FAC Explorer

Audit 297426

FY End
2023-06-30
Total Expended
$1.52M
Findings
14
Programs
6
Organization: Trinity Bible College and Graduate School (ND)
Year: 2023 Accepted: 2024-03-25
Auditor: Capincrouse LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
384283 2023-001 Significant Deficiency - N
384284 2023-001 Significant Deficiency - N
384285 2023-001 Significant Deficiency - N
384286 2023-001 Significant Deficiency - N
384287 2023-001 Significant Deficiency - N
384288 2023-001 Significant Deficiency - N
384289 2023-002 - - L
960725 2023-001 Significant Deficiency - N
960726 2023-001 Significant Deficiency - N
960727 2023-001 Significant Deficiency - N
960728 2023-001 Significant Deficiency - N
960729 2023-001 Significant Deficiency - N
960730 2023-001 Significant Deficiency - N
960731 2023-002 - - L

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $808,701 Yes 1
84.063 Federal Pell Grant Program $373,013 Yes 1
84.038 Federal Perkins Loan Program $161,569 Yes 2
84.033 Federal Work-Study Program $100,559 Yes 1
84.007 Federal Supplemental Educational Opportunity Grants $58,968 Yes 1
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $20,746 Yes 1

Contacts

Name Title Type
VSCGPLJGN8Z6 Vaughn Jordan Auditee
7013495774 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 Trinity Bible College and Graduate School under programs of the federal government for the year ended 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. If Trinity Bible College and Graduate School 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 Trinity Bible College and Graduate School under programs of the federal government for the year ended 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. If Trinity Bible College and Graduate School 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 Trinity Bible College and Graduate School 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 Trinity Bible College and Graduate School under programs of the federal government for the year ended 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. If Trinity Bible College and Graduate School 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

Finding Details

Finding 2023-001
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats or implemented multi-factor authentication on all systems containing personally identifiable information (PII). Additionally, the College has not sufficiently implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board that covers all areas required by GLBA. 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 commend the College for all work completed on GLBA. 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.
Finding 2023-001
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats or implemented multi-factor authentication on all systems containing personally identifiable information (PII). Additionally, the College has not sufficiently implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board that covers all areas required by GLBA. 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 commend the College for all work completed on GLBA. 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.
Finding 2023-001
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats or implemented multi-factor authentication on all systems containing personally identifiable information (PII). Additionally, the College has not sufficiently implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board that covers all areas required by GLBA. 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 commend the College for all work completed on GLBA. 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.
Finding 2023-001
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats or implemented multi-factor authentication on all systems containing personally identifiable information (PII). Additionally, the College has not sufficiently implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board that covers all areas required by GLBA. 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 commend the College for all work completed on GLBA. 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.
Finding 2023-001
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats or implemented multi-factor authentication on all systems containing personally identifiable information (PII). Additionally, the College has not sufficiently implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board that covers all areas required by GLBA. 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 commend the College for all work completed on GLBA. 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.
Finding 2023-001
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats or implemented multi-factor authentication on all systems containing personally identifiable information (PII). Additionally, the College has not sufficiently implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board that covers all areas required by GLBA. 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 commend the College for all work completed on GLBA. 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.
Finding 2023-002
FISAP Reporting DEPARTMENT OF EDUCATION ALN #: 84.038 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not accurately report certain items relating to Perkins reporting on the FISAP report. Criteria: 34 CFR 668.24(e) Questioned Costs: $0 Context: The College did not properly report Perkins cash on hand information on the most recent FISAP. Cause: Oversight by management. Effect: FISAP cash on hand was overstated which potentially leads to the College returning more cash to the Department of Education than required. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College work with the Department of Education to correct errors in the Perkins portion of the FISAP. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-001
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats or implemented multi-factor authentication on all systems containing personally identifiable information (PII). Additionally, the College has not sufficiently implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board that covers all areas required by GLBA. 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 commend the College for all work completed on GLBA. 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.
Finding 2023-001
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats or implemented multi-factor authentication on all systems containing personally identifiable information (PII). Additionally, the College has not sufficiently implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board that covers all areas required by GLBA. 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 commend the College for all work completed on GLBA. 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.
Finding 2023-001
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats or implemented multi-factor authentication on all systems containing personally identifiable information (PII). Additionally, the College has not sufficiently implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board that covers all areas required by GLBA. 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 commend the College for all work completed on GLBA. 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.
Finding 2023-001
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats or implemented multi-factor authentication on all systems containing personally identifiable information (PII). Additionally, the College has not sufficiently implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board that covers all areas required by GLBA. 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 commend the College for all work completed on GLBA. 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.
Finding 2023-001
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats or implemented multi-factor authentication on all systems containing personally identifiable information (PII). Additionally, the College has not sufficiently implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board that covers all areas required by GLBA. 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 commend the College for all work completed on GLBA. 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.
Finding 2023-001
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, 84.038, 84.379 Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats or implemented multi-factor authentication on all systems containing personally identifiable information (PII). Additionally, the College has not sufficiently implemented continuous monitoring, such as penetration testing and vulnerability scanning, implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board that covers all areas required by GLBA. 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 commend the College for all work completed on GLBA. 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.
Finding 2023-002
FISAP Reporting DEPARTMENT OF EDUCATION ALN #: 84.038 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not accurately report certain items relating to Perkins reporting on the FISAP report. Criteria: 34 CFR 668.24(e) Questioned Costs: $0 Context: The College did not properly report Perkins cash on hand information on the most recent FISAP. Cause: Oversight by management. Effect: FISAP cash on hand was overstated which potentially leads to the College returning more cash to the Department of Education than required. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College work with the Department of Education to correct errors in the Perkins portion of the FISAP. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.