EIN: 941339635
UEI: DKLXHQNHDBH4
Audited by: CapinCrouse LLC
Oversight agency: 84 [Department of Education]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 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 July 30, 2026 (31 days ago).
What is a management decision? →Title IV funds were not always returned accurately or timely when students withdrew during a term. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 7 students, 3 students who withdrew during the audit period tested had a total of $13,214 Federal Direct Loans (FDL) and $1,820 of Pell returned late, ranging from 17 to 44 days late. Additionally one student in a modular program, had all their Pell returned when they unofficially withdrew but was eligible for $924. Cause: Staffing issues and turnover Effect: Incorrect amounts of federal funding were returned. Return of Title IV funds were not performed timely. Identification as repeat finding, if applicable: Yes, 2024-001. Recommendation: We recommend that R2T4’s be calculated as soon as the financial aid office is notified of student’s official withdrawal or when it is determined a student unofficially withdrew. We also recommend that an individual with appropriate knowledge review R2T4 calculations and returns made to help ensure that internal controls are operating effectively to achieve compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Incorrect and Untimely Return of Title IV Funds (R2T4) Calculations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Pell Grants and 84.268 Federal Direct Loans Federal Award Identification #: 2024-2025 Financial Aid Year Condition: Title IV funds were not always returned accurately or timely when students withdrew during a term. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 7 students, 3 students who withdrew during the audit period tested had a total of $13,214 Federal Direct Loans (FDL) and $1,820 of Pell returned late, ranging from 17 to 44 days late. Additionally one student in a modular program, had all their Pell returned when they unofficially withdrew but was eligible for $924. Cause: Staffing issues and turnover Effect: Incorrect amounts of federal funding were returned. Return of Title IV funds were not performed timely. Identification as repeat finding, if applicable: Yes, 2024-001. Recommendation: We recommend that R2T4’s be calculated as soon as the financial aid office is notified of student’s official withdrawal or when it is determined a student unofficially withdrew. We also recommend that an individual with appropriate knowledge review R2T4 calculations and returns made to help ensure that internal controls are operating effectively to achieve compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
2025-002 Incorrect and Untimely Return of Title IV Funds (R2T4) Calculations Planned Corrective Action: The University agrees mostly with these findings. The University determined that delays in certain Return of Title IV (R2T4) calculations were primarily the result of gaps in the timing and consistency of withdrawal information communicated between offices during the audit period. To address this, the University has strengthened procedures between the Registrar’s Office and the Financial Aid Office to ensure timely identification of official and unofficial withdrawals and prompt initiation of R2T4 calculations. The University has reviewed the affected student accounts and confirmed that Title IV funds were returned appropriately. With respect to the student in the modular program, the Pell Grant adjustment was required because the student had already received Pell Grant funds at another institution during the same award year and was not eligible for the additional amount; this adjustment was not the result of an R2T4 calculation. The University will continue to monitor withdrawal reporting and R2T4 processing to ensure ongoing compliance with federal requirements. Person Responsible for Corrective Action Plan: Adrienne Currington, University Registrar and Shondra Dickson, Director of Financial Aid Anticipated Date of Completion: September 1, 2026
2024-001
The University initiated Federal Direct Loan (FDL) and Pell drawdowns from G5 for amounts greater than what had been disbursed to students, resulting in excess cash on hand for more than 3 days. Criteria: 34 CFR 668.162(a), 34 CFR 668.162(c) Questioned Costs: $0 Context: 2 FDL drawdowns out of 4 tested and 1 Pell drawdown out of 2 tested were greater than the amounts disbursed to students and therefore, not all disbursed within 3 days as required. The Pell overdraw occurred in September 2024 in the amount of $20,087 and was fully disbursed by October 2024. One FDL overdraw occurred in January 2025 in the amount of $52,389 and was fully disbursed by February 2025. One overdraw occurred at the end of April 2025 in the amount of $170,186 and wasn’t fully disbursed until June 2025. It was also noted that another drawdown for $550,000 in March 2025 wasn’t tied to any disbursements but was then returned in April 2025, 12 days later. Cause: Turnover and oversight by management. It appears that draws are being done based on what is authorized in G5 rather than the actual disbursement to student accounts. Effect: Non-compliance with cash management requirements to minimize the time between drawing the Title IV funds and disbursement of those funds to students. Cash on hand in excess of allowable levels and time frames may result in interest owed back to the Department of Education on excess cash. