Audit 300926

FY End
2023-06-30
Total Expended
$21.82M
Findings
12
Programs
14
Year: 2023 Accepted: 2024-03-29

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
390062 2023-001 Significant Deficiency - N
390063 2023-001 Significant Deficiency - N
390064 2023-001 Significant Deficiency - N
390065 2023-002 Significant Deficiency - N
390066 2023-002 Significant Deficiency - N
390067 2023-002 Significant Deficiency - N
966504 2023-001 Significant Deficiency - N
966505 2023-001 Significant Deficiency - N
966506 2023-001 Significant Deficiency - N
966507 2023-002 Significant Deficiency - N
966508 2023-002 Significant Deficiency - N
966509 2023-002 Significant Deficiency - N

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $16.02M Yes 2
16.030 National Center on Restorative Justice $1.48M - 0
84.038 Federal Perkins Loan Program $1.33M Yes 2
10.001 Agricultural Research_basic and Applied Research $1.15M Yes 0
19.345 International Programs to Support Democracy, Human Rights and Labor $517,287 - 0
10.700 National Agricultural Library $324,264 - 0
84.033 Federal Work-Study Program $281,349 Yes 2
21.019 Coronavirus Relief Fund $217,848 - 0
84.425 Education Stabilization Fund $180,939 - 0
59.077 Community Navigator Pilot Program $100,028 - 0
21.023 Emergency Rental Assistance Program $76,924 - 0
19.040 Public Diplomacy Programs $61,739 - 0
16.575 Crime Victim Assistance $40,498 - 0
93.604 Assistance for Torture Victims $35,378 - 0

Contacts

Name Title Type
XMKUFB4JA8Y1 Nathaniel Hibler Auditee
8028311204 Mark Laprade Auditor
No contacts on file

Notes to SEFA

Title: 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 principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass-through entity identifying numbers are presented where available. De Minimis Rate Used: N Rate Explanation: The School has not elected to use the 10% de minimis indirect cost rate. The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the federal grant activity of Vermont Law and Graduate School, Inc. and Subsidiary (the School) for the year ended June 30, 2023. The information in this Schedule is presented in accordance with 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 portion of the operations of the School, it is not intended to and does not present the financial position, changes in net assets or cash flows of the School.
Title: Federal Perkins Loan Program Accounting Policies: Expenditures reported on 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. Pass-through entity identifying numbers are presented where available. De Minimis Rate Used: N Rate Explanation: The School has not elected to use the 10% de minimis indirect cost rate. The following sets forth certain balances and activities in the Federal Perkins Loan Program for the year ended June 30, 2023: See Notes to the SEFA for chart/table

