EIN: 951644026
UEI: KGP6EXJ2DEM1
Audited by: Baker Tilly US, LLP
Cognizant agency: 84 [Department of Education]
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Data as of September 7, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 26, 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 26, 2026 (18 days from today).
What is a management decision? →Special Tests and Provisions – Return of Title IV Funds: Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance (See table in "Schedule of Findings and Questioned Costs"). Criteria – When a recipient of Title IV grant or loan assistance withdraws from the University during a payment period or period of enrollment in which the recipient began attendance, the University must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. The regulations (34 CFR 668.22(j)(1)) provide that an institution must return the amount of title IV funds for which it is responsible under this paragraph (34 CFR 668.22(a)(6)(ii)(B)(1)) as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. In addition, the University is required to maintain internal controls to ensure that the calculation of all returns are complete and accurate which includes documentation of reviews and approvals when completed by an individual other than who prepared them. Condition/Context – We selected a sample of 20 students out of a population of 109 that were identified by the University as having received some federal assistance and withdrew from the University during the year under audit. We believe this to be a representative sample of the population; however, it was not a statistical sample. Effect – We found exception with one student whose title IV funds were returned 48 days after it was determined that the student had withdrawn. We also could not observe retained evidence that any of the calculations were reviewed and approved by an individual other than who prepared them. Cause – The FY2024 Corrective Action Plan (CAP) was approved in November 2024, near the end of the Fall 2024 term, with a projected completion date of December 2024. The associated finding pertains to Fall 2024 unofficial withdrawals and was identified through a report developed by the Registrar’s Office in response to this CAP. Development of the report could not begin until after November 2024 and required at least two months to complete to ensure accuracy of data output. Consequently, processing for this student was delayed, as completion of the report took longer than initially anticipated. Additionally, management’s current procedures do not require retention of documentation to support reviews and approvals of R2T4 calculations. Questioned Costs – None. Repeat Finding – This is a repeat finding, see 2024-001. Recommendation – We recommend the University’s management update the internal control procedures in place to process R2T4 returns in a timely manner and ensure that documentation is retained for evidence that the calculations were reviewed and approved by someone other than who prepared them to ensure the completeness and accuracy of the calculations. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the finding. See the corrective action plan for further detail.
Show full finding ▾Hide full finding ▴Special Tests and Provisions – Return of Title IV Funds: Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance (See table in "Schedule of Findings and Questioned Costs"). Criteria – When a recipient of Title IV grant or loan assistance withdraws from the University during a payment period or period of enrollment in which the recipient began attendance, the University must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. The regulations (34 CFR 668.22(j)(1)) provide that an institution must return the amount of title IV funds for which it is responsible under this paragraph (34 CFR 668.22(a)(6)(ii)(B)(1)) as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. In addition, the University is required to maintain internal controls to ensure that the calculation of all returns are complete and accurate which includes documentation of reviews and approvals when completed by an individual other than who prepared them. Condition/Context – We selected a sample of 20 students out of a population of 109 that were identified by the University as having received some federal assistance and withdrew from the University during the year under audit. We believe this to be a representative sample of the population; however, it was not a statistical sample. Effect – We found exception with one student whose title IV funds were returned 48 days after it was determined that the student had withdrawn. We also could not observe retained evidence that any of the calculations were reviewed and approved by an individual other than who prepared them. Cause – The FY2024 Corrective Action Plan (CAP) was approved in November 2024, near the end of the Fall 2024 term, with a projected completion date of December 2024. The associated finding pertains to Fall 2024 unofficial withdrawals and was identified through a report developed by the Registrar’s Office in response to this CAP. Development of the report could not begin until after November 2024 and required at least two months to complete to ensure accuracy of data output. Consequently, processing for this student was delayed, as completion of the report took longer than initially anticipated. Additionally, management’s current procedures do not require retention of documentation to support reviews and approvals of R2T4 calculations. Questioned Costs – None. Repeat Finding – This is a repeat finding, see 2024-001. Recommendation – We recommend the University’s management update the internal control procedures in place to process R2T4 returns in a timely manner and ensure that documentation is retained for evidence that the calculations were reviewed and approved by someone other than who prepared them to ensure the completeness and accuracy of the calculations. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the finding. See the corrective action plan for further detail.