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University review student disbursements reports generated to ensure compliance with cash management requirements to disburse aid first before drawing FDL and Pell. We also recommend the University determine the amount of interest to be returned on the excess cash and return amounts greater than $500 to the Department of Education. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Cash Management Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Pell Grants and 84.268 Federal Direct Loans Federal Award Identification #: 2024-2025 Financial Aid Year Condition: The University initiated Federal Direct Loan (FDL) and Pell drawdowns from G5 for amounts greater than what had been disbursed to students, resulting in excess cash on hand for more than 3 days. Criteria: 34 CFR 668.162(a), 34 CFR 668.162(c) Questioned Costs: $0 Context: 2 FDL drawdowns out of 4 tested and 1 Pell drawdown out of 2 tested were greater than the amounts disbursed to students and therefore, not all disbursed within 3 days as required. The Pell overdraw occurred in September 2024 in the amount of $20,087 and was fully disbursed by October 2024. One FDL overdraw occurred in January 2025 in the amount of $52,389 and was fully disbursed by February 2025. One overdraw occurred at the end of April 2025 in the amount of $170,186 and wasn’t fully disbursed until June 2025. It was also noted that another drawdown for $550,000 in March 2025 wasn’t tied to any disbursements but was then returned in April 2025, 12 days later. Cause: Turnover and oversight by management. It appears that draws are being done based on what is authorized in G5 rather than the actual disbursement to student accounts. Effect: Non-compliance with cash management requirements to minimize the time between drawing the Title IV funds and disbursement of those funds to students. Cash on hand in excess of allowable levels and time frames may result in interest owed back to the Department of Education on excess cash. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University review student disbursements reports generated to ensure compliance with cash management requirements to disburse aid first before drawing FDL and Pell. We also recommend the University determine the amount of interest to be returned on the excess cash and return amounts greater than $500 to the Department of Education. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Cash Management Planned Corrective Action: The University agrees with the finding. The University determined that certain federal drawdowns during the audit period were initiated based on authorized amounts rather than confirmed student disbursements, resulting in excess cash on hand beyond allowable timeframes. To address this, the University has reviewed its cash management procedures and strengthened processes to ensure that federal funds are drawn only after student disbursements have been posted to student accounts. The University has reviewed the identified transactions, confirmed that excess funds were fully disbursed or returned as required, and will calculate and remit any applicable interest in accordance with federal regulations. Ongoing monitoring has been implemented to ensure drawdowns are consistently aligned with actual disbursement activity and compliance with cash management requirements is maintained. Person Responsible for Corrective Action Plan: Ken Macur, Interim Chief Financial Officer Anticipated Date of Completion: September 1, 2026
FAC accepted this audit on January 30, 2025 — management decision was due July 30, 2025.
Title IV funds were not always returned accurately or timely when students withdrew during a term. Criteria: 34 CFR 668.22 Questioned Costs: $2,504 Context: Out of 11 students, 5 students who withdrew during the audit period tested had a total of $29,006 Federal Direct Loans (FDL) and $1,110 of Pell returned late, ranging from 39 to 154 days late. 7 of 11 withdrawals tested had R2T4 calculation errors and/or incorrect returns of aid. 4 students had $8,861 of FDL and 1 had $1,849 of Pell over returned, while 3 students had $2,380 of FDL and $124 of Pell funds under returned. Cause: Staffing issues and turnover. Incorrect calendar set up leading to 4 miscalculations and 2 errors were caused by using the incorrect calendar dates. Incorrect inputs into the R2T4 calculation led to the other error. Effect: Incorrect amounts of federal funding were returned. Returned of Title IV funds were not performed timely. Identification as repeat finding, if applicable: n/a Recommendation: We recommend an individual with appropriate knowledge of R2T4 calculations review each system set up and recalculate the first few withdrawals manually to ensure the system is functioning as intended. We also recommend that returns be verified once they post on the student account to verify they match what is calculated on the R2T4 calculation. