Pacific Union College

EIN: 941279798

UEI: EAKUXBK2M1C3

Data as of August 21, 2026

Pacific Union College9 audit years7 findings2 repeat
9
Audit Years
7
Total Findings
2
Repeat Findings

FY 2025-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 30, 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 30, 2026 (39 days from today).

What is a management decision? →
2025-001
Special Tests & Provisions

Federal Program – Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268. Program Year – July 1, 2024 – June 30, 2025 Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the National Student Loan Data System (NSLDS) sends a Roster file to the school or its third-party servicer. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition – NSLDS did not reflect that proper status for certain students, or the status update was not made within the proper timeframe. Questioned Costs – None Context – Of the 25 students selected for testing, the following exceptions were identified: • No status update was made for four students • Nine students were reported as separated from the College, but not within the required timeframe • Six students were reported with incorrect status changes. Our sample was not intended to be statistically valid. Cause – The College experienced turnover in the Registrar’s office during the year, which could have contributed to the exceptions in the testing Effect – Status changes were not properly reported to NSLDS. Identification as a Repeat Finding – N/A Recommendation – We recommend that the College review its policies and procedures around reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Views of Responsible Officials and Planned Corrective Action – Pacific Union College transmits enrollment information to NSDLS through the National Student Clearinghouse (NCS), a third-party organization. PUC was faced with an unprecedented series of events related to data reporting to the National Student Clearinghouse between January and May 2025. During the month of February 2025, the College Registrar resigned without notice and the Director of Institutional Research tragically passed away within one ten day period. At that time the Director of College Admissions was asked to serve as the emergency Registrar and emergency IR Director. The above events led to some gaps in reporting to the NSC during the months noted above including some gaps in reporting that had occurred before the Registrar resigned. Communication with the NSC began immediately and during this time a series of reporting deadlines were “forgiven” by the NSC liaisons in support of PUC during a difficult series of one time events. Since the above dates PUC has been consistent and timely with all reporting to the NSC and the college anticipates that current staffing levels and cross training will prevent any such occurrences in the future.

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Full finding narrative

Federal Program – Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268. Program Year – July 1, 2024 – June 30, 2025 Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the National Student Loan Data System (NSLDS) sends a Roster file to the school or its third-party servicer. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition – NSLDS did not reflect that proper status for certain students, or the status update was not made within the proper timeframe. Questioned Costs – None Context – Of the 25 students selected for testing, the following exceptions were identified: • No status update was made for four students • Nine students were reported as separated from the College, but not within the required timeframe • Six students were reported with incorrect status changes. Our sample was not intended to be statistically valid. Cause – The College experienced turnover in the Registrar’s office during the year, which could have contributed to the exceptions in the testing Effect – Status changes were not properly reported to NSLDS. Identification as a Repeat Finding – N/A Recommendation – We recommend that the College review its policies and procedures around reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Views of Responsible Officials and Planned Corrective Action – Pacific Union College transmits enrollment information to NSDLS through the National Student Clearinghouse (NCS), a third-party organization. PUC was faced with an unprecedented series of events related to data reporting to the National Student Clearinghouse between January and May 2025. During the month of February 2025, the College Registrar resigned without notice and the Director of Institutional Research tragically passed away within one ten day period. At that time the Director of College Admissions was asked to serve as the emergency Registrar and emergency IR Director. The above events led to some gaps in reporting to the NSC during the months noted above including some gaps in reporting that had occurred before the Registrar resigned. Communication with the NSC began immediately and during this time a series of reporting deadlines were “forgiven” by the NSC liaisons in support of PUC during a difficult series of one time events. Since the above dates PUC has been consistent and timely with all reporting to the NSC and the college anticipates that current staffing levels and cross training will prevent any such occurrences in the future.