FINDING 2025-001 – Special Tests and Provisions – Return of Title IV Funds: Significant Deficiency in Internal Control over Compliance; (See table in "Management's Corrective Action Plan"); Condition/Context – Auditors selected a sample of 20 students out of a population of 109 that were identified by the University as having received some federal assistance and withdrew from the University during the year under audit. Auditors believed this to be a representative sample of the population; however, it was not a statistical sample. Corrective Action Plan: The finding has been addressed through the implementation of our FY2024 Corrective Action Plan. The Office of Financial Aid has collaborated with the University Registrar to develop a comprehensive report identifying non-completed courses inclusive of all grade codes. This report is reviewed on the day following faculty submission of final grades for both semester and modular terms. Students subject to R2T4 processing are identified by the Associate Director of Compliance & Special Programs and subsequently assigned to a team of three Program Managers for COD processing. Timely review of this report ensures that all required funds are returned within the 45-day regulatory timeframe. Internal controls have been revised to include a secondary review of all processed R2T4’s. Additionally, an internal control document will be established to demonstrate that R2T4 calculations were reviewed for accuracy and completeness. Name of Contact Person: Laura Evans, Director of Financial Aid at levans2@laverne.edu Projected Completion Date: This was corrected as of March 22, 2026
2024-001
FINDING 2025-002 – Cash Management: Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance (See table in "Schedule of Findings and Questioned Costs". Criteria –34 CFR 668.166 (a), Excess Cash: a) General. The Secretary considers excess cash to be any amount of title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students by the end of the third business day following the date the institution— 1. Received those funds from the Secretary; or 2. Deposited or transferred to its depository account previously disbursed title IV, HEA program funds, such as those resulting from award adjustments, recoveries, or cancellations. The Department of Education allows an institution to retain, for up to seven days, excess cash that does not exceed one percent of the total amount of funds drawn by the institution in the prior award year. The institution must return to the Department of education any excess cash over the tolerable amount (one percent) and any amount remaining after the tolerance period (seven days). Questioned costs would be those in excess of the one percent threshold. Condition/Context – The University made 48 draws for various student financial assistance cluster programs. We selected a sample of 7 and believe this to be a representative sample; however, it was not a statistical sample. Effect – We noted one instance in which the University made an advance drawdown of $10,662,472 that was not disbursed to students until 18 days after receiving the cash drawdown. This drawdown exceeded 1% of total drawdowns from funding in the prior fiscal year and was retained for more than the tolerance period described in the criteria above. We noted the University calculated interest on the days outstanding and applied the interest to the program. Cause – The excess drawdown occurred due to a conservative approach taken by the University to ensure sufficient funds were available to cover anticipated February 2025 disbursements, which resulted in an advance drawdown being requested in January 2025 prior to the related disbursements. Questioned Costs – Advance drawdowns totaling $9,872,238 exceeded one percent of prior-year drawdowns that were held beyond the seven day tolerance period before disbursement to students. Repeat Finding – Not a repeat finding. Recommendation – We recommend that the University’s management continue to adhere to its established internal control procedures requiring that any excess advance drawdowns be processed within three business days. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the finding. See the corrective action plan for further detail.
Show full finding ▾Hide full finding ▴FINDING 2025-002 – Cash Management: Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance (See table in "Schedule of Findings and Questioned Costs". Criteria –34 CFR 668.166 (a), Excess Cash: a) General. The Secretary considers excess cash to be any amount of title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students by the end of the third business day following the date the institution— 1. Received those funds from the Secretary; or 2. Deposited or transferred to its depository account previously disbursed title IV, HEA program funds, such as those resulting from award adjustments, recoveries, or cancellations. The Department of Education allows an institution to retain, for up to seven days, excess cash that does not exceed one percent of the total amount of funds drawn by the institution in the prior award year. The institution must return to the Department of education any excess cash over the tolerable amount (one percent) and any amount remaining after the tolerance period (seven days). Questioned costs would be those in excess of the one percent threshold. Condition/Context – The University made 48 draws for various student financial assistance cluster programs. We selected a sample of 7 and believe this to be a representative sample; however, it was not a statistical sample. Effect – We noted one instance in which the University made an advance drawdown of $10,662,472 that was not disbursed to students until 18 days after receiving the cash drawdown. This drawdown exceeded 1% of total drawdowns from funding in the prior fiscal year and was retained for more than the tolerance period described in the criteria above. We noted the University calculated interest on the days outstanding and applied the interest to the program. Cause – The excess drawdown occurred due to a conservative approach taken by the University to ensure sufficient funds were available to cover anticipated February 2025 disbursements, which resulted in an advance drawdown being requested in January 2025 prior to the related disbursements. Questioned Costs – Advance drawdowns totaling $9,872,238 exceeded one percent of prior-year drawdowns that were held beyond the seven day tolerance period before disbursement to students. Repeat Finding – Not a repeat finding. Recommendation – We recommend that the University’s management continue to adhere to its established internal control procedures requiring that any excess advance drawdowns be processed within three business days. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the finding. See the corrective action plan for further detail.
FINDING 2025-002 – Special Tests and Provisions – Cash Management: Significant Deficiency in Internal Control over Compliance (See table in "Management's Corrective Action Plan"). Condition/Context – The University made 48 draws for various student financial assistance cluster programs. Auditors selected a sample of 7 and believe this to be a representative sample; however, it was not a statistical sample; Corrective Action Plan: This was done due to the perceived understanding that the new Federal Administration indicated that all grants were at risk of being cancelled and that the G5 website would go dark. Due to the unique nature of the Federal Administration’s perceived announcement, the University would not handle this in the same manner, in the future. If for some reason they were to cancel any future grants, the University would endure the cancellation and close out the grant in the usual process, which is by reimbursement only. Name of Contact Person: Lori Gordien Case, Associate Vice President of Finance and Controller at lgordien@laverne.edu Projected Completion Date: This was corrected as of March 31, 2025.
Finding 2025-003 – Special Test and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance (See table in "Schedule of Findings and Questioned Costs"). Criteria – 34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/Context – Out of a population of approximately 1,000 student status changes and 230 permanent address changes, a sample of 74 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2024-2025 academic year. We believe this to be a representative sample although not a statistical sample. The enrollment information and withdrawal, address change, or graduation date per the University’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Questioned Costs – None. Effect – Although the University generally reported enrollment status changes to NSLDS accurately, it did not fully comply with timeliness requirements for two batches of students that graduated in May and June 2025, which were reported 30 days and 4 days, respectively beyond the 60-day requirement noted in the criteria above. In addition, we noted four other withdrawn students whose status change was not reported timely. Cause – The cause was due to no internal controls in place to report enrollment status changes within a timely manner, no internal controls related to review of effective dates, and unofficially withdrawn students Repeat Finding – Not a repeat finding. Recommendation – We recommend the University to establish a formal policy requiring a review of student status information submitted to the NSLDS, by a third-party intermediary on the University’s behalf, for completeness and accuracy. We also recommend the University establish a cadence of monitoring reporting deadlines, particularly those around classes of graduating students. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the finding. See the corrective action plan for further detail.