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Incorrect and Untimely Returns of Title IV Funds (R2T4) Calculations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007 Federal Award Identification #: 2023-2024 Award Year Condition: Title IV funds were not always returned accurately or timely when students withdrew during a term. Criteria: 34 CFR 668.22 Questioned Costs: $2,504 Context: Out of 11 students, 5 students who withdrew during the audit period tested had a total of $29,006 Federal Direct Loans (FDL) and $1,110 of Pell returned late, ranging from 39 to 154 days late. 7 of 11 withdrawals tested had R2T4 calculation errors and/or incorrect returns of aid. 4 students had $8,861 of FDL and 1 had $1,849 of Pell over returned, while 3 students had $2,380 of FDL and $124 of Pell funds under returned. Cause: Staffing issues and turnover. Incorrect calendar set up leading to 4 miscalculations and 2 errors were caused by using the incorrect calendar dates. Incorrect inputs into the R2T4 calculation led to the other error. Effect: Incorrect amounts of federal funding were returned. Returned of Title IV funds were not performed timely. Identification as repeat finding, if applicable: n/a Recommendation: We recommend an individual with appropriate knowledge of R2T4 calculations review each system set up and recalculate the first few withdrawals manually to ensure the system is functioning as intended. We also recommend that returns be verified once they post on the student account to verify they match what is calculated on the R2T4 calculation. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect and Untimely Returns of Title IV Funds (R2T4) Calculations Planned Corrective Action: The University agrees with these findings. It was determined that these issues primarily resulted from a critical staff shortage in the Financial Aid Office during the audit period. This shortage significantly impacted our ability to complete R2T4 calculations accurately and withing the required timeframe. To address these findings, the institution will prioritize the recruitment and onboarding of additional qualified staff to alleviate workload challenges and support timely processing of R2T4s. Concurrently, we will provide comprehensive training to all financial aid staff, focusing on federal regulations, calculation methods, and deadlines. To reduce errors, we will establish a robust quality assurance process that includes a secondary review of all R2T4 calculations before finalization. Person Responsible for Corrective Action Plan: Shondra Dickson, Director of Financial Aid Anticipated Date of Completion: September 1, 2025
The College did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 67 students tested, 2 students were reported as no record found though both had Title IV aid. Cause: The University was not completing timely reconciliations of enrollment statuses throughout the year. One of the students started and withdrew before the fall 23 enrollment reporting was completed. Both students were corrected as part of the audit process. Effect: Inaccurate reporting can impact a student's loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: n/a Recommendation: We recommend the College put a system in place to ensure that the College is completing reconciliations of enrollment status periodically, and that the College is completing spot checks of enrollment statuses to NSLDS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Other Matter DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2023-2024 Financial Aid Year Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 67 students tested, 2 students were reported as no record found though both had Title IV aid. Cause: The University was not completing timely reconciliations of enrollment statuses throughout the year. One of the students started and withdrew before the fall 23 enrollment reporting was completed. Both students were corrected as part of the audit process. Effect: Inaccurate reporting can impact a student's loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: n/a Recommendation: We recommend the College put a system in place to ensure that the College is completing reconciliations of enrollment status periodically, and that the College is completing spot checks of enrollment statuses to NSLDS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Our records indicate that the student's account at Simpson University was reported to the National Student Clearinghouse (NSC) on several occasions while the student was enrolled. It is the duty of the NSC program to ensure the accurate transmission of information to the National Student Loan Data System (NSLDS). Once the data leaves Simpson University, the university does not track its progress to other entities. It is recommended that any necessary adjustments be discussed directly with the NSC, particularly if issues arise from their data transfer to third parties. To ensure accuracy, various methods can be implemented, such as conducting random data audits to verify that the information sent to NSC matches that in the NSLDS. This process can be quite exhaustive. Alternatively, a sample audit might involve reviewing a certain error threshold; for instance, if 300 records are submitted, a check of 15-30 records could be performed, reflecting an error tolerance of approximately 5-10%. Another option is for the reporting body to collaborate with NSC in identifying any errors or complications that may affect the correct data transmission. Simpson University maintains evidence that all data submissions to the NSC have been properly reported, accepted, and timely without any discrepancies. Person Responsible for Corrective Action Plan: Adrienne Currington, Registrar Anticipated Date of Completion: Next NSC reporting cycle
FAC accepted this audit on December 20, 2023 — management decision was due June 20, 2024.