Corrective Action Plan

Finding: 2025-001 CFDA #: 84.063 and 84.268 Recommendation: We recommend the College monitor and evaluate the schedule reporting dates to the NSLDS and confirm or modify existing policies, procedures, or processes from timely identification to ensure that status changes can be communicated to the NSLDS within the regulatory timeframes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding Corrective Action Plan: All graduate and withdrawn student files will be reviewed on a monthly basis to verify any status changes are reported to NSLDS within regulatory timeframes. Training and professional development will be required for responsible staff to ensure a compliance schedule is developed. Personnel will be evaluated to ensure existing policies, procedures, and processes are followed and supported through corrective action where needed. Name of Contact Responsible for Corrective Action: Joy Hirdler, Vice President of Financial Administration, Chief Financial Officer, 707-965-6699 Anticipated Completion Date: March 31, 2026

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FY 2024-06-30

FAC accepted this audit on July 25, 2025 — management decision was due January 25, 2026.

2024-001
Special Tests & Provisions

Federal Program – Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268. Program Year – July 1, 2023 – June 30, 2024 Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the National Student Loan Data System (NSLDS) sends a Roster file to the school or its third-party servicer. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition – NSLDS did not reflect that proper status for certain students, or the status update was not made within the proper timeframe. Questioned Costs – None Context – Of the 17 students selected for testing, the following exceptions were identified: • No status update was made for four students • Nine students were reported as separated from the College, but not within the required timeframe • Six students were reported with incorrect status changes. Our sample was not intended to be statistically valid. Cause – The College experienced turnover in the Registrar’s office during the year, which could have contributed to the exceptions in the testing Effect – Status changes were not properly reported to NSLDS. Identification as a Repeat Finding – N/A Recommendation – We recommend that the College review its policies and procedures around reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Views of Responsible Officials and Planned Corrective Action – Pacific Union College transmits enrollment information to NSDLS through the National Student Clearinghouse (NCS), a third-party organization. PUC was faced with an unprecedented series of events related to data reporting to the National Student Clearinghouse between January and May 2024. During the month of February 2024, the College Registrar resigned without notice and the Director of Institutional Research tragically passed away within one ten day period. At that time the Director of College Admissions was asked to serve as the emergency Registrar and emergency IR Director. The above events led to some gaps in reporting to the NSC during the months noted above including some gaps in reporting that had occurred before the Registrar resigned. Communication with the NSC began immediately and during this time a series of reporting deadlines were “forgiven” by the NSC liaisons in support of PUC during a difficult series of one time events. Since the above dates PUC has been consistent and timely with all reporting to the NSC and the college anticipates that current staffing levels and cross training will prevent any such occurrences in the future.

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Full finding narrative

Federal Program – Department of Education, Student Financial Assistance Cluster, Federal Pell Grant Program, Assistance Listing Number 84.063; Federal Direct Loan Program, Assistance Listing Number 84.268. Program Year – July 1, 2023 – June 30, 2024 Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level. In addition, at a minimum, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that the National Student Loan Data System (NSLDS) sends a Roster file to the school or its third-party servicer. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition – NSLDS did not reflect that proper status for certain students, or the status update was not made within the proper timeframe. Questioned Costs – None Context – Of the 17 students selected for testing, the following exceptions were identified: • No status update was made for four students • Nine students were reported as separated from the College, but not within the required timeframe • Six students were reported with incorrect status changes. Our sample was not intended to be statistically valid. Cause – The College experienced turnover in the Registrar’s office during the year, which could have contributed to the exceptions in the testing Effect – Status changes were not properly reported to NSLDS. Identification as a Repeat Finding – N/A Recommendation – We recommend that the College review its policies and procedures around reporting status changes and other enrollment information to NSLDS to ensure timely and accurate reporting. Views of Responsible Officials and Planned Corrective Action – Pacific Union College transmits enrollment information to NSDLS through the National Student Clearinghouse (NCS), a third-party organization. PUC was faced with an unprecedented series of events related to data reporting to the National Student Clearinghouse between January and May 2024. During the month of February 2024, the College Registrar resigned without notice and the Director of Institutional Research tragically passed away within one ten day period. At that time the Director of College Admissions was asked to serve as the emergency Registrar and emergency IR Director. The above events led to some gaps in reporting to the NSC during the months noted above including some gaps in reporting that had occurred before the Registrar resigned. Communication with the NSC began immediately and during this time a series of reporting deadlines were “forgiven” by the NSC liaisons in support of PUC during a difficult series of one time events. Since the above dates PUC has been consistent and timely with all reporting to the NSC and the college anticipates that current staffing levels and cross training will prevent any such occurrences in the future.