Show full finding ▾Hide full finding ▴Finding 2025-003 – Special Test and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance (See table in "Schedule of Findings and Questioned Costs"). Criteria – 34 CFR section 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition/Context – Out of a population of approximately 1,000 student status changes and 230 permanent address changes, a sample of 74 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2024-2025 academic year. We believe this to be a representative sample although not a statistical sample. The enrollment information and withdrawal, address change, or graduation date per the University’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Questioned Costs – None. Effect – Although the University generally reported enrollment status changes to NSLDS accurately, it did not fully comply with timeliness requirements for two batches of students that graduated in May and June 2025, which were reported 30 days and 4 days, respectively beyond the 60-day requirement noted in the criteria above. In addition, we noted four other withdrawn students whose status change was not reported timely. Cause – The cause was due to no internal controls in place to report enrollment status changes within a timely manner, no internal controls related to review of effective dates, and unofficially withdrawn students Repeat Finding – Not a repeat finding. Recommendation – We recommend the University to establish a formal policy requiring a review of student status information submitted to the NSLDS, by a third-party intermediary on the University’s behalf, for completeness and accuracy. We also recommend the University establish a cadence of monitoring reporting deadlines, particularly those around classes of graduating students. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the finding. See the corrective action plan for further detail.
Finding 2025-003 – Special Test and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance (See table in Management's Corrective Action Plan"). Condition/Context – Out of a population of approximately 1,000 student status changes and 230 permanent address changes, a sample of 74 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2024-2025 academic year. Auditors believe this to be a representative sample although not a statistical sample. The enrollment information and withdrawal, address change, or graduation date per the University’s records was compared to the information reported to the National Student Loan Data System (NSLDS) in order to determine if status changes were reported within the required timeframes. Corrective Action Plan: The finding has been addressed through staffing changes and scheduled reporting which took effect January 2026. The office of the University Registrar did not previously have a dedicated staff member to submit reports in a timely manner. With the departure of the Associate Registrar in April 2025, the task fell to several staff members to share the responsibility along with their other tasks. The office currently has an assistant registrar as well as a transcript evaluator who share the responsibility and submit reports once every 30 days, with the exception of winter reporting, which is on a different schedule due to breaks. Internal controls have been revised to check conferral dates prior to submitting the enrollment report for the Main Campus. Name of Contact Person: Julie Khella, University Registrar at jkhella@laverne.edu Projected Completion Date: This was corrected as of March 22, 2026
FAC accepted this audit on March 26, 2025 — management decision was due September 26, 2025.
Finding #: 2024-001 Student Financial Assistance Cluster (Various Assistance Listing Numbers) Award year ended June 30, 2024 Federal Agency: U.S. Department of Education Type of Finding: Special Tests and Provisions - Return of Title IV Funds Noncompliance and Internal Control over Compliance (Material Weakness) Criteria: Pursuant to the 34 CFR 668.22(j)(2), an institution is required to determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew to allow for the timely calculation and return of Title IV funds as required. Pursuant to the 34 CFR 668.22(e), an institution is required to calculate the amount of Title IV assistance earned by the student once the institution has determined the withdrawal date in accordance with the 34 CFR 668.22(j), and pursuant to the 34 CFR 668.22(g), an institution is required to calculate and return unearned aid in the order as required: the lesser of the total amount of unearned Title IV assistance to be returned as calculated under 34 CFR 668.22(e)(4); or an amount equal to the total institutional charges incurred by the student for the payment period or period of enrollment multiplied by the percentage of Title IV grant or loan assistance that has not been earned by the student, as described in 34 CFR 668.22(e)(3). Pursuant to the 34 CFR 690.83(b)(2) an institution shall submit, in accordance with deadline dates established by the U.S. Department of Education (Secretary), through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Pursuant to 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as, but no later than 45 days, after the date of the institution's determination that the student withdrew. Condition/Context: During our testing at the University, we noted one instance out of 12 students tested in which the University did not complete the return of Title IV funds as calculated within the 45-day requirement as noted in the Federal Regulations. Effect The University was not compliant with the timeliness rules for one student in our sample. Cause The cause of the delay in performing the return was due to the substantial irregularity in the manner in which a member of the faculty updated the student’s record. The student was not reported as having exited by the faculty when the exit took place, but instead the faculty gave her a grade that reflects a withdrawal took place instead of grading with an expected FW/F/NC. As such, the student’s record fell outside the University’s discovery range for identifying unofficial withdrawals. Questioned Costs: None noted. Identification as a Repeat Finding: This is not a repeat finding. Recommendation We recommend the University’s management update the internal control procedures in place to identify student’s that have withdrawn without providing notification. Views of Responsible Officials: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Finding #: 2024-001 Student Financial Assistance Cluster (Various Assistance Listing Numbers) Award year ended June 30, 2024 Federal Agency: U.S. Department of Education Type of Finding: Special Tests and Provisions - Return of Title IV Funds Noncompliance and Internal Control over Compliance (Material Weakness) Criteria: Pursuant to the 34 CFR 668.22(j)(2), an institution is required to determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew to allow for the timely calculation and return of Title IV funds as required. Pursuant to the 34 CFR 668.22(e), an institution is required to calculate the amount of Title IV assistance earned by the student once the institution has determined the withdrawal date in accordance with the 34 CFR 668.22(j), and pursuant to the 34 CFR 668.22(g), an institution is required to calculate and return unearned aid in the order as required: the lesser of the total amount of unearned Title IV assistance to be returned as calculated under 34 CFR 668.22(e)(4); or an amount equal to the total institutional charges incurred by the student for the payment period or period of enrollment multiplied by the percentage of Title IV grant or loan assistance that has not been earned by the student, as described in 34 CFR 668.22(e)(3). Pursuant to the 34 CFR 690.83(b)(2) an institution shall submit, in accordance with deadline dates established by the U.S. Department of Education (Secretary), through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Pursuant to 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as, but no later than 45 days, after the date of the institution's determination that the student withdrew. Condition/Context: During our testing at the University, we noted one instance out of 12 students tested in which the University did not complete the return of Title IV funds as calculated within the 45-day requirement as noted in the Federal Regulations. Effect The University was not compliant with the timeliness rules for one student in our sample. Cause The cause of the delay in performing the return was due to the substantial irregularity in the manner in which a member of the faculty updated the student’s record. The student was not reported as having exited by the faculty when the exit took place, but instead the faculty gave her a grade that reflects a withdrawal took place instead of grading with an expected FW/F/NC. As such, the student’s record fell outside the University’s discovery range for identifying unofficial withdrawals. Questioned Costs: None noted. Identification as a Repeat Finding: This is not a repeat finding. Recommendation We recommend the University’s management update the internal control procedures in place to identify student’s that have withdrawn without providing notification. Views of Responsible Officials: Management agrees with the finding.
