FAC Explorer

Audit 300763

FY End
2023-06-30
Total Expended
$60.27M
Findings
6
Programs
10
Organization: Tusculum University (TN)
Year: 2023 Accepted: 2024-03-29
Auditor: Blackburn Childers & Steagall Plc

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
389878 2023-002 Material Weakness - N
389879 2023-003 Significant Deficiency Yes N
389880 2023-003 Significant Deficiency Yes N
966320 2023-002 Material Weakness - N
966321 2023-003 Significant Deficiency Yes N
966322 2023-003 Significant Deficiency Yes N

Programs

ALN Program Spent Major Findings
10.766 Community Facilities Loans and Grants $47.55M Yes 0
84.268 Federal Direct Student Loans $7.57M Yes 2
84.063 Federal Pell Grant Program $2.57M Yes 1
84.047 Trio_upward Bound $1.15M - 0
84.044 Trio_talent Search $614,399 - 0
84.042 Trio_student Support Services $589,780 - 0
84.007 Federal Supplemental Educational Opportunity Grants $112,250 Yes 0
84.033 Federal Work-Study Program $82,044 Yes 0
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $18,860 Yes 0
84.038 Federal Perkins Loan Program $184 Yes 0

Contacts

Name Title Type
WLC1GBMGN9N7 Benita Bare Auditee
4236367215 Chad Kisner Auditor
No contacts on file

Notes to SEFA

Title: Note A: Basis of Presentation Accounting Policies: Expenditures reported on the SEFA 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. De Minimis Rate Used: N Rate Explanation: The University has elected not to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. The accompanying SEFA includes the federal award activity of the University under programs of the federal government for the year ended June 30, 2023. The information in this SEFA 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 SEFA presents only a selected portion of the operations of the University, it is not intended to, and does not present, the financial position, changes in net assets or cash flows of the University.
Title: Note C: Federal Perkins Loan Program Accounting Policies: Expenditures reported on the SEFA 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. De Minimis Rate Used: N Rate Explanation: The University has elected not to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. The University administers the Perkins Loan Program. For purposes of the schedule, the amount reported includes the outstanding loan balance at the beginning of the fiscal year. Due to regulation changes, no further loans can be made from the program and no administrative cost allowance can be taken from the loan fund. See the Notes to the SEFA for table. Schools began the wind down process to liquidate the program during the year ending June 30, 2023; prior to this period, liquidation had been voluntary. The University has completed the Perkins liquidation process as of June 30, 2023. See the Independent Perkins Program Liquidation Audit Report on page 46.
Title: Note D: U.S. Department of Agriculture Community Facilities Loans Accounting Policies: Expenditures reported on the SEFA 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. De Minimis Rate Used: N Rate Explanation: The University has elected not to use the 10 percent de minimis indirect cost rate allowed under the Uniform Guidance. The federal financial assistance from the U.S. Department of Agriculture (USDA), Community Facilities Loans program, is in the form of interest-bearing loans to be repaid in accordance with the terms of the agreements. Because of the continuing compliance requirements, the total outstanding loan balances at the beginning of the fiscal year plus any new loans are reported on the schedule. See the Notes to the SEFA for table. The USDA committed up to $49,799,190 toward the funding of the approved projects. In FY2022, USDA re-amortized the loan to increase the principal amount by the amount of interest that was deferred due to the coronavirus pandemic. After the deferral, the new outstanding principal balance for fiscal year 2022 was $47,553,064.