Corrective Action Plan

Pacific Union College transmits enrollment information to NSDLS through the National Student Clearinghouse (NCS), a third-party organization. PUC was faced with an unprecedented series of events related to data reporting to the National Student Clearinghouse between January and May 2024. During the month of February 2024, the College Registrar resigned without notice and the Director of Institutional Research tragically passed away within one ten day period. At that time the Director of College Admissions was asked to serve as the emergency Registrar and emergency IR Director. The above events led to some gaps in reporting to the NSC during the months noted above including some gaps in reporting that had occurred before the Registrar resigned. Communication with the NSC began immediately and during this time a series of reporting deadlines were “forgiven” by the NSC liaisons in support of PUC during a difficult series of one time events. Since the above dates PUC has been consistent and timely with all reporting to the NSC and the college anticipates that current staffing levels and cross training will prevent any such occurrences in the future.

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FY 2019-06-30

FAC accepted this audit on June 25, 2020 — management decision was due December 25, 2020.

2019-001
Special Tests & Provisions

Federal Program ? Department of Education, Student Financial Assistance Cluster; Federal Supplemental Educational Opportunity Grant Program, CFDA 84.007; Federal Work-Study Program, CFDA 84.033; Federal Perkins Loan Program, CFDA 84.038; Federal Pell Grant Program, CFDA 84.063; Federal Direct Student Loan Program, CFDA 84.268 Program Year ? July 1, 2018 ? June 30, 2019 Criteria or Specific Requirement ? Special Tests and Provisions ? Verification ? An institution is required to have appropriate procedures that incorporate the provisions of federal regulations for verifying applicant information. The institution requires each applicant whose application is selected by the central processor to provide documentation to verify the information specified in the federal regulations. This also requires the institution to verify any information used to calculate the applicant?s EFC that the institution has reason to believe is inaccurate. Generally, the information that must be updated is the number of family members, number of family members attending postsecondary educational institutions, the applicant?s dependency status, adjusted gross income, U.S. income tax paid and untaxed income and benefits. If discrepancies are found during the verification process, data corrections must be submitted to the central processor and awards recalculated. Condition ? Certain data inaccuracies were present and corrections were not made during the verification process. Questioned Costs ? N/A Context ? Of a sample of 25 students tested from a population of 299 students who required verification of information on the ISIR, three students were found to have discrepancies between the information listed on the ISIR, and the supporting documentation provided in the verification process. Our sample was not, and was not intended to be, statistically valid. Cause ? Due to turnover in the financial aid department, certain secondary checks were not consistently performed. Effect ? The College is not in full compliance with verification guidelines as outlined in sections 34 CFR 668.51-668.61. Identification as a Repeat Finding ? N/A. Recommendation ? We recommend secondary reviews be performed on all verification steps, as well as a check be put in place to ensure all required changes are made to the ISIR as a result of verification procedures performed.

