Audit 298024

FY End
2023-06-30
Total Expended
$835,013
Findings
6
Programs
3
Year: 2023 Accepted: 2024-03-26
Auditor: Blue & CO LLC

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
384982 2023-002 Material Weakness - E
384983 2023-003 Material Weakness - N
384984 2023-004 Material Weakness - E
961424 2023-002 Material Weakness - E
961425 2023-003 Material Weakness - N
961426 2023-004 Material Weakness - E

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $802,407 Yes 3
84.425 Education Stabilization Fund $28,283 - 0
84.033 Federal Work-Study Program $4,323 Yes 0

Contacts

Name Title Type
FC4WY6KFK5E6 Ward Logan Auditee
3179314212 Doug Hasler Auditor
No contacts on file

Notes to SEFA

Title: Note 1 - Basis of Presentation Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost priciples contained in Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The Seminary has elected not to use the 10% de minimis indirect cost rate as allowed under Uniform Guidance. De Minimis Rate Used: N Rate Explanation: No indirect costs were charged to federal programs. The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the federal grant activity of Christian Theological Seminary, Inc. (the Seminary) under the programs of the federal government for the year ended June 30, 2023. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the Seminary, it is not intended to and does not present the financial position, changes in net assets or cash flows of the Seminary.
Title: Note 2 - Summary of Significant Accounting Policies Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost priciples contained in Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The Seminary has elected not to use the 10% de minimis indirect cost rate as allowed under Uniform Guidance. De Minimis Rate Used: N Rate Explanation: No indirect costs were charged to federal programs. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The Seminary has elected not to use the 10% de minimis indirect cost rate as allowed under Uniform Guidance.
Title: Note 3 - Federal Direct Student Loan Program Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost priciples contained in Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. The Seminary has elected not to use the 10% de minimis indirect cost rate as allowed under Uniform Guidance. De Minimis Rate Used: N Rate Explanation: No indirect costs were charged to federal programs. The Federal Direct Student Loan Program loans made during the year are included in the federal expenditures presented in the Schedule. Such loans were not made directly by the Seminary and are not included in its financial statements but were received by students of the Seminary during the audit period.