Finding Details

Information on the Federal Program: Federal Agency: United States Department of Educations Program Name: Student Financial Assistance Cluster CFDA: 84.268, 84.033, 84.038 Federal Award Identification Number: N/A Federal Award Year: Year Ended June 30, 2023 Specific Requirement: Changes in enrollment status for all students need to be submitted to the National Student Loan Data System (NSLDS) in a timely manner. Condition Found: The School was submitting certain enrollment statuses to the NSLDS with the appropriate change in enrollment status. However, there was a technology issue with the third-party administrator utilized by the School, which was inadvertently overwriting the change in enrollment status as submitted by the School. Questioned Costs: None. Cause and Effect: The School was not checking to verify the statuses as submitted by the third party administrator as being submitted correctly to the NSDLS appropriately. Recommendation: We recommend the School spot-check a sample of submissions throughout the year to ensure the enrollment statuses are appropriate and that they were not changed by the third party administrator. Repeat Finding: No. Views of a Responsible Official and Correction Action Plan: See Corrective Action Plan.
Information on the Federal Program: Federal Agency: United States Department of Educations Program Name: Student Financial Assistance Cluster CFDA: 84.268, 84.033, 84.038 Federal Award Identification Number: N/A Federal Award Year: Year Ended June 30, 2023 Specific Requirement: Changes in enrollment status for all students need to be submitted to the National Student Loan Data System (NSLDS) in a timely manner. Condition Found: The School was submitting certain enrollment statuses to the NSLDS with the appropriate change in enrollment status. However, there was a technology issue with the third-party administrator utilized by the School, which was inadvertently overwriting the change in enrollment status as submitted by the School. Questioned Costs: None. Cause and Effect: The School was not checking to verify the statuses as submitted by the third party administrator as being submitted correctly to the NSDLS appropriately. Recommendation: We recommend the School spot-check a sample of submissions throughout the year to ensure the enrollment statuses are appropriate and that they were not changed by the third party administrator. Repeat Finding: No. Views of a Responsible Official and Correction Action Plan: See Corrective Action Plan.
Information on the Federal Program: Federal Agency: United States Department of Educations Program Name: Student Financial Assistance Cluster CFDA: 84.268, 84.033, 84.038 Federal Award Identification Number: N/A Federal Award Year: Year Ended June 30, 2023 Specific Requirement: Changes in enrollment status for all students need to be submitted to the National Student Loan Data System (NSLDS) in a timely manner. Condition Found: The School was submitting certain enrollment statuses to the NSLDS with the appropriate change in enrollment status. However, there was a technology issue with the third-party administrator utilized by the School, which was inadvertently overwriting the change in enrollment status as submitted by the School. Questioned Costs: None. Cause and Effect: The School was not checking to verify the statuses as submitted by the third party administrator as being submitted correctly to the NSDLS appropriately. Recommendation: We recommend the School spot-check a sample of submissions throughout the year to ensure the enrollment statuses are appropriate and that they were not changed by the third party administrator. Repeat Finding: No. Views of a Responsible Official and Correction Action Plan: See Corrective Action Plan.
Information on the Federal Program: Federal Agency: United States Department of Educations Program Name: Student Financial Assistance Cluster CFDA: 84.268, 84.033, 84.038 Federal Award Identification Number: N/A Federal Award Year: Year Ended June 30, 2023 Specific Requirement: The School outsources the billings, collections and due diligence for the Federal Perkins Loan Program to a third party, University Accounting Services (UAS). UAS engages an independent accountant to perform a compliance examination of UAS’s compliance with those requirements. The School could not obtain an audit report for the servicer of its Perkins Loans program, University Accounting Services (UAS). Condition Found: The School could not obtain the compliance examination report due to the fact that the compliance examination was not completed timely. Questioned Costs: None. Cause and Effect: UAS’s compliance with the billings, collections and due diligence for the Federal Perkins Loan Program for the School could not be determined. Recommendation: We recommend management work with their UAS representative to obtain the UAS compliance examination report on a timely basis each year. If UAS is unable to provide the compliance examination report on a timely basis, we recommend management consider finding another vendor to assist with the billings, collections and due diligence for the Federal Perkins Loan Program. Repeat Finding: No. Views of a Responsible Official and Correction Action Plan:See Corrective Action Plan.