Finding #: 2024-001 – Special Tests and Provisions – Return of Title IV Funds Description of Finding: One record from the return to Title IV sampling of 12 students tested, had funds returned beyond the required timeline for an unofficial withdrawal. The record received a non-completed course grade for the fall 2023 term, but the return of funds based on the unofficial withdrawal was not performed until July 2024. The cause of the delayed return was the irregular non-completed course grade that was applied by faculty. The grade type was not incorporated into control measures for prompt identification. The University of La Verne concurs with this finding. Corrective Action: The reporting criteria used to identify non-completed courses are being modified to include all grade codes that meet the non-completed criteria, regardless of their appropriateness to the enrollment type. This revision is to ensure that any irregular grade reporting would still be captured. Secondly, all staff who perform return to Title IV calculations are expected to complete the Federal Student Aid training modules on return to Title IV funds to reinforce the staff knowledge base. Lastly, with the recent onboarding of a Financial Aid Compliance Manager, additional quality assurance steps are being added to include random sampling and secondary review of return to Title IV records for accuracy and timeliness. The responsible party is Laura Evans at levans2@laverne.edu. This will be completed by December 2024.
FAC accepted this audit on March 22, 2024 — management decision was due September 22, 2024.
FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.
Finding #: 2022-001 Funding Year(s): 7/1/2021 ? 6/30/2022 Federal Direct Student Loan (FAL #84.268) Award Numbers: Various Federal Agency: U.S. Department of Education Type of Finding: Special Test ? Enrollment Reporting ? Compliance and Internal Control (Significant Deficiency) Criteria: Institutions are required to report enrollment information under the Pell grant and Direct and FFEL loan programs via the NSLDS (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access website. Institutions must complete and return within 15 days the Enrollment Reporting Roster File, within a minimum of every 60 days. If errors are identified by NSLDS in the submitted roster, an Error/Acknowledgement file is provided to the institution and the institution has 10 days to correct the errors and resubmit to NSLDS. Condition/Context: From a non-statistical sample of forty (40) students for which enrollment changes were reported to NSLDS, we identified one (1) instance where the student information was rejected, and for which a correction was not made within the required 10 days. Cause/Effect: Based on discussions with personnel, the above occurred due to significant turnover at the University within the Financial Aid department, including the individual with primary responsibility for NSLDS reporting. Without proper transfer of knowledge to the new Financial Aid personnel, previous processed and controls were not followed to ensure timely updated of rejected student information. Questioned Costs: None noted. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the University?s management update the internal control procedures in place surrounding enrollment reporting, including the correction of data rejected by NSLDS. Views of Responsible Official: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Finding #: 2022-001 Funding Year(s): 7/1/2021 ? 6/30/2022 Federal Direct Student Loan (FAL #84.268) Award Numbers: Various Federal Agency: U.S. Department of Education Type of Finding: Special Test ? Enrollment Reporting ? Compliance and Internal Control (Significant Deficiency) Criteria: Institutions are required to report enrollment information under the Pell grant and Direct and FFEL loan programs via the NSLDS (OMB No. 1845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access website. Institutions must complete and return within 15 days the Enrollment Reporting Roster File, within a minimum of every 60 days. If errors are identified by NSLDS in the submitted roster, an Error/Acknowledgement file is provided to the institution and the institution has 10 days to correct the errors and resubmit to NSLDS. Condition/Context: From a non-statistical sample of forty (40) students for which enrollment changes were reported to NSLDS, we identified one (1) instance where the student information was rejected, and for which a correction was not made within the required 10 days. Cause/Effect: Based on discussions with personnel, the above occurred due to significant turnover at the University within the Financial Aid department, including the individual with primary responsibility for NSLDS reporting. Without proper transfer of knowledge to the new Financial Aid personnel, previous processed and controls were not followed to ensure timely updated of rejected student information. Questioned Costs: None noted. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the University?s management update the internal control procedures in place surrounding enrollment reporting, including the correction of data rejected by NSLDS. Views of Responsible Official: Management agrees with the finding.