Finding Details

MATERIAL WEAKNESS, Document Satisfactory Academic Progress Evaluation, Information on the federal program: U.S. Department of Education, Assistance Listing No. 84.268; Federal Direct Student Loan Program, Criteria: Students awarded financial aid must meet certain eligibility requirements including maintaining satisfactory academic progress. Condition: The Seminary did document the evaluation of student satisfactory academic progress. Context: Out of a population of 50 students who received aid under the student financial aid cluster, we sampled 10. No documentation of the annual evaluation of satisfactory academic progress was maintained either within or outside of the student management system. None of the sample of 10 were found to not have achieved satisfactory academic progress. Questioned Costs: None Cause: Manual evaluations are being performed in accordance with the Seminary's policy but are not documented within the student management software. Effect: No documentation exists that the annual evaluation was performed. Recommendation: We recommend that management adjust its procedures to document the annual evaluation either within our outside of the student management software. Views of responsible officials and planned corrective actions: Management acknowledges this finding and is working on documentation to remove this deficiency in the future. Satisfactory academic progress is being calculated, but lack of paperwork by the Seminary made this finding necessary. The Seminary financial aid department will work on documenting processes moving forward.
MATERIAL WEAKNESS, Compliance with Gramm-Leach-Bliley Act, Information on the federal program: U.S. Department of Education, Assistance Listing No. 84.268; Federal Direct Student Loan Program, Criteria: Institutions that participate in Title IV educational assistance programs are subject to the Gramm-Leach-Bliley Act to protect student financial aid information. They are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and includes certain elements. Condition: The Seminary did not have a written program in place by June 9, 2023, the required deadline. Context: The Seminary has an outsourced IT provider which provides services under a service agreement. Questioned Costs: None, Cause: Management was not aware of the documentation requirement. Effect: While the services provided by the IT service provider as well as the Seminary's internal IT department address security concerns and needs within the Seminary, all areas of Gramm-Leach-Bliley might not be addressed. Recommendation: We recommend that management develop the written comprehensive information security program using the standards set by the Gramm-Leach-Bliley Act including designating a qualified individual responsible for overseeing, implementing, and enforcing the program. Views of responsible officials and planned corrective actions: Management acknowledges this finding and is working toward documenting Gramm-Leach-Bliley Act processes and procedures. The Seminary is working on formal process and procedure guides. The Seminary has done work in this area, but without a procedure guide we realize that the documentation is as key as the work that is being done.
MATERIAL WEAKNESS, Documentation of Cost of Attendance, Information on the federal program: U.S. Department of Education, Assistance Listing No. 84.268; Federal Direct Student Loan Program, Criteria: Students awarded financial aid must meet eligibility requirements including having financial need and total awards that do not exceed that need. Condition: The Seminary did not maintain documentation of accurate cost of attendance used to calculate financial need. Context: Out of a population of 50 students who received aid under the student financial aid cluster, we sampled 10. Within this sample, three of these students were less than full-time. Within their student record, their cost of attendance was noted at the full-time student rate. None of these students received aid in excess of need based on a reduced cost of attendance. Questioned Costs: None Cause: Manual calculations of need are being performed but are not documented within the student management software. Effect: Documentation of cost of attendance within student records is not accurate which could lead to incorrect calculation of need and award of funding. Recommendation: We recommend that management adjust its procedures to document within the student management software the cost of attendance for students who attend less than full-time. Views of responsible officials and planned corrective actions: Management acknowledges this finding and is working on documenting the review of students once they change their status. The calculations are occurring but are not being documented in the system of record.
MATERIAL WEAKNESS, Document Satisfactory Academic Progress Evaluation, Information on the federal program: U.S. Department of Education, Assistance Listing No. 84.268; Federal Direct Student Loan Program, Criteria: Students awarded financial aid must meet certain eligibility requirements including maintaining satisfactory academic progress. Condition: The Seminary did document the evaluation of student satisfactory academic progress. Context: Out of a population of 50 students who received aid under the student financial aid cluster, we sampled 10. No documentation of the annual evaluation of satisfactory academic progress was maintained either within or outside of the student management system. None of the sample of 10 were found to not have achieved satisfactory academic progress. Questioned Costs: None Cause: Manual evaluations are being performed in accordance with the Seminary's policy but are not documented within the student management software. Effect: No documentation exists that the annual evaluation was performed. Recommendation: We recommend that management adjust its procedures to document the annual evaluation either within our outside of the student management software. Views of responsible officials and planned corrective actions: Management acknowledges this finding and is working on documentation to remove this deficiency in the future. Satisfactory academic progress is being calculated, but lack of paperwork by the Seminary made this finding necessary. The Seminary financial aid department will work on documenting processes moving forward.
MATERIAL WEAKNESS, Compliance with Gramm-Leach-Bliley Act, Information on the federal program: U.S. Department of Education, Assistance Listing No. 84.268; Federal Direct Student Loan Program, Criteria: Institutions that participate in Title IV educational assistance programs are subject to the Gramm-Leach-Bliley Act to protect student financial aid information. They are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and includes certain elements. Condition: The Seminary did not have a written program in place by June 9, 2023, the required deadline. Context: The Seminary has an outsourced IT provider which provides services under a service agreement. Questioned Costs: None, Cause: Management was not aware of the documentation requirement. Effect: While the services provided by the IT service provider as well as the Seminary's internal IT department address security concerns and needs within the Seminary, all areas of Gramm-Leach-Bliley might not be addressed. Recommendation: We recommend that management develop the written comprehensive information security program using the standards set by the Gramm-Leach-Bliley Act including designating a qualified individual responsible for overseeing, implementing, and enforcing the program. Views of responsible officials and planned corrective actions: Management acknowledges this finding and is working toward documenting Gramm-Leach-Bliley Act processes and procedures. The Seminary is working on formal process and procedure guides. The Seminary has done work in this area, but without a procedure guide we realize that the documentation is as key as the work that is being done.
MATERIAL WEAKNESS, Documentation of Cost of Attendance, Information on the federal program: U.S. Department of Education, Assistance Listing No. 84.268; Federal Direct Student Loan Program, Criteria: Students awarded financial aid must meet eligibility requirements including having financial need and total awards that do not exceed that need. Condition: The Seminary did not maintain documentation of accurate cost of attendance used to calculate financial need. Context: Out of a population of 50 students who received aid under the student financial aid cluster, we sampled 10. Within this sample, three of these students were less than full-time. Within their student record, their cost of attendance was noted at the full-time student rate. None of these students received aid in excess of need based on a reduced cost of attendance. Questioned Costs: None Cause: Manual calculations of need are being performed but are not documented within the student management software. Effect: Documentation of cost of attendance within student records is not accurate which could lead to incorrect calculation of need and award of funding. Recommendation: We recommend that management adjust its procedures to document within the student management software the cost of attendance for students who attend less than full-time. Views of responsible officials and planned corrective actions: Management acknowledges this finding and is working on documenting the review of students once they change their status. The calculations are occurring but are not being documented in the system of record.