Finding Details

Finding 2023-002
2023-002 Material Weakness: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Criteria: In accordance with 16 CFR 314.4, a University shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue and must contain all of the elements that are further described in 16 CFR 314.4. Statement of Condition: During the 2023 audit, it was noted that the University’s Gramm-Leach-Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University for the 2023 year. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The 2023 audit included testing of the University’s Gramm-Leach-Bliley Act Policy as outlined in Part 5 of the Compliance Supplement including the application of this program for the year. Cause and Effect: Due to oversight by the director of the program, the GLBA policy was not reviewed and updated for changes to the program as required by the Compliance Supplement. Recommendation: The University should update their Gramm-Leach-Bliley Act Policy to be in accordance with the requirements and put in place effective controls and practices to ensure the policy is monitored in a way to ensure it is administered effectively. View of Responsible Officials: The University concurs with this finding. The University has begun the process of updating policies and procedures to comply with all of the latest GLBA policies. The university is currently in the process of finishing the risk assessment and will update all applicable policies and procedures to align with the GLBA requirements.
Finding 2023-003
2023-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat finding of 2022-001) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, once the Enrollment Reporting roster file is received from the NSLDS, the institution must update the Enrollment Reporting roster file for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes to NSLDS. Statement of Condition: During the audit, it was noted that the University incorrectly reported student enrollment status for changes in enrollment. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 12, indicating an error rate of 30.00%. Cause and Effect: Due to lapses in communication between departments, in certain instances, the University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct enrollment status is reported to NSLDS. View of Responsible Officials: The University concurs with this finding. Student enrollment status is pulled monthly into a report and submitted to clearinghouse out of Colleague. The failure of the system to pull the correct enrollment status for changes in enrollment is noted and the Director of Financial Aid and the Registrar of the university will work in conjecture to determine why the report that pulls out of the system is not pulling accurate student enrollment status for changes in enrollment. Once fixed, we will continue to monitor by pulling a list of random sampling of students out of each monthly report to ensure that enrollment status is being reported correctly.
Finding 2023-003
2023-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat finding of 2022-001) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, once the Enrollment Reporting roster file is received from the NSLDS, the institution must update the Enrollment Reporting roster file for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes to NSLDS. Statement of Condition: During the audit, it was noted that the University incorrectly reported student enrollment status for changes in enrollment. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 12, indicating an error rate of 30.00%. Cause and Effect: Due to lapses in communication between departments, in certain instances, the University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct enrollment status is reported to NSLDS. View of Responsible Officials: The University concurs with this finding. Student enrollment status is pulled monthly into a report and submitted to clearinghouse out of Colleague. The failure of the system to pull the correct enrollment status for changes in enrollment is noted and the Director of Financial Aid and the Registrar of the university will work in conjecture to determine why the report that pulls out of the system is not pulling accurate student enrollment status for changes in enrollment. Once fixed, we will continue to monitor by pulling a list of random sampling of students out of each monthly report to ensure that enrollment status is being reported correctly.
Finding 2023-002
2023-002 Material Weakness: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Criteria: In accordance with 16 CFR 314.4, a University shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue and must contain all of the elements that are further described in 16 CFR 314.4. Statement of Condition: During the 2023 audit, it was noted that the University’s Gramm-Leach-Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University for the 2023 year. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The 2023 audit included testing of the University’s Gramm-Leach-Bliley Act Policy as outlined in Part 5 of the Compliance Supplement including the application of this program for the year. Cause and Effect: Due to oversight by the director of the program, the GLBA policy was not reviewed and updated for changes to the program as required by the Compliance Supplement. Recommendation: The University should update their Gramm-Leach-Bliley Act Policy to be in accordance with the requirements and put in place effective controls and practices to ensure the policy is monitored in a way to ensure it is administered effectively. View of Responsible Officials: The University concurs with this finding. The University has begun the process of updating policies and procedures to comply with all of the latest GLBA policies. The university is currently in the process of finishing the risk assessment and will update all applicable policies and procedures to align with the GLBA requirements.
Finding 2023-003
2023-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat finding of 2022-001) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, once the Enrollment Reporting roster file is received from the NSLDS, the institution must update the Enrollment Reporting roster file for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes to NSLDS. Statement of Condition: During the audit, it was noted that the University incorrectly reported student enrollment status for changes in enrollment. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 12, indicating an error rate of 30.00%. Cause and Effect: Due to lapses in communication between departments, in certain instances, the University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct enrollment status is reported to NSLDS. View of Responsible Officials: The University concurs with this finding. Student enrollment status is pulled monthly into a report and submitted to clearinghouse out of Colleague. The failure of the system to pull the correct enrollment status for changes in enrollment is noted and the Director of Financial Aid and the Registrar of the university will work in conjecture to determine why the report that pulls out of the system is not pulling accurate student enrollment status for changes in enrollment. Once fixed, we will continue to monitor by pulling a list of random sampling of students out of each monthly report to ensure that enrollment status is being reported correctly.
Finding 2023-003
2023-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat finding of 2022-001) Criteria: In accordance with 34 CFR 685.309(b) and 34 CFR section 690.83(b)(2), for Direct Loans and Pell grants, respectively, once the Enrollment Reporting roster file is received from the NSLDS, the institution must update the Enrollment Reporting roster file for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes to NSLDS. Statement of Condition: During the audit, it was noted that the University incorrectly reported student enrollment status for changes in enrollment. Questioned Costs: Such information is not applicable for this finding since it is nonmonetary in nature. Perspective Information: The audit included a detailed testing of 40 student files, of which this significant deficiency applies to 12, indicating an error rate of 30.00%. Cause and Effect: Due to lapses in communication between departments, in certain instances, the University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in misrepresentation within the NSLDS system. Recommendation: The University should ensure that the correct enrollment status is reported to NSLDS. View of Responsible Officials: The University concurs with this finding. Student enrollment status is pulled monthly into a report and submitted to clearinghouse out of Colleague. The failure of the system to pull the correct enrollment status for changes in enrollment is noted and the Director of Financial Aid and the Registrar of the university will work in conjecture to determine why the report that pulls out of the system is not pulling accurate student enrollment status for changes in enrollment. Once fixed, we will continue to monitor by pulling a list of random sampling of students out of each monthly report to ensure that enrollment status is being reported correctly.