FAC Explorer

Audit 290692

FY End
2023-06-30
Total Expended
$1.47M
Findings
4
Programs
2
Organization: Western Seminary (OR)
Year: 2023 Accepted: 2024-02-15
Auditor: Capincrouse LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
369472 2023-002 Significant Deficiency Yes N
369473 2023-003 Significant Deficiency - N
945914 2023-002 Significant Deficiency Yes N
945915 2023-003 Significant Deficiency - N

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $1.33M Yes 2
84.425 Covid-19 Education Stabilization Fund Heerf - Student Aid Portion $140,231 - 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 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 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. 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 Western 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 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. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate Western 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

Finding 2023-002
Untimely Returns of Title IV Funds (R2T4)Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew whether officially or unofficially, the Seminary did not always return unearned Title IV aid timely. Criteria: 34 CFR 668.22 Questioned Costs: $6,096 Context: Out of 5 students who withdrew during the audit period tested 3 had funds returned late. One official withdrawal for summer 2023 had $2,336 returned 35 days late. Two unofficial withdrawals were not performed by the Seminary although the student withdrew before the 60% date for the semester. These two were identified during the audit process and $6,096 were returned in October 2023 resulting in the funds being returned between 106 and 230 days late. All students who withdrew were tested. Cause: The system for R2T4 tracking is not sufficient. High turnover in the Financial Aid department and the new Director of Financial Aid does not have in-depth training on R2T4 tracking or calculations as they are new to the position. Effect: Returned of Title IV funds were not performed timely. Identification as repeat finding, if applicable: 2022-002 Recommendation: We recommend that the Seminary reviews the R2T4 tracking system to make sure all students that withdrawal are being properly tracked along with the last day of attendance. If the tracking system is deemed to be insufficient, we recommend implementing a new tracking system and put in place a procedure to review students with no passing grades and Title IV aid to determine if an R2T4 for an unofficial withdrawal is required. We also recommend that the Seminary set aside appropriate funds and time for the Director of Financial Aid to attend R2T4 training and professional development so they have the the appropriate knowledge and skill to manage R2T4 calculations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-003
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 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: 1) sufficiently documented its security risk assessment and safeguards, including an application-specific assessment 2) implemented multi-factor authentication on all systems containing personally identifiable information (PII) 3) implemented ongoing vendor management policies and reviews 4) implemented an incident response plan that addresses all requirements 5) provided a written, annual report to the board 6) updated employee training in light of the revised regulations from June 2023 7) updated its written information security program to address all components that went into effect in June 2023 Cause: The Seminary has not allocated sufficient resources to address and document compliance with the requirements of GLBA. 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 requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-002
Untimely Returns of Title IV Funds (R2T4)Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew whether officially or unofficially, the Seminary did not always return unearned Title IV aid timely. Criteria: 34 CFR 668.22 Questioned Costs: $6,096 Context: Out of 5 students who withdrew during the audit period tested 3 had funds returned late. One official withdrawal for summer 2023 had $2,336 returned 35 days late. Two unofficial withdrawals were not performed by the Seminary although the student withdrew before the 60% date for the semester. These two were identified during the audit process and $6,096 were returned in October 2023 resulting in the funds being returned between 106 and 230 days late. All students who withdrew were tested. Cause: The system for R2T4 tracking is not sufficient. High turnover in the Financial Aid department and the new Director of Financial Aid does not have in-depth training on R2T4 tracking or calculations as they are new to the position. Effect: Returned of Title IV funds were not performed timely. Identification as repeat finding, if applicable: 2022-002 Recommendation: We recommend that the Seminary reviews the R2T4 tracking system to make sure all students that withdrawal are being properly tracked along with the last day of attendance. If the tracking system is deemed to be insufficient, we recommend implementing a new tracking system and put in place a procedure to review students with no passing grades and Title IV aid to determine if an R2T4 for an unofficial withdrawal is required. We also recommend that the Seminary set aside appropriate funds and time for the Director of Financial Aid to attend R2T4 training and professional development so they have the the appropriate knowledge and skill to manage R2T4 calculations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-003
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 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: 1) sufficiently documented its security risk assessment and safeguards, including an application-specific assessment 2) implemented multi-factor authentication on all systems containing personally identifiable information (PII) 3) implemented ongoing vendor management policies and reviews 4) implemented an incident response plan that addresses all requirements 5) provided a written, annual report to the board 6) updated employee training in light of the revised regulations from June 2023 7) updated its written information security program to address all components that went into effect in June 2023 Cause: The Seminary has not allocated sufficient resources to address and document compliance with the requirements of GLBA. 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 requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.