Errors in need analysis for federal financial aid let to inaccurate awarding and disbursing need based federal financial aid. Criteria: 34 CFR 685.200 and 34 CFR 685.203 Questioned Costs: $0 Context: Out of 60 students tested, one was under awarded subsidized Federal Direct Loans by $3,500 and three students were over awarded subsidized Federal Direct Loans totaling $6,260. Cause: Turnover in staffing and inexperience of new Financial Aid staff. For one student, the University followed the student request to award the unsubsidized loan and reject the subsidized loan. However, per Federal regulations, the school must always award the maximum subsidized loan before awarding any Unsubsidized loan funds. Three students were awarded over need and should have been awarded the loans as unsubsidized. Effect: Incorrect allocation of subsidized versus unsubsidized which affects the amount and timing of interest the student must repay. Identification as repeat finding, if applicable: N/A Recommendation: We recommend that the University set up reports in the student information system to periodically check for over or under awarding of need based federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Need Analysis Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Award Year Condition: Errors in need analysis for federal financial aid let to inaccurate awarding and disbursing need based federal financial aid. Criteria: 34 CFR 685.200 and 34 CFR 685.203 Questioned Costs: $0 Context: Out of 60 students tested, one was under awarded subsidized Federal Direct Loans by $3,500 and three students were over awarded subsidized Federal Direct Loans totaling $6,260. Cause: Turnover in staffing and inexperience of new Financial Aid staff. For one student, the University followed the student request to award the unsubsidized loan and reject the subsidized loan. However, per Federal regulations, the school must always award the maximum subsidized loan before awarding any Unsubsidized loan funds. Three students were awarded over need and should have been awarded the loans as unsubsidized. Effect: Incorrect allocation of subsidized versus unsubsidized which affects the amount and timing of interest the student must repay. Identification as repeat finding, if applicable: N/A Recommendation: We recommend that the University set up reports in the student information system to periodically check for over or under awarding of need based federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Need Analysis Planned Corrective Action: The University recognizes the federal regulations regarding over‐awarding and has implemented the use of a delivered report through the Student Information System to address this concern. Person Responsible for Corrective Action Plan: Shondra Dickson, Director of Financial Aid Anticipated Date of Completion: Implemented
The University did not always have supporting documentation for the in-kind match or accurate reporting of the in-kind match for the GEAR UP federal program. Criteria: 2 CFR 200.306 Questioned Costs: $0 Context: Out of 23 GEAR UP in-kind match items tested, supporting documentation was not located for one item and for another item, the support provided did not agree to the amount reported to Department of Education. Cause: Turnover in GEAR UP staffing. Effect: Record retention issue and inaccurate reporting of match. Identification as repeat finding, if applicable: N/A Recommendation: We recommend that the University keep their documents in a central location and verify in-kind match reported annually against supporting documentation. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴GEAR UP Program In-Kind Match Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.334A Federal Award Identification #: P334A170060 Condition: The University did not always have supporting documentation for the in-kind match or accurate reporting of the in-kind match for the GEAR UP federal program. Criteria: 2 CFR 200.306 Questioned Costs: $0 Context: Out of 23 GEAR UP in-kind match items tested, supporting documentation was not located for one item and for another item, the support provided did not agree to the amount reported to Department of Education. Cause: Turnover in GEAR UP staffing. Effect: Record retention issue and inaccurate reporting of match. Identification as repeat finding, if applicable: N/A Recommendation: We recommend that the University keep their documents in a central location and verify in-kind match reported annually against supporting documentation. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
GEAR UP Program In-Kind Match Planned Corrective Action: The corrective action plan is to review In-Kind Match monthly, to ensure we there are no missing documentation & review for accuracy. Person Responsible for Corrective Action Plan: Shelley Belong Anticipated Date of Completion: December 1, 2023
2 students out of 28 were not properly awarded Pell based on the updated Pell tables. Criteria: 34 CFR 690.63 Questioned Costs: $0 Context: Two students were under awarded $600 of Pell Grant due to the client's system not updating Pell based in the updated Pell tables when they were released by the Department of Education. Cause: The system and Financial Aid staff did not update all Pell grants when new Pell tables were implemented. Effect: There was an incorrect amount of Pell Grant paid to these two students. Identification as repeat finding, if applicable: N/A Recommendation: We recommend a process be used to adjust Pell when updated Pell tables are released. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Incorrect Pell Calculations DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2022-2023 Award Year Condition: 2 students out of 28 were not properly awarded Pell based on the updated Pell tables. Criteria: 34 CFR 690.63 Questioned Costs: $0 Context: Two students were under awarded $600 of Pell Grant due to the client's system not updating Pell based in the updated Pell tables when they were released by the Department of Education. Cause: The system and Financial Aid staff did not update all Pell grants when new Pell tables were implemented. Effect: There was an incorrect amount of Pell Grant paid to these two students. Identification as repeat finding, if applicable: N/A Recommendation: We recommend a process be used to adjust Pell when updated Pell tables are released. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Inaccurate Pell Calculations Planned Corrective Action: The University recognized that this was an isolated concern based on the late notification from the Department of Education on Pell Grant Awards for the 2022-23 award year. System updates and 20 hours of system training have been scheduled and/or implemented to prevent this from reoccurring. Person Responsible for Corrective Action Plan: Shondra Dickson, Director of Financial Aid Anticipated Date of Completion: April 2024
FAC accepted this audit on January 30, 2023 — management decision was due July 30, 2023.