Description of Finding: There was a sample of forty (40) students for which enrollment changes were reported to NSLDS. There was one (1) instance where the student information was rejected, and for which a correction was not made within the required 10 days. Corrective Action Plan: Uploads to the National Student Clearinghouse are now reviewed through a report which performs a pre-check for common errors in an effort to reduce the number of enrollment errors overall. The reject reports are monitored with every upload and are managed using the outlined best practices from the National Student Clearinghouse directly. The reject reports are managed within 10 days of receipt with any changes captured within the same timeframe. The responsible parties are Adam Evans at aevans@laverne.edu. This will be corrected by July 1, 2023.
Finding #: 2022-002 Funding Year(s): 7/1/2021 ? 6/30/2022 Education Stabilization Fund (ESF) (FAL #84.425L, 84,425F, 84,825E) Award Numbers: P425L200075-20C; P425F201063-20B; P425E200786-20B Federal Agency: U.S. Department of Education Type of Finding: Procurement - Internal Control (Material Weakness) Criteria: In accordance with 2 CFR section 200.318, the entity must establish policies for procurement of equipment, real property and other services funded by federal funds. The procurement records and files for purchases in excess of the micro purchase threshold shall include at the minimum the following items: the basis for contractor selection, justification for lack of competition when competitive bids are not obtained, and basis for award cost or price. In addition, award recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. To ensure this is done, recipients should utilize the Excluded Parties List System website. Condition/Context: From a non-statistical sample of two (2) vendors subjected to testing, we determined that rate quotations and rationale for limited competition were not retained for either vendor. It was also determined that there was no documentation retained regarding verification of vendor suspension or debarment for either vendor. Cause/Effect: Per discussion with Management, the entity has the processes designed via the Policies and Procedures provided, however, there is not a formal process established to document the performance of such controls. We note that inadequate controls could result in a reasonable possibility that the entity would not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None noted. Identification as a Repeat Finding: Repeat finding. See prior year finding 2021-002. Recommendation: We recommend implementing a system of review and approval controls to complement the design of processes over the procurement, suspension, and debarment compliance requirements. In addition, we recommend that the University retain documentation regarding procurement decisions including rate quotations and verification of vendor suspension and debarment checks. Views of Responsible Official: Management agrees with finding.
Show full finding ▾Hide full finding ▴Finding #: 2022-002 Funding Year(s): 7/1/2021 ? 6/30/2022 Education Stabilization Fund (ESF) (FAL #84.425L, 84,425F, 84,825E) Award Numbers: P425L200075-20C; P425F201063-20B; P425E200786-20B Federal Agency: U.S. Department of Education Type of Finding: Procurement - Internal Control (Material Weakness) Criteria: In accordance with 2 CFR section 200.318, the entity must establish policies for procurement of equipment, real property and other services funded by federal funds. The procurement records and files for purchases in excess of the micro purchase threshold shall include at the minimum the following items: the basis for contractor selection, justification for lack of competition when competitive bids are not obtained, and basis for award cost or price. In addition, award recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. To ensure this is done, recipients should utilize the Excluded Parties List System website. Condition/Context: From a non-statistical sample of two (2) vendors subjected to testing, we determined that rate quotations and rationale for limited competition were not retained for either vendor. It was also determined that there was no documentation retained regarding verification of vendor suspension or debarment for either vendor. Cause/Effect: Per discussion with Management, the entity has the processes designed via the Policies and Procedures provided, however, there is not a formal process established to document the performance of such controls. We note that inadequate controls could result in a reasonable possibility that the entity would not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None noted. Identification as a Repeat Finding: Repeat finding. See prior year finding 2021-002. Recommendation: We recommend implementing a system of review and approval controls to complement the design of processes over the procurement, suspension, and debarment compliance requirements. In addition, we recommend that the University retain documentation regarding procurement decisions including rate quotations and verification of vendor suspension and debarment checks. Views of Responsible Official: Management agrees with finding.
Description of Finding: There were two vendors that did not have the documentation to substantiate the use of the vendors, or the necessary pricing quotations. Corrective Action Plan: In the case of these two vendors, there were items ordered directly by a University department. These vendors were familiar vendors in the work of the department, so the standard vetting and documentation by the Purchasing department was not performed and documented. To correct this, all new vendors for purposes of Federal Awards will not be added into the system until reviewed and approved by the Purchasing department. The responsible parties are Lori Gordien Case at lgordien@laverne.edu, Xochitl Martinez-Eckel at xmartinez@laverne.edu, and Debbie Deacy at ddeacy@laverne.edu . This was corrected in November 2022.
2021-002
Finding #: 2022-003 Funding Year(s): 7/1/2021 ? 6/30/2022 Education Stabilization Fund (ESF) (FAL #84.425L, 84,425F, 84,825E) Award Numbers: P425L200075-20C; P425F201063-20B; P425E200786-20B Federal Agency: U.S. Department of Education Type of Finding: Reporting - Internal Control (Material Weakness) Criteria: In accordance with 2 CFR sections 200.328 and 200.329, there are three components to reporting for HEERF: 1) public reporting on the Student Aid Portion; 2) public reporting on the Institutional Portion and subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. A complete system of internal controls requires all expenditures be properly approved and supported by appropriate documentation. Condition/Context: From a non-statistical sample of two (2) reports subject to testing, we identified two (2) instances where the report tested lacked evidence of review in accordance with the University?s control policies. Cause/Effect: Based on discussions with Management, the above occurred due to efforts made to abide by the 10-day time period between quarter-end and the reporting deadline. Due to the short time period, the review and approval process is rushed, and the necessary review took place during tele-conference and the CFO provided approval over the phone to get the report posted accordingly. Questioned Costs: None noted. Identification as a Repeat Finding: Repeat finding. See prior year finding 2021-003. Recommendation: We recommend the University?s Management routinely review and consider modifications that would strengthen the internal controls surrounding reporting specifically as it relates to documenting approval of reports. Views of Responsible Official: Management agrees with finding.