Information on the Federal Program: Federal Agency: United States Department of Educations Program Name: Student Financial Assistance Cluster CFDA: 84.268, 84.033, 84.038 Federal Award Identification Number: N/A Federal Award Year: Year Ended June 30, 2023 Specific Requirement: The School outsources the billings, collections and due diligence for the Federal Perkins Loan Program to a third party, University Accounting Services (UAS). UAS engages an independent accountant to perform a compliance examination of UAS’s compliance with those requirements. The School could not obtain an audit report for the servicer of its Perkins Loans program, University Accounting Services (UAS). Condition Found: The School could not obtain the compliance examination report due to the fact that the compliance examination was not completed timely. Questioned Costs: None. Cause and Effect: UAS’s compliance with the billings, collections and due diligence for the Federal Perkins Loan Program for the School could not be determined. Recommendation: We recommend management work with their UAS representative to obtain the UAS compliance examination report on a timely basis each year. If UAS is unable to provide the compliance examination report on a timely basis, we recommend management consider finding another vendor to assist with the billings, collections and due diligence for the Federal Perkins Loan Program. Repeat Finding: No. Views of a Responsible Official and Correction Action Plan:See Corrective Action Plan.
Information on the Federal Program: Federal Agency: United States Department of Educations Program Name: Student Financial Assistance Cluster CFDA: 84.268, 84.033, 84.038 Federal Award Identification Number: N/A Federal Award Year: Year Ended June 30, 2023 Specific Requirement: The School outsources the billings, collections and due diligence for the Federal Perkins Loan Program to a third party, University Accounting Services (UAS). UAS engages an independent accountant to perform a compliance examination of UAS’s compliance with those requirements. The School could not obtain an audit report for the servicer of its Perkins Loans program, University Accounting Services (UAS). Condition Found: The School could not obtain the compliance examination report due to the fact that the compliance examination was not completed timely. Questioned Costs: None. Cause and Effect: UAS’s compliance with the billings, collections and due diligence for the Federal Perkins Loan Program for the School could not be determined. Recommendation: We recommend management work with their UAS representative to obtain the UAS compliance examination report on a timely basis each year. If UAS is unable to provide the compliance examination report on a timely basis, we recommend management consider finding another vendor to assist with the billings, collections and due diligence for the Federal Perkins Loan Program. Repeat Finding: No. Views of a Responsible Official and Correction Action Plan:See Corrective Action Plan.
Information on the Federal Program: Federal Agency: United States Department of Educations Program Name: Student Financial Assistance Cluster CFDA: 84.268, 84.033, 84.038 Federal Award Identification Number: N/A Federal Award Year: Year Ended June 30, 2023 Specific Requirement: Changes in enrollment status for all students need to be submitted to the National Student Loan Data System (NSLDS) in a timely manner. Condition Found: The School was submitting certain enrollment statuses to the NSLDS with the appropriate change in enrollment status. However, there was a technology issue with the third-party administrator utilized by the School, which was inadvertently overwriting the change in enrollment status as submitted by the School. Questioned Costs: None. Cause and Effect: The School was not checking to verify the statuses as submitted by the third party administrator as being submitted correctly to the NSDLS appropriately. Recommendation: We recommend the School spot-check a sample of submissions throughout the year to ensure the enrollment statuses are appropriate and that they were not changed by the third party administrator. Repeat Finding: No. Views of a Responsible Official and Correction Action Plan: See Corrective Action Plan.
Information on the Federal Program: Federal Agency: United States Department of Educations Program Name: Student Financial Assistance Cluster CFDA: 84.268, 84.033, 84.038 Federal Award Identification Number: N/A Federal Award Year: Year Ended June 30, 2023 Specific Requirement: Changes in enrollment status for all students need to be submitted to the National Student Loan Data System (NSLDS) in a timely manner. Condition Found: The School was submitting certain enrollment statuses to the NSLDS with the appropriate change in enrollment status. However, there was a technology issue with the third-party administrator utilized by the School, which was inadvertently overwriting the change in enrollment status as submitted by the School. Questioned Costs: None. Cause and Effect: The School was not checking to verify the statuses as submitted by the third party administrator as being submitted correctly to the NSDLS appropriately. Recommendation: We recommend the School spot-check a sample of submissions throughout the year to ensure the enrollment statuses are appropriate and that they were not changed by the third party administrator. Repeat Finding: No. Views of a Responsible Official and Correction Action Plan: See Corrective Action Plan.