The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not documented its security assessment. Cause: COVID-19, turnover in staffing. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: 2021-002 Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster Federal Award Identification #: 2021-2022 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not documented its security assessment. Cause: COVID-19, turnover in staffing. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: 2021-002 Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act Compliance Planned Corrective Action: The Director of Information Technology is in the process of creating the necessary security policies to further Simpson University?s compliance of the consumer financial information rule of the Gramm-Leach-Bliley Act. Completion of this project has a planned finalization date of 6/1/2023. The following security measures have been implemented since the audit findings of 2021. -Established a Zero Trust access control strategy -Created an Incident Response Policy and Cyber Security Plan -IT and HR departments have developed training materials and schedules for all employees pertaining to cyber security policies -Deployed encryption at-rest and immutable backups -Enforced Multi-factor authentication -Installed next-generation endpoint protection software: Crowdstrike Falcon Complete -Drafted a Written Information Security Program (WISP) Person Responsible for Corrective Action Plan: Ryan Opfer, IT Director Anticipated Date of Completion: 4/30/2024
2021-002
The University did not post the required Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) reports to their website as required for institutional and student aid portions expended from the Coronavirus Aid, Relief and Economic Security Act (CARES), Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), and American Rescue Plan (ARP). The University also did not retain a copy of the 2nd annual report and supporting data so the accuracy of that report was not able to be tested. Criteria: 86 FR 262132, CFR 200.329 The University was required to post the Institutional Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Additionally, for each student grant disbursement made, the University is required to report quarterly to their website a summary of how the funds were allocated and disbursed. The University is also required to retain supporting documentation for all HEERF reports. Questioned Costs: None Context: During the audit, it was noted that the University had initially disclosed the required CARES Act reporting for the HEERF student emergency grants disbursed but made no further disclosure after December 2020. The CARES Act Institutional Quarterly Budget and Expenditure reports for March 31, 2021, and each subsequent quarter were not completed and posted to their website as required. Subsequent to year end and as part of the audit process, the University completed and posted the required reports to their website. For the 2nd annual report, the University has not yet been able to obtain a copy from the Department of Education as the portal is closed. Cause: Along with staffing challenges brought on by COVID, there were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements for HEERF reporting. Effect: The University was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: 2021-003 Recommendation: We recommend that the University complete the HEERF quarterly reporting until the HEERF funding is spent to ensure compliance is maintained. We also recommend that a copy of the annual reports be retained along with all supporting data used to compile the reports for record retention purposes. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Education Stabilization Fund Reporting Significant Deficiency DEPARTMENT OF EDUCATION ALN#: 84.425E and 84.425F Federal Award Identification #: P425E203311 and P425F203100 Condition: The University did not post the required Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) reports to their website as required for institutional and student aid portions expended from the Coronavirus Aid, Relief and Economic Security Act (CARES), Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), and American Rescue Plan (ARP). The University also did not retain a copy of the 2nd annual report and supporting data so the accuracy of that report was not able to be tested. Criteria: 86 FR 262132, CFR 200.329 The University was required to post the Institutional Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Additionally, for each student grant disbursement made, the University is required to report quarterly to their website a summary of how the funds were allocated and disbursed. The University is also required to retain supporting documentation for all HEERF reports. Questioned Costs: None Context: During the audit, it was noted that the University had initially disclosed the required CARES Act reporting for the HEERF student emergency grants disbursed but made no further disclosure after December 2020. The CARES Act Institutional Quarterly Budget and Expenditure reports for March 31, 2021, and each subsequent quarter were not completed and posted to their website as required. Subsequent to year end and as part of the audit process, the University completed and posted the required reports to their website. For the 2nd annual report, the University has not yet been able to obtain a copy from the Department of Education as the portal is closed. Cause: Along with staffing challenges brought on by COVID, there were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements for HEERF reporting. Effect: The University was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: 2021-003 Recommendation: We recommend that the University complete the HEERF quarterly reporting until the HEERF funding is spent to ensure compliance is maintained. We also recommend that a copy of the annual reports be retained along with all supporting data used to compile the reports for record retention purposes. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Education Stabilization Fund Reporting Planned Corrective Action: We are in process of updating the website. Person Responsible for Corrective Action Plan: Tim Dietz, CFO Anticipated Date of Completion: 4/30/2023
2021-003
The University did not use some institutional funds from the American Rescue Plan (ARP) HEERF allocation for conducting direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the HEA as required by the ARP. Criteria: ARP HEERF (a) (1) Institutional portion Questioned Costs: None Context: During the audit, it was noted that the University did not have evidence of using HEERF funds for direct outreach to financial aid applicants. Management indicated that an e-mail notification was provided to students but was unable to provide this as the employee responsible for this task is no longer employed by the University. Cause: Staffing challenges brought on by COVID. Effect: The University was not in compliance with the ARP earmarking requirements. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend that the University conduct the direct outreach to financial aid applicants or work with the IT department in obtaining the evidence that it was completed in fiscal year 2022. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Education Stabilization Fund-ARP Earmarking DEPARTMENT OF EDUCATION ALN#: 84.425F Federal Award Identification #: P425F203100 Condition: The University did not use some institutional funds from the American Rescue Plan (ARP) HEERF allocation for conducting direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the HEA as required by the ARP. Criteria: ARP HEERF (a) (1) Institutional portion Questioned Costs: None Context: During the audit, it was noted that the University did not have evidence of using HEERF funds for direct outreach to financial aid applicants. Management indicated that an e-mail notification was provided to students but was unable to provide this as the employee responsible for this task is no longer employed by the University. Cause: Staffing challenges brought on by COVID. Effect: The University was not in compliance with the ARP earmarking requirements. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend that the University conduct the direct outreach to financial aid applicants or work with the IT department in obtaining the evidence that it was completed in fiscal year 2022. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
ARP Earmarking Planned Corrective Action: The Office of Financial Aid called students and conducted in-person interviews as outreach to communicate the opportunity for an income adjustment professional judgement. However, we admittedly did not document the outreach in a manner that we can readily produce for audit purposes. Students were notated on a case-by-case basis. The employee leading these efforts is no longer employed by the University. The Office of Financial Aid will send out a new mass communication to all students to ensure students are still aware of the opportunity to submit a professional judgment based on COVID related income adjustments for FY23. Person Responsible for Corrective Action Plan: Shondra Dickson, Ryan Opfer Anticipated Date of Completion: 4/30/2023
FAC accepted this audit on July 11, 2022 — management decision was due January 11, 2023.