Show full finding ▾Hide full finding ▴Finding #: 2022-003 Funding Year(s): 7/1/2021 ? 6/30/2022 Education Stabilization Fund (ESF) (FAL #84.425L, 84,425F, 84,825E) Award Numbers: P425L200075-20C; P425F201063-20B; P425E200786-20B Federal Agency: U.S. Department of Education Type of Finding: Reporting - Internal Control (Material Weakness) Criteria: In accordance with 2 CFR sections 200.328 and 200.329, there are three components to reporting for HEERF: 1) public reporting on the Student Aid Portion; 2) public reporting on the Institutional Portion and subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. A complete system of internal controls requires all expenditures be properly approved and supported by appropriate documentation. Condition/Context: From a non-statistical sample of two (2) reports subject to testing, we identified two (2) instances where the report tested lacked evidence of review in accordance with the University?s control policies. Cause/Effect: Based on discussions with Management, the above occurred due to efforts made to abide by the 10-day time period between quarter-end and the reporting deadline. Due to the short time period, the review and approval process is rushed, and the necessary review took place during tele-conference and the CFO provided approval over the phone to get the report posted accordingly. Questioned Costs: None noted. Identification as a Repeat Finding: Repeat finding. See prior year finding 2021-003. Recommendation: We recommend the University?s Management routinely review and consider modifications that would strengthen the internal controls surrounding reporting specifically as it relates to documenting approval of reports. Views of Responsible Official: Management agrees with finding.
Description of Finding: The quarterly reports for purposes of reporting use of HEERF funds for the public reporting of both the Student Aid Portion, and the Institutional Portions did not have documented evidence of review and approval of the Chief Financial Officer prior to the posting to the website, and sending to the Program Director of the HEERF funds. Corrective Action Plan: The quarterly information for both the Student Aid Portion and the Institutional Portion will continued to be reviewed by the Finance Office management team prior to reporting. In addition, it will be required that the information and the quarterly and annual reports will have documented evidence of review and approval by the Chief Financial Officer prior to posting of the reports to the website or submitting to the Program Director of the HEERF funds. The responsible parties are Lori Gordien Case at lgordien@laverne.edu , Xochitl Martinez-Eckel at xmartinez@laverne.edu, and Avo Kechichian at akechichian2@laverne.edu . This was corrected by October 2022.
2021-003
FAC accepted this audit on September 29, 2022 — management decision was due March 29, 2023.
Criteria: In accordance with 23 CFR sections 1.9, 172.11(a), 420.113(a), and 630.106(a), costs incurred under federal awards are considered allowable and reimbursable when such costs are deemed necessary and reasonable; incurred subsequent to the date of authorization to proceed and in accordance with the conditions contained in the project agreement and the plans specifications; and, not included as costs used to meet cost sharing or matching requirements, among other things. A complete system of internal controls requires all expenditures be properly approved and supported by appropriate documentation. Condition/Context: The following internal control issues were noted during testing: ? Education Stabilization Fund o From a non-statistical sample of forty (40) expenditures subject to testing, we identified six (6) instances where the expenditure tested lacked evidence of review in accordance with the University?s control policies. ? Higher Education Institutional Aid o From a non-statistical sample of forty (40) expenditures subject to testing, we identified two (2) instances where the expenditure tested lacked evidence of review in accordance with the University?s control policies. Cause/Effect: Based on discussions with personnel, the above occurred due to significant turnover at the University in addition to changes in controls due to the COVID pandemic. Without proper approval procedures in place unallowable expenses may be paid and charged to the federal program or charged at the wrong amount. Questioned Costs: None noted. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the University?s management follow the internal control procedures in place surrounding allowable costs specifically as it relates to documenting approval of expenditures. Views of Responsible Official: Management agrees with the finding.
Show full finding ▾Hide full finding ▴Criteria: In accordance with 23 CFR sections 1.9, 172.11(a), 420.113(a), and 630.106(a), costs incurred under federal awards are considered allowable and reimbursable when such costs are deemed necessary and reasonable; incurred subsequent to the date of authorization to proceed and in accordance with the conditions contained in the project agreement and the plans specifications; and, not included as costs used to meet cost sharing or matching requirements, among other things. A complete system of internal controls requires all expenditures be properly approved and supported by appropriate documentation. Condition/Context: The following internal control issues were noted during testing: ? Education Stabilization Fund o From a non-statistical sample of forty (40) expenditures subject to testing, we identified six (6) instances where the expenditure tested lacked evidence of review in accordance with the University?s control policies. ? Higher Education Institutional Aid o From a non-statistical sample of forty (40) expenditures subject to testing, we identified two (2) instances where the expenditure tested lacked evidence of review in accordance with the University?s control policies. Cause/Effect: Based on discussions with personnel, the above occurred due to significant turnover at the University in addition to changes in controls due to the COVID pandemic. Without proper approval procedures in place unallowable expenses may be paid and charged to the federal program or charged at the wrong amount. Questioned Costs: None noted. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the University?s management follow the internal control procedures in place surrounding allowable costs specifically as it relates to documenting approval of expenditures. Views of Responsible Official: Management agrees with the finding.
