Audit 1114

FY End
2023-06-30
Total Expended
$5.05M
Findings
12
Programs
7
Year: 2023 Accepted: 2023-10-24
Auditor: Capincrouse LLP

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
567 2023-001 Significant Deficiency - N
568 2023-001 Significant Deficiency - N
569 2023-001 Significant Deficiency - N
570 2023-001 Significant Deficiency - N
571 2023-001 Significant Deficiency - N
572 2023-001 Significant Deficiency - N
577009 2023-001 Significant Deficiency - N
577010 2023-001 Significant Deficiency - N
577011 2023-001 Significant Deficiency - N
577012 2023-001 Significant Deficiency - N
577013 2023-001 Significant Deficiency - N
577014 2023-001 Significant Deficiency - N

Contacts

Name Title Type
L5MMBAMNPNS7 Mark Huffines Auditee
7068201560 Christian Mantegna, CPA Auditor
No contacts on file

Notes to SEFA

Title: RELATIONSHIP TO CONSOLIDATED FINANCIAL STATEMENTS Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Covenant College, Inc. and Supporting Foundation (College) under programs of the federal government for the year ending June 30, 2023. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the College is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: N/A See the Notes to the SEFA for chart/table
Title: SUBRECIPIENTS, NON-CASH ASSISTANCE, FEDERAL INSURANCE, LOANS, AND LOAN GUARANTEES Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Covenant College, Inc. and Supporting Foundation (College) under programs of the federal government for the year ending June 30, 2023. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the College is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: N/A The College did not provide any federal funds to subrecipients nor did they receive any federal non-cash assistance, insurance, loans, or loan guarantees.
Title: FEDERAL PERKINS LOAN PROGRAM Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Covenant College, Inc. and Supporting Foundation (College) under programs of the federal government for the year ending June 30, 2023. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the College is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: N/A See the Notes to the SEFA for chart/table

Finding Details

Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not: • Implemented multi-factor authentication on systems containing personally identifiable information (PII) • Implemented continuous monitoring, such as penetration testing and vulnerability scanning • Implemented sufficient vendor management policies and reviews • Provided a written, annual report to the board Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College 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: Not applicable. Recommendation: We recommend the College 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 (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not: • Implemented multi-factor authentication on systems containing personally identifiable information (PII) • Implemented continuous monitoring, such as penetration testing and vulnerability scanning • Implemented sufficient vendor management policies and reviews • Provided a written, annual report to the board Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College 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: Not applicable. Recommendation: We recommend the College 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 (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not: • Implemented multi-factor authentication on systems containing personally identifiable information (PII) • Implemented continuous monitoring, such as penetration testing and vulnerability scanning • Implemented sufficient vendor management policies and reviews • Provided a written, annual report to the board Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College 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: Not applicable. Recommendation: We recommend the College 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 (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not: • Implemented multi-factor authentication on systems containing personally identifiable information (PII) • Implemented continuous monitoring, such as penetration testing and vulnerability scanning • Implemented sufficient vendor management policies and reviews • Provided a written, annual report to the board Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College 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: Not applicable. Recommendation: We recommend the College 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 (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not: • Implemented multi-factor authentication on systems containing personally identifiable information (PII) • Implemented continuous monitoring, such as penetration testing and vulnerability scanning • Implemented sufficient vendor management policies and reviews • Provided a written, annual report to the board Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College 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: Not applicable. Recommendation: We recommend the College 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 (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not: • Implemented multi-factor authentication on systems containing personally identifiable information (PII) • Implemented continuous monitoring, such as penetration testing and vulnerability scanning • Implemented sufficient vendor management policies and reviews • Provided a written, annual report to the board Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College 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: Not applicable. Recommendation: We recommend the College 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 (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not: • Implemented multi-factor authentication on systems containing personally identifiable information (PII) • Implemented continuous monitoring, such as penetration testing and vulnerability scanning • Implemented sufficient vendor management policies and reviews • Provided a written, annual report to the board Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College 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: Not applicable. Recommendation: We recommend the College 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 (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not: • Implemented multi-factor authentication on systems containing personally identifiable information (PII) • Implemented continuous monitoring, such as penetration testing and vulnerability scanning • Implemented sufficient vendor management policies and reviews • Provided a written, annual report to the board Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College 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: Not applicable. Recommendation: We recommend the College 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 (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not: • Implemented multi-factor authentication on systems containing personally identifiable information (PII) • Implemented continuous monitoring, such as penetration testing and vulnerability scanning • Implemented sufficient vendor management policies and reviews • Provided a written, annual report to the board Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College 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: Not applicable. Recommendation: We recommend the College 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 (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not: • Implemented multi-factor authentication on systems containing personally identifiable information (PII) • Implemented continuous monitoring, such as penetration testing and vulnerability scanning • Implemented sufficient vendor management policies and reviews • Provided a written, annual report to the board Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College 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: Not applicable. Recommendation: We recommend the College 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 (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not: • Implemented multi-factor authentication on systems containing personally identifiable information (PII) • Implemented continuous monitoring, such as penetration testing and vulnerability scanning • Implemented sufficient vendor management policies and reviews • Provided a written, annual report to the board Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College 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: Not applicable. Recommendation: We recommend the College 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 (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not: • Implemented multi-factor authentication on systems containing personally identifiable information (PII) • Implemented continuous monitoring, such as penetration testing and vulnerability scanning • Implemented sufficient vendor management policies and reviews • Provided a written, annual report to the board Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College 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: Not applicable. Recommendation: We recommend the College 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.