The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not documented its security assessment. Cause: COVID-19, turnover in staffing. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: 2020-004 Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.
Show full finding ▾Hide full finding ▴Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster Federal Award Identification #: 2020-2021 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not documented its security assessment. Cause: COVID-19, turnover in staffing. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: 2020-004 Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.
Finding Number: 2021-002 Gramm-Leach-Bliley Act Compliance Planned Corrective Action: The Director of Information Technology is in the process of creating the necessary security policies to further Simpson University?s compliance of the consumer financial information rule of the Gramm-Leach-Bliley Act. Completion of this project has a planned finalization date of 6/1/2023. The following security measures have been implemented since the audit findings of 2021. - Established a Zero Trust access control strategy - Created an Incident Response Policy and Cyber Security Plan - IT and HR departments have developed training materials and schedules for all employees pertaining to cyber security policies - Deployed encryption at-rest and immutable backups - Enforced Multi-factor authentication - Installed next-generation endpoint protection software: Crowdstrike Falcon Complete - Drafted a Written Information Security Program (WISP) Person Responsible for Corrective Action Plan: Ryan Opfer, IT Director Anticipated Date of Completion: 4/30/2024
2020-004
The University did not post the required Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) reports to their website as required for institutional and student aid portions expended from the Coronavirus Aid, Relief and Economic Security Act (CARES) and Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA). Criteria: 86 FR 262132, CFR 200.329 The University was required to post the Institutional Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Additionally, for each student grant disbursement made, the University is required to report quarterly to their website a summary of how the funds were allocated and disbursed. Questioned Costs: None Context: During the audit, it was noted that the University had initially disclosed the required CARES Act reporting for the HEERF student emergency grants disbursed but made no further disclosure after June 2020. The CARES Act Institutional Quarterly Budget and Expenditure reports for September 30, 2020, and each subsequent quarter were not completed and posted to their website as required. While subsequent to the fiscal year end, we noted that no reporting was completed for the CRRSAA emergency student grants and that only one Institutional Quarterly Budget and expenditure report was completed. The University is in the process of completing and posting the required reports to their website. Cause: Along with staffing challenges brought on by COVID, there were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements for HEERF reporting. Effect: The University was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend that the University complete the HEERF quarterly reporting until the HEERF funding is spent to ensure compliance is maintained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Education Stabilization Fund Reporting Other Matter DEPARTMENT OF EDUCATION ALN#: 84.425E, 84.425F and 84.425M Education Stabilization Fund Federal Award Identification #: P425E203311, P425F203100, and P425M201081 Condition: The University did not post the required Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) reports to their website as required for institutional and student aid portions expended from the Coronavirus Aid, Relief and Economic Security Act (CARES) and Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA). Criteria: 86 FR 262132, CFR 200.329 The University was required to post the Institutional Quarterly Report to their website within 10 days of the end of the quarter in which the funds were spent. Additionally, for each student grant disbursement made, the University is required to report quarterly to their website a summary of how the funds were allocated and disbursed. Questioned Costs: None Context: During the audit, it was noted that the University had initially disclosed the required CARES Act reporting for the HEERF student emergency grants disbursed but made no further disclosure after June 2020. The CARES Act Institutional Quarterly Budget and Expenditure reports for September 30, 2020, and each subsequent quarter were not completed and posted to their website as required. While subsequent to the fiscal year end, we noted that no reporting was completed for the CRRSAA emergency student grants and that only one Institutional Quarterly Budget and expenditure report was completed. The University is in the process of completing and posting the required reports to their website. Cause: Along with staffing challenges brought on by COVID, there were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements for HEERF reporting. Effect: The University was not in compliance with the reporting requirements of HEERF. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend that the University complete the HEERF quarterly reporting until the HEERF funding is spent to ensure compliance is maintained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding Number: 2021-002 Education Stabilization Fund Reporting Planned Corrective Action: We are in process of updating the website. Person Responsible for Corrective Action Plan: Tim Dietz, CFO Anticipated Date of Completion: 10/31/2022
FAC accepted this audit on March 23, 2021 — management decision was due September 23, 2021.
