Audit 25878

FY End

2022-06-30

Total Expended

$1.80M

Findings

4

Programs

3

Organization: Western Seminary (OR)

Year: 2022 Accepted: 2023-03-20

Auditor: Capincrouse LLP

Organization Exclusion Status:

Checking exclusion status...

ID	Ref	Severity	Repeat	Requirement
20411	2022-002	Significant Deficiency	-	N
20412	2022-003	-	-	N
596853	2022-002	Significant Deficiency	-	N
596854	2022-003	-	-	N

ALN	Program	Spent	Major	Findings
84.268	Federal Direct Student Loans	$1.51M	Yes	2
84.425	Covid-19 Education Stabilization Fund Heerf - Institutional Portion	$162,781	-	0
84.425	Covid-19 Education Stabilization Fund Heerf - Fund for the Improvement of Postsecondary Education Formula Grant (fipse)	$128,304	-	0

Contacts

Name	Title	Type
KCLBMKRFR344	Jonathan Gibson	Auditee
5035171882	Christopher Gordon, CPA	Auditor
No contacts on file

Notes to SEFA

Title: RELATIONSHIP TO FINANCIAL STATEMENTS Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Western Seminary (the Seminary) under programs of the federal government for the year ending June 30, 2022. 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 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 table in SEFA Note 3.

Title: SUBRECIPIENTS, NON-CASH ASSISTANCE, FEDERAL INSURANCE, LOANS, AND LOAN GUAR Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Western Seminary (the Seminary) under programs of the federal government for the year ending June 30, 2022. 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 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.

Title: COVID-19 HEERF FUNDS Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Western Seminary (the Seminary) under programs of the federal government for the year ending June 30, 2022. 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 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 Education Stabilization Fund requires that a minimum of HEERF funds be spent on emergency financial aid grants to students. As of June 30, 2022, the Seminary had approximately $140,000 yet to disburse to students to meet this minimum. The Seminary has until June 30, 2023 to make the remaining emergency financial aid grants to students.

Finding Details

Finding 2022-002

Return of Title IV (R2T4) Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Student Loans Federal Award Identification #: 2021-22 Financial Aid Year Condition: When students withdrew unofficially, the Seminary did not always return unearned Title IV aid. Criteria: 34 CFR 668.22 Questioned Costs: $1,207 Context: Out of 7 students tested for withdrawals, 1 unofficial withdrawal did not have a return calculation initially performed. This student is in the process of being corrected. Cause: This was due to the Seminary evaluating the last date of attendance based on the first absence instead of the last active date of participation. This student's last date of participation was just before the 60% mark of the semester. Effect: A return of loans was not initially completed for one student. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the Seminary run a 0-credit report be run at the end of each semester to ensure all unofficial withdrawals are followed up on so that R2T4's are completed timely when required. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Finding 2022-003

Incorrect and Late Enrollment Reporting to National Student Loan Data System (NSLDS) DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Student Loans Federal Award Identification #: 2021-22 Financial Aid Year Condition: The NSLDS enrollment status effective date for withdrawals was not accurately sent to NSLDS from the system. Additionally, 4 of 63 submissions to NSLDS were not responded to within 15 days of receiving an error report. Criteria: 34 CFR 685.309 Questioned Costs: $-0- Context: Out of 7 students tested, 2 students had incorrect effective dates reported for their enrollment status. All of these students were official and unofficial withdrawals. On the 4 late responses to NSLDS, the number of days late ranged from 1-2 days. Cause: The field being pulled for NSLDS enrollment reporting did not accurately capture official withdrawals and the last date of participation for unofficial withdrawals. Effect: Inaccurate reporting can impact a student?s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the Seminary put a system in place to ensure that the date being reported to NSLDS as the effective date of withdrawal is the actual last date of attendance for the student, that the Seminary is responding to errors within 15 days, and that the Seminary is completing spot checks of enrollment statuses to NSLDS. This may include working with National Student Clearinghouse. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Finding 2022-002

Return of Title IV (R2T4) Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Student Loans Federal Award Identification #: 2021-22 Financial Aid Year Condition: When students withdrew unofficially, the Seminary did not always return unearned Title IV aid. Criteria: 34 CFR 668.22 Questioned Costs: $1,207 Context: Out of 7 students tested for withdrawals, 1 unofficial withdrawal did not have a return calculation initially performed. This student is in the process of being corrected. Cause: This was due to the Seminary evaluating the last date of attendance based on the first absence instead of the last active date of participation. This student's last date of participation was just before the 60% mark of the semester. Effect: A return of loans was not initially completed for one student. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the Seminary run a 0-credit report be run at the end of each semester to ensure all unofficial withdrawals are followed up on so that R2T4's are completed timely when required. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Finding 2022-003

Incorrect and Late Enrollment Reporting to National Student Loan Data System (NSLDS) DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Student Loans Federal Award Identification #: 2021-22 Financial Aid Year Condition: The NSLDS enrollment status effective date for withdrawals was not accurately sent to NSLDS from the system. Additionally, 4 of 63 submissions to NSLDS were not responded to within 15 days of receiving an error report. Criteria: 34 CFR 685.309 Questioned Costs: $-0- Context: Out of 7 students tested, 2 students had incorrect effective dates reported for their enrollment status. All of these students were official and unofficial withdrawals. On the 4 late responses to NSLDS, the number of days late ranged from 1-2 days. Cause: The field being pulled for NSLDS enrollment reporting did not accurately capture official withdrawals and the last date of participation for unofficial withdrawals. Effect: Inaccurate reporting can impact a student?s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the Seminary put a system in place to ensure that the date being reported to NSLDS as the effective date of withdrawal is the actual last date of attendance for the student, that the Seminary is responding to errors within 15 days, and that the Seminary is completing spot checks of enrollment statuses to NSLDS. This may include working with National Student Clearinghouse. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.