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Federal Program ? Department of Education, Student Financial Assistance Cluster; Federal Supplemental Educational Opportunity Grant Program, CFDA 84.007; Federal Work-Study Program, CFDA 84.033; Federal Perkins Loan Program, CFDA 84.038; Federal Pell Grant Program, CFDA 84.063; Federal Direct Student Loan Program, CFDA 84.268 Program Year ? July 1, 2018 ? June 30, 2019 Criteria or Specific Requirement ? Special Tests and Provisions ? Verification ? An institution is required to have appropriate procedures that incorporate the provisions of federal regulations for verifying applicant information. The institution requires each applicant whose application is selected by the central processor to provide documentation to verify the information specified in the federal regulations. This also requires the institution to verify any information used to calculate the applicant?s EFC that the institution has reason to believe is inaccurate. Generally, the information that must be updated is the number of family members, number of family members attending postsecondary educational institutions, the applicant?s dependency status, adjusted gross income, U.S. income tax paid and untaxed income and benefits. If discrepancies are found during the verification process, data corrections must be submitted to the central processor and awards recalculated. Condition ? Certain data inaccuracies were present and corrections were not made during the verification process. Questioned Costs ? N/A Context ? Of a sample of 25 students tested from a population of 299 students who required verification of information on the ISIR, three students were found to have discrepancies between the information listed on the ISIR, and the supporting documentation provided in the verification process. Our sample was not, and was not intended to be, statistically valid. Cause ? Due to turnover in the financial aid department, certain secondary checks were not consistently performed. Effect ? The College is not in full compliance with verification guidelines as outlined in sections 34 CFR 668.51-668.61. Identification as a Repeat Finding ? N/A. Recommendation ? We recommend secondary reviews be performed on all verification steps, as well as a check be put in place to ensure all required changes are made to the ISIR as a result of verification procedures performed.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Actions ? The College?s student finance department will perform secondary reviews on all verification steps, as well as a secondary check to ensure all required changes are made to the ISIR. The first verification will be made by a financial aid counselor. The student account manager, student account liaison or the student financial services director will perform the second verification.

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2019-002
Special Tests & Provisions

Federal Program ? Department of Education, Student Financial Assistance Cluster; Federal Supplemental Educational Opportunity Grant Program, CFDA 84.007; Federal Work-Study Program, CFDA 84.033; Federal Perkins Loan Program, CFDA 84.038; Federal Pell Grant Program, CFDA 84.063; Federal Direct Student Loan Program, CFDA 84.268 Program Year ? July 1, 2018 ? June 30, 2019 Criteria or Specific Requirement ? Special Tests and Provisions ? Return of Title IV Funds ? When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment (34 CFR Sections 668.22(a)(1)-(3)). Condition ? The earned percentage, based upon the enrollment period determined and the amount of aid to return, was calculated incorrectly. The College returned the incorrect amount of funds to the Department of Education because of the error in the calculation. Questioned Costs ? N/A Context ? Of a sample of three return of funds tested from a population of 30 performed during the examination period, one return of funds calculation was not performed correctly. This resulted in an incorrect amount of funds being returned to the Department of Education for that student. Our sample was not, and was not intended to be, statistically valid. Cause ? The number of days in the break for the fall semester was calculated incorrectly when determining the enrollment period. Effect ? The College returned the incorrect amount of funds to the Department of Education. Identification as a Repeat Finding ? N/A. Recommendation ? We recommend a secondary review be implemented on the schedule used for the return of funds calculation.

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Federal Program ? Department of Education, Student Financial Assistance Cluster; Federal Supplemental Educational Opportunity Grant Program, CFDA 84.007; Federal Work-Study Program, CFDA 84.033; Federal Perkins Loan Program, CFDA 84.038; Federal Pell Grant Program, CFDA 84.063; Federal Direct Student Loan Program, CFDA 84.268 Program Year ? July 1, 2018 ? June 30, 2019 Criteria or Specific Requirement ? Special Tests and Provisions ? Return of Title IV Funds ? When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment (34 CFR Sections 668.22(a)(1)-(3)). Condition ? The earned percentage, based upon the enrollment period determined and the amount of aid to return, was calculated incorrectly. The College returned the incorrect amount of funds to the Department of Education because of the error in the calculation. Questioned Costs ? N/A Context ? Of a sample of three return of funds tested from a population of 30 performed during the examination period, one return of funds calculation was not performed correctly. This resulted in an incorrect amount of funds being returned to the Department of Education for that student. Our sample was not, and was not intended to be, statistically valid. Cause ? The number of days in the break for the fall semester was calculated incorrectly when determining the enrollment period. Effect ? The College returned the incorrect amount of funds to the Department of Education. Identification as a Repeat Finding ? N/A. Recommendation ? We recommend a secondary review be implemented on the schedule used for the return of funds calculation.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Actions ? The College?s student finance department will perform a secondary review on the schedule used for the return of funds calculation. The student account manager will process R2T4, and the student financial services director will perform the secondary review.