The University did not return the unearned funds within the 45 days from the determination of the student?s withdrawal. Criteria: 34 CFR 668.22 (j) and 34 CFR 668.173 (c) (1) Questioned Costs: $0 Context: Out of 4 R2T4?s tested for accuracy and timeliness, 2 students had $9,871 of unearned funds returned seven days late. Cause: Turnover in financial aid office and R2T4?s were not processed timely for the fall 2019 term. Effect: Title IV funds were not being returned timely in accordance with the regulations to the Department of Education when students withdraw. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend that the University process R2T4?s as soon as notified of a student?s withdrawal but no later than 45 days from the determination of the student?s withdrawal. Views of Officials and Planned Corrective Action: Management is in agreement with this finding. See attached corrective action plan.
Show full finding ▾Hide full finding ▴2020-003 Untimely Return of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION CFDA #: 84.033 Pell and 84.268 Federal Direct Loans Federal Award Identification: 2019-2020 Award Year Condition: The University did not return the unearned funds within the 45 days from the determination of the student?s withdrawal. Criteria: 34 CFR 668.22 (j) and 34 CFR 668.173 (c) (1) Questioned Costs: $0 Context: Out of 4 R2T4?s tested for accuracy and timeliness, 2 students had $9,871 of unearned funds returned seven days late. Cause: Turnover in financial aid office and R2T4?s were not processed timely for the fall 2019 term. Effect: Title IV funds were not being returned timely in accordance with the regulations to the Department of Education when students withdraw. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend that the University process R2T4?s as soon as notified of a student?s withdrawal but no later than 45 days from the determination of the student?s withdrawal. Views of Officials and Planned Corrective Action: Management is in agreement with this finding. See attached corrective action plan.
Finding Number: 2020-003 Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The University agrees with this finding. The University has initiated action to implement a process for the Office of Financial Aid to retrieve a daily report directly from the Registrar?s Office of students who are total withdrawals. The Office of Financial Aid has designated and trained two people to monitor this process and submit student data to DOE through COD in a timely manner. In addition, the Office of Financial Aid will hold regular trainings and reviews to ensure that staff and systems are complying with federal regulations. The Office of Financial Aid will continue to implement and strengthen procedures to ensure compliance going forward. Person Responsible for Corrective Action Plan: Shondra Dickson, Director Anticipated Date of Completion: 3/30/2021
The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not documented its security assessment. Cause: The University has not allocated sufficient resources to address the requirements of GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.
Show full finding ▾Hide full finding ▴2020-004 Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION CFDA #: 84.268, 84.063, 84.007, 84.033, and 84.038-Student Financial Assistance Cluster Federal Award Identification #: 2019-2020 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: The University has not documented its security assessment. Cause: The University has not allocated sufficient resources to address the requirements of GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management is in agreement with the finding and is in the process of addressing the issue. See attached corrective action plan.
Finding Number: 2020-004 Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The University agrees in part with this finding, but believes it is in compliance with the individual student security protocols. In preparation for this audit, it was discovered that there are staff members with system access that may or may not be a violation of applicable standards. The Registrar and the Director of Financial Aid are both working with IT to ensure access is properly assigned based on roles, responsibilities, and federal regulations. However, the University does require all staff and faculty to complete regular FERPA trainings. Person Responsible for Corrective Action Plan: David Guercia, Director of IT
The University was unable to provide the supporting documentation for the FISAP report covering the award year July 1, 2018 ? June 30, 2019 and application for award year July 1, 2020 ? June 30, 2021. Criteria: 34 CFR 668.24 Questioned Costs: $0 Context: Underlying documentation was not retrievable to verify the accuracy of the information reported, particularly for the income grids. Cause: Former employee completed the FISAP but supporting documentation used to compile the information reported could not be located. Effect: Non compliance with record retention requirements. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the University create a repository either electronically or in hard copy for the final submitted FISAP and all supporting documentation so that it is easily retrievable for review. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has addressed the issue. See corrective action plan.
