedures. There will be informal training for Principal Investigators on preparing, processing reports and on the federal policies and procedures when a new grant is setup in Banner and a meeting is set with the new PI. Annual training will be done for grants personnel when they attend NCURA Conferences each year and campus training in Banner, the Purch etc. will start in April 2025. Reminders will be sent to grants and contract personnel regarding proper reporting when a file is prepared for the new grant and annually after that.
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