Finding #: 2021-001 ? Allowable Cost ? Internal Control (Material Weakness) Description of Finding: There were six documents attributed to payments against the Education Stabilization Fund, and two documents attributed to payments against the Higher Education Institutional Aid. These documents did not have sign off reflecting proper review and approval for payment. This may happen with the Pcard reports when an employee has submitted their report packet to the supervisor, but the supervisor does not review and approve it timely. The Accounts Payable office is required to pay the Pcard bill timely, so they will process the payment without the supervisor?s approval. Corrective Action Plan: In order to ensure that all payments are reviewed and approved, in the instance of when a supervisor has not signed off on the Pcard report timely, the report will be sent to the Controller for review, approval, and sign off, prior to paying the Pcard bill. The responsible party is Lori Gordien Case at lgordien@laverne.edu . This will be corrected by November 2022.
Criteria: In accordance with 2 CFR section 200.318, the entity must establish policies for procurement of equipment, real property and other services funded by federal funds. The procurement records and files for purchases in excess of the micro purchase threshold shall include at the minimum the following items: the basis for contractor selection, justification for lack of competition when competitive bids are not obtained, and basis for award cost or price. In addition, award recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. To ensure this is done, recipients should utilize the Excluded Parties List System website. Condition/Context: From a non-statistical sample of two (2) vendors subjected to testing, we determined that rate quotations and rationale for limited competition were not retained for either vendor. It was also determined that there was no documentation retained regarding verification of vendor suspension or debarment for either vendor. Cause/Effect: Per discussion with Management, the entity has the processes designed via the Policies and Procedures provided, however, there is not a formal process established to document the performance of such controls. We note that inadequate controls could result in a reasonable possibility that the entity would not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None noted. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend implementing a system of review and approval controls to complement the design of processes over the procurement, suspension, and debarment compliance requirements. In addition, we recommend that the University retain documentation regarding procurement decisions including rate quotations and verification of vendor suspension and debarment checks. Views of Responsible Official: Management agrees with finding.
Show full finding ▾Hide full finding ▴Criteria: In accordance with 2 CFR section 200.318, the entity must establish policies for procurement of equipment, real property and other services funded by federal funds. The procurement records and files for purchases in excess of the micro purchase threshold shall include at the minimum the following items: the basis for contractor selection, justification for lack of competition when competitive bids are not obtained, and basis for award cost or price. In addition, award recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. To ensure this is done, recipients should utilize the Excluded Parties List System website. Condition/Context: From a non-statistical sample of two (2) vendors subjected to testing, we determined that rate quotations and rationale for limited competition were not retained for either vendor. It was also determined that there was no documentation retained regarding verification of vendor suspension or debarment for either vendor. Cause/Effect: Per discussion with Management, the entity has the processes designed via the Policies and Procedures provided, however, there is not a formal process established to document the performance of such controls. We note that inadequate controls could result in a reasonable possibility that the entity would not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None noted. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend implementing a system of review and approval controls to complement the design of processes over the procurement, suspension, and debarment compliance requirements. In addition, we recommend that the University retain documentation regarding procurement decisions including rate quotations and verification of vendor suspension and debarment checks. Views of Responsible Official: Management agrees with finding.
Finding #: 2021-002 ? Procurement ? Internal Control (Material Weakness) Description of Finding: There were two vendors that did not have the documentation to substantiate the use of the vendors, or the necessary pricing quotations. Corrective Action Plan: In the case of these two vendors, there were items ordered directly by a University department. These vendors were familiar vendors in the work of the department, so the standard vetting and documentation by the Purchasing department was not performed and documented. To correct this, all new vendors for purposes of Federal Awards will not be added into the system until reviewed and approved by the Purchasing department. The responsible parties are Lori Gordien Case at lgordien@laverne.edu and Debbie Deacy at ddeacy@laverne.edu . This will be corrected by November 2022.
Criteria: In accordance with 2 CFR sections 200.328 and 200.329, there are three components to reporting for HEERF: 1) public reporting on the Student Aid Portion; 2) public reporting on the Institutional Portion and subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. A complete system of internal controls requires all expenditures be properly approved and supported by appropriate documentation. Condition/Context: From a non-statistical sample of two (2) reports subject to testing, we identified two (2) instances where the report tested lacked evidence of review in accordance with the University?s control policies. Cause/Effect: Based on discussions with Management, the above occurred due to efforts made to abide by the 10-day time period between quarter-end and the reporting deadline. Due to the short time period, the review and approval process is rushed, and the necessary review took place during tele-conference and the CFO provided approval over the phone to get the report posted accordingly. Questioned Costs: None noted. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the University?s Management routinely review and consider modifications that would strengthen the internal controls surrounding reporting specifically as it relates to documenting approval of reports. Views of Responsible Official: Management agrees with finding.
Show full finding ▾Hide full finding ▴Criteria: In accordance with 2 CFR sections 200.328 and 200.329, there are three components to reporting for HEERF: 1) public reporting on the Student Aid Portion; 2) public reporting on the Institutional Portion and subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. A complete system of internal controls requires all expenditures be properly approved and supported by appropriate documentation. Condition/Context: From a non-statistical sample of two (2) reports subject to testing, we identified two (2) instances where the report tested lacked evidence of review in accordance with the University?s control policies. Cause/Effect: Based on discussions with Management, the above occurred due to efforts made to abide by the 10-day time period between quarter-end and the reporting deadline. Due to the short time period, the review and approval process is rushed, and the necessary review took place during tele-conference and the CFO provided approval over the phone to get the report posted accordingly. Questioned Costs: None noted. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend the University?s Management routinely review and consider modifications that would strengthen the internal controls surrounding reporting specifically as it relates to documenting approval of reports. Views of Responsible Official: Management agrees with finding.