Show full finding ▾Hide full finding ▴2020-005 Fiscal Operations Report and Application to Participate (FISAP) Reporting Significant Deficiency DEPARTMENT OF EDUCATION CFDA #: 84.007, 84.033 and 84.038 Federal Award Identification #: 2018-2019 Financial Aid Year Condition: The University was unable to provide the supporting documentation for the FISAP report covering the award year July 1, 2018 ? June 30, 2019 and application for award year July 1, 2020 ? June 30, 2021. Criteria: 34 CFR 668.24 Questioned Costs: $0 Context: Underlying documentation was not retrievable to verify the accuracy of the information reported, particularly for the income grids. Cause: Former employee completed the FISAP but supporting documentation used to compile the information reported could not be located. Effect: Non compliance with record retention requirements. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the University create a repository either electronically or in hard copy for the final submitted FISAP and all supporting documentation so that it is easily retrievable for review. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has addressed the issue. See corrective action plan.
Finding Number: 2020-005 FISAP Reporting Planned Corrective Action: The University agrees with this finding. The University recognizes that severe turnover in the Office of Financial Aid caused the loss of critical data. The Office of Financial Aid recognizes the need to strengthen its procedures over the preparation of the FISAP report to ensure supporting documentation is properly maintained in a shared drive/folder for any staff within the office to access data. Person Responsible for Corrective Action Plan: Shondra Dickson, Director of Financial Aid Anticipated Date of Completion: 3/30/21
FAC accepted this audit on March 10, 2020 — management decision was due September 10, 2020.
MATERIAL WEAKNESS ? INTERNAL CONTROL OVER COMPLIANCE Notification to Student of Direct Loan Award Criteria or Specific Requirement The Student Financial Assistance Cluster (SFA) of the Uniform Guidance, (under special tests and provisions as it relates to disbursements to or on behalf of students), requires for direct loans that the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR section 668.165). Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan, FPL funds, or TEACH Grants. Institutions that do not implement an affirmative confirmation process must notify a student no earlier than 30 days before, but no later than seven days after, crediting the student?s account and must give the student 30 days (instead of 14) to cancel all or part of the loan. Condition For twelve students out of the forty that we tested, we were unable to observe the email notifications that were sent out within 30 days prior to the credit to the students account. Questioned Costs For the twelve students identified as an error in our sample, the amount of questioned costs were $43,873. The errors appear to be limited to the month of January 2019. Total loan disbursements for that month were $811,037 and therefore this is the total potential amount of questioned costs. Effect The University could not prove that the specific requirement noted above was met. Cause Lack of following current processes and procedures. Recommendation The University should develop and implement procedures to ensure adherence to the compliance requirements noted above. In addition, the University should retain documentation for auditors and regulatory agencies to prove compliance.
Show full finding ▾Hide full finding ▴MATERIAL WEAKNESS ? INTERNAL CONTROL OVER COMPLIANCE Notification to Student of Direct Loan Award Criteria or Specific Requirement The Student Financial Assistance Cluster (SFA) of the Uniform Guidance, (under special tests and provisions as it relates to disbursements to or on behalf of students), requires for direct loans that the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR section 668.165). Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan, FPL funds, or TEACH Grants. Institutions that do not implement an affirmative confirmation process must notify a student no earlier than 30 days before, but no later than seven days after, crediting the student?s account and must give the student 30 days (instead of 14) to cancel all or part of the loan. Condition For twelve students out of the forty that we tested, we were unable to observe the email notifications that were sent out within 30 days prior to the credit to the students account. Questioned Costs For the twelve students identified as an error in our sample, the amount of questioned costs were $43,873. The errors appear to be limited to the month of January 2019. Total loan disbursements for that month were $811,037 and therefore this is the total potential amount of questioned costs. Effect The University could not prove that the specific requirement noted above was met. Cause Lack of following current processes and procedures. Recommendation The University should develop and implement procedures to ensure adherence to the compliance requirements noted above. In addition, the University should retain documentation for auditors and regulatory agencies to prove compliance.
The University agrees with this finding. The University has initiated action to implement a delivered process within the system to properly notify students of their Direct Loan award prior to disbursement. Right away, when discovering the process was not addressed, the University made an immediate change in personnel. In addition, the Office of Financial Aid will hold regular trainings and reviews, to ensure that staff and systems are complying with federal regulations. The Office of Financial Aid will continue to implement and strengthen procedures to ensure compliance going forward.
2018-001
FAC accepted this audit on October 29, 2018 — management decision was due April 29, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on September 18, 2017 — management decision was due March 18, 2018.
FAC accepted this audit on September 8, 2016 — management decision was due March 8, 2017.
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