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2019-003
Special Tests & Provisions
REPEAT

Federal Program ? Department of Education, Student Financial Assistance Cluster; Federal Pell Grant Program, CFDA 84.063; Federal Direct Loan Program, CFDA 84.268, Federal Perkins Loan Program, CFDA 84.038. Program Year ? July 1, 2018 ? June 30, 2019 Criteria or Specific Requirement ? Special Tests and Provisions ? Enrollment Reporting ? Under the Pell grant and loan programs, colleges must complete and return within 30 days the Enrollment Reporting roster file. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date and submit the changes electronically through the batch method or the NSLDS web site. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Unless the school expects to complete its next roster within 60 days, the College must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis. (FPL, 34 CFR Section 674.19; Pell, 34 CFR Section 690.83(b)(2); Direct Loan, 34 CFR Section 685.309). Condition ? Notification of the student status change (graduated, withdrew, less than half-time) did not reach the NSLDS within the required timeframe. Questioned Costs ? N/A Context ? Out of a sample of 40 students from a population of 336 students who had changes in status during the year, NSLDS was not provided timely notification for six of the student status changes reviewed. Our sample was not, and was not intended to be, statistically valid. Cause ? Information between the College and NSLDS was not updated timely. This could have been a result of certain glitches in the reporting between the College and the Clearinghouse. Effect ? The status change was ultimately reported correctly to NSLDS, but was not performed timely. Identification as a Repeat Finding ? Yes, see finding 2018-001. Recommendation ? We recommend the College implement secondary checks to ensure proper and timely reporting to the NSLDS.

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Federal Program ? Department of Education, Student Financial Assistance Cluster; Federal Pell Grant Program, CFDA 84.063; Federal Direct Loan Program, CFDA 84.268, Federal Perkins Loan Program, CFDA 84.038. Program Year ? July 1, 2018 ? June 30, 2019 Criteria or Specific Requirement ? Special Tests and Provisions ? Enrollment Reporting ? Under the Pell grant and loan programs, colleges must complete and return within 30 days the Enrollment Reporting roster file. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date and submit the changes electronically through the batch method or the NSLDS web site. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Unless the school expects to complete its next roster within 60 days, the College must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis. (FPL, 34 CFR Section 674.19; Pell, 34 CFR Section 690.83(b)(2); Direct Loan, 34 CFR Section 685.309). Condition ? Notification of the student status change (graduated, withdrew, less than half-time) did not reach the NSLDS within the required timeframe. Questioned Costs ? N/A Context ? Out of a sample of 40 students from a population of 336 students who had changes in status during the year, NSLDS was not provided timely notification for six of the student status changes reviewed. Our sample was not, and was not intended to be, statistically valid. Cause ? Information between the College and NSLDS was not updated timely. This could have been a result of certain glitches in the reporting between the College and the Clearinghouse. Effect ? The status change was ultimately reported correctly to NSLDS, but was not performed timely. Identification as a Repeat Finding ? Yes, see finding 2018-001. Recommendation ? We recommend the College implement secondary checks to ensure proper and timely reporting to the NSLDS.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Actions ? To fix this issue for the future, we will work with the Clearinghouse to make sure that the ?G? status is processed more quickly. It appears that we currently have a 4-5 week gap between the degree verification and the ?G? status, and this delay is causing the problem with the reporting timeline.

Prior Finding References

2018-001

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FY 2018-06-30

FAC accepted this audit on March 20, 2019 — management decision was due September 20, 2019.

2018-001
Special Tests & Provisions

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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FY 2016-06-30

FAC accepted this audit on February 2, 2017 — management decision was due August 2, 2017.

2016-001
Special Tests & Provisions
MATERIAL WEAKNESSREPEAT

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2015-002

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