Audit 2132

FY End
2023-06-30
Total Expended
$3.03M
Findings
4
Programs
3
Organization: Dallas Theological Seminary (TX)
Year: 2023 Accepted: 2023-11-02
Auditor: Capincrouse LLP

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
1116 2023-001 Significant Deficiency - N
1117 2023-001 Significant Deficiency - N
577558 2023-001 Significant Deficiency - N
577559 2023-001 Significant Deficiency - N

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $2.86M Yes 1
84.033 Federal Work-Study Program $126,966 Yes 1
84.425 Covid-19 Education Stabilization Fund Governor’s Emergency Education Relifef Fund $50,000 - 0

Contacts

Name Title Type
FRLBRGREMNP5 David Tarrant Auditee
2148875021 Dan Campbell, 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 Dallas Theological Seminary (Seminary) 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 Seminary 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: The auditee did not use the de minimis cost rate 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 Dallas Theological Seminary (Seminary) 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 Seminary 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: The auditee did not use the de minimis cost rate The Seminary did not provide any federal funds to subrecipients nor did they receive any federal non-cash assistance, insurance, loans, or loan guarantees.

Finding Details

Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.033, Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The Seminary did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $-0- Context: The Seminary has not: - sufficiently documented its security risk assessment and safeguards for systems and programs added during the year - implemented multi-factor authentication on all systems containing personally identifiable information (PII) - implemented a formal employee training program - implemented comprehensive continuous monitoring or annual penetration testing and biannual vulnerability scanning during the audit period - provided a written, annual report to the board Cause: The Seminary underwent a system conversion during the year and was not able to allocate sufficient resources to address and document compliance with the updated requirements of GLBA. Additionally, equipment purchased to address portions of compliance has remained on backorder. Effect: The Seminary 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 Seminary allocate sufficient resources to address all updated 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 and 84.033, Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The Seminary did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $-0- Context: The Seminary has not: - sufficiently documented its security risk assessment and safeguards for systems and programs added during the year - implemented multi-factor authentication on all systems containing personally identifiable information (PII) - implemented a formal employee training program - implemented comprehensive continuous monitoring or annual penetration testing and biannual vulnerability scanning during the audit period - provided a written, annual report to the board Cause: The Seminary underwent a system conversion during the year and was not able to allocate sufficient resources to address and document compliance with the updated requirements of GLBA. Additionally, equipment purchased to address portions of compliance has remained on backorder. Effect: The Seminary 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 Seminary allocate sufficient resources to address all updated 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 and 84.033, Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The Seminary did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $-0- Context: The Seminary has not: - sufficiently documented its security risk assessment and safeguards for systems and programs added during the year - implemented multi-factor authentication on all systems containing personally identifiable information (PII) - implemented a formal employee training program - implemented comprehensive continuous monitoring or annual penetration testing and biannual vulnerability scanning during the audit period - provided a written, annual report to the board Cause: The Seminary underwent a system conversion during the year and was not able to allocate sufficient resources to address and document compliance with the updated requirements of GLBA. Additionally, equipment purchased to address portions of compliance has remained on backorder. Effect: The Seminary 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 Seminary allocate sufficient resources to address all updated 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 and 84.033, Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The Seminary did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $-0- Context: The Seminary has not: - sufficiently documented its security risk assessment and safeguards for systems and programs added during the year - implemented multi-factor authentication on all systems containing personally identifiable information (PII) - implemented a formal employee training program - implemented comprehensive continuous monitoring or annual penetration testing and biannual vulnerability scanning during the audit period - provided a written, annual report to the board Cause: The Seminary underwent a system conversion during the year and was not able to allocate sufficient resources to address and document compliance with the updated requirements of GLBA. Additionally, equipment purchased to address portions of compliance has remained on backorder. Effect: The Seminary 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 Seminary allocate sufficient resources to address all updated requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.