Information on the Federal Program: Federal Agency: United States Department of Educations Program Name: Student Financial Assistance Cluster CFDA: 84.268, 84.033, 84.038 Federal Award Identification Number: N/A Federal Award Year: Year Ended June 30, 2023 Specific Requirement: Changes in enrollment status for all students need to be submitted to the National Student Loan Data System (NSLDS) in a timely manner. Condition Found: The School was submitting certain enrollment statuses to the NSLDS with the appropriate change in enrollment status. However, there was a technology issue with the third-party administrator utilized by the School, which was inadvertently overwriting the change in enrollment status as submitted by the School. Questioned Costs: None. Cause and Effect: The School was not checking to verify the statuses as submitted by the third party administrator as being submitted correctly to the NSDLS appropriately. Recommendation: We recommend the School spot-check a sample of submissions throughout the year to ensure the enrollment statuses are appropriate and that they were not changed by the third party administrator. Repeat Finding: No. Views of a Responsible Official and Correction Action Plan: See Corrective Action Plan.
Information on the Federal Program: Federal Agency: United States Department of Educations Program Name: Student Financial Assistance Cluster CFDA: 84.268, 84.033, 84.038 Federal Award Identification Number: N/A Federal Award Year: Year Ended June 30, 2023 Specific Requirement: The School outsources the billings, collections and due diligence for the Federal Perkins Loan Program to a third party, University Accounting Services (UAS). UAS engages an independent accountant to perform a compliance examination of UAS’s compliance with those requirements. The School could not obtain an audit report for the servicer of its Perkins Loans program, University Accounting Services (UAS). Condition Found: The School could not obtain the compliance examination report due to the fact that the compliance examination was not completed timely. Questioned Costs: None. Cause and Effect: UAS’s compliance with the billings, collections and due diligence for the Federal Perkins Loan Program for the School could not be determined. Recommendation: We recommend management work with their UAS representative to obtain the UAS compliance examination report on a timely basis each year. If UAS is unable to provide the compliance examination report on a timely basis, we recommend management consider finding another vendor to assist with the billings, collections and due diligence for the Federal Perkins Loan Program. Repeat Finding: No. Views of a Responsible Official and Correction Action Plan:See Corrective Action Plan.
Information on the Federal Program: Federal Agency: United States Department of Educations Program Name: Student Financial Assistance Cluster CFDA: 84.268, 84.033, 84.038 Federal Award Identification Number: N/A Federal Award Year: Year Ended June 30, 2023 Specific Requirement: The School outsources the billings, collections and due diligence for the Federal Perkins Loan Program to a third party, University Accounting Services (UAS). UAS engages an independent accountant to perform a compliance examination of UAS’s compliance with those requirements. The School could not obtain an audit report for the servicer of its Perkins Loans program, University Accounting Services (UAS). Condition Found: The School could not obtain the compliance examination report due to the fact that the compliance examination was not completed timely. Questioned Costs: None. Cause and Effect: UAS’s compliance with the billings, collections and due diligence for the Federal Perkins Loan Program for the School could not be determined. Recommendation: We recommend management work with their UAS representative to obtain the UAS compliance examination report on a timely basis each year. If UAS is unable to provide the compliance examination report on a timely basis, we recommend management consider finding another vendor to assist with the billings, collections and due diligence for the Federal Perkins Loan Program. Repeat Finding: No. Views of a Responsible Official and Correction Action Plan:See Corrective Action Plan.
Information on the Federal Program: Federal Agency: United States Department of Educations Program Name: Student Financial Assistance Cluster CFDA: 84.268, 84.033, 84.038 Federal Award Identification Number: N/A Federal Award Year: Year Ended June 30, 2023 Specific Requirement: The School outsources the billings, collections and due diligence for the Federal Perkins Loan Program to a third party, University Accounting Services (UAS). UAS engages an independent accountant to perform a compliance examination of UAS’s compliance with those requirements. The School could not obtain an audit report for the servicer of its Perkins Loans program, University Accounting Services (UAS). Condition Found: The School could not obtain the compliance examination report due to the fact that the compliance examination was not completed timely. Questioned Costs: None. Cause and Effect: UAS’s compliance with the billings, collections and due diligence for the Federal Perkins Loan Program for the School could not be determined. Recommendation: We recommend management work with their UAS representative to obtain the UAS compliance examination report on a timely basis each year. If UAS is unable to provide the compliance examination report on a timely basis, we recommend management consider finding another vendor to assist with the billings, collections and due diligence for the Federal Perkins Loan Program. Repeat Finding: No. Views of a Responsible Official and Correction Action Plan:See Corrective Action Plan.