Finding #: 2021-003 ? Reporting-Internal Control (Material Weakness) Description of Finding: The quarterly reports for purposes of reporting use of HEERF funds for the public reporting of both the Student Aid Portion, and the Institutional Portions did not have documented evidence of review and approval of the Chief Financial Officer prior to the posting to the website, and sending to the Program Director of the HEERF funds. Corrective Action Plan: The quarterly information for both the Student Aid Portion and the Institutional Portion will continued to be reviewed by the Finance Office management team prior to reporting. In addition, it will be required that the information and the quarterly and annual reports will have documented evidence of review and approval by the Chief Financial Officer prior to posting of the reports to the website or submitting to the Program Director of the HEERF funds. The responsible parties are Lori Gordien Case at lgordien@laverne.edu and Avo Kechichian at akechichian2@laverne.edu . This will be corrected by October 2022.
FAC accepted this audit on July 13, 2021 — management decision was due January 13, 2022.
FAC accepted this audit on November 19, 2019 — management decision was due May 19, 2020.
In mid-October 2019, the University of La Verne discovered that 78 eligible students enrolled for Summer 2019 did not receive Federal Pell grant disbursements for the Summer 2019 payment period. Questioned Costs: None Context: Pell qualified students enrolled for the Summer 2019 term did not receive their Pell grant disbursements within the required time period. Cause: A long term configuration problem in the Banner computer system causes an improper distribution of the Pell Grants among the different terms for which the students were enrolled, if a financial aid packet is altered from its original award. There has been no satisfactory solution to the configuration issue, therefore internal controls were enacted to identify and correct any errors. There was a breakdown in the manual monitoring set in place to manage any errors on a timely basis. Effect: The impact of the above cause is that Pell Grants may not be disbursed to eligible students in amounts in compliance with federal regulations. Recommendation: We recommend the University review the underlying elections contained within the Banner computer system and ensure these elections are appropriately set up to properly reflect the University?s academic calendar and federal requirements. If this is not practical, improve the review procedures monitoring this item. Management?s Response and Corrective Action: The functional technology staff in the Financial Aid Office has updated their procedures and checklists to ensure cost of attendance and needs analysis processes are run with the proper timing. The Associate Director overseeing functional technology is directly responsible for ensuring this process runs successfully by their staff and reporting issues or anomalies immediately as they are discovered to the Director of Financial Aid. This responsibility has been affirmed with the Associate Director. The current monthly Pell reconciliations processes and reports were enhanced in direct response to this matter. This matter was reviewed in detail with the Pell Grant Coordinator and Associate Director overseeing compliance. It has been affirmed with both of these staff members, that identifying and reporting issues or anomalies immediately to the Director of Financial Aid it is their responsibility. "
Show full finding ▾Hide full finding ▴"Federal Program: U.S. Department of Education ? Student Financial Assistance Cluster (Pell Grant CFDA 84.063) Type of Finding: Deficiency and Noncompliance Compliance Requirement: Reporting and Cash Management Criteria: 34 CFR Section 690.63-.64 provides guidance for calculating Federal Pell Grants over different terms/semesters. Condition: In mid-October 2019, the University of La Verne discovered that 78 eligible students enrolled for Summer 2019 did not receive Federal Pell grant disbursements for the Summer 2019 payment period. Questioned Costs: None Context: Pell qualified students enrolled for the Summer 2019 term did not receive their Pell grant disbursements within the required time period. Cause: A long term configuration problem in the Banner computer system causes an improper distribution of the Pell Grants among the different terms for which the students were enrolled, if a financial aid packet is altered from its original award. There has been no satisfactory solution to the configuration issue, therefore internal controls were enacted to identify and correct any errors. There was a breakdown in the manual monitoring set in place to manage any errors on a timely basis. Effect: The impact of the above cause is that Pell Grants may not be disbursed to eligible students in amounts in compliance with federal regulations. Recommendation: We recommend the University review the underlying elections contained within the Banner computer system and ensure these elections are appropriately set up to properly reflect the University?s academic calendar and federal requirements. If this is not practical, improve the review procedures monitoring this item. Management?s Response and Corrective Action: The functional technology staff in the Financial Aid Office has updated their procedures and checklists to ensure cost of attendance and needs analysis processes are run with the proper timing. The Associate Director overseeing functional technology is directly responsible for ensuring this process runs successfully by their staff and reporting issues or anomalies immediately as they are discovered to the Director of Financial Aid. This responsibility has been affirmed with the Associate Director. The current monthly Pell reconciliations processes and reports were enhanced in direct response to this matter. This matter was reviewed in detail with the Pell Grant Coordinator and Associate Director overseeing compliance. It has been affirmed with both of these staff members, that identifying and reporting issues or anomalies immediately to the Director of Financial Aid it is their responsibility. "
The functional technology staff in the Financial Aid Office has updated their procedures and checklists to ensure cost of attendance and needs analysis process are run with the proper timing. The Associate Director overseeing functional technology is directly responsible for ensuring the process runs successfully by their staff and reporting issues or anomalies immediately as they are discovered to the Director of Financial Aid. This responsibility has been affirmed with the Associate Director. The current monthly Pell reconciliations process and reports were enhanced in direct response to the matter. This matter was reviewed in detail with the Pell Grant coordinator and Associate Director overseeing compliance. It has been affirmed with both of these staff members, that identifying and reporting issues or anomalies immediately to the Director of Financial Aid is their responsibility.
FAC accepted this audit on November 28, 2018 — management decision was due May 28, 2019.
FAC accepted this audit on December 21, 2017 — management decision was due June 21, 2018.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on December 19, 2016 — management decision was due June 19, 2017.
GSA_MIGRATION
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