Finding 2022-001 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: In accordance with Federal Regulations 34 CFR 668.171, an institution administering Federal Student Financial Aid must obtain a minimum composite score of 1.5 to fulfill the requirements of financial responsibility and be above 1.0 to be considered for ?Zone Alternative? treatment. Condition: For the year under audit, the College?s financial responsibility composite score will fail to meet the numeric standard of responsibility as set by the Department of Education (ED). However, when an institution cannot meet the criteria for financial responsibility through the composite score, ED provides other ways to comply with this standard. One way the College can comply with this standard is by obtaining an irrevocable letter of credit from a bank. In addition, the College must make Federal Student Financial Aid disbursements under the heightened cash monitoring method described in 34 CFR 668.162. Context: The College?s ED financial responsibility composite fell below 1.0 in previous years and was between 1.0 and 1.5 in the past two fiscal years. The College has not been able to bring its score above 1.5, therefore will continue to have to obtain a letter of credit and follow heightened cash monitoring procedures. Effect: The College will have to obtain a letter of credit and follow heightened cash monitoring procedures. Additionally, the College may be required to provide further documentation of its financial plans and progress to accreditation agencies in which it may seek accreditation through. Questioned Costs: None noted. Cause: Bethany College does not have proper processes and related controls in place to ensure that the required financial responsibility composite score does not fall below 1.5. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: We recommend that the College implement controls and processes for monitoring budgets that include all expenses including non-cash transactions in order to adequately anticipate the revenue needed to cover the expenses of the College. We recommend that the College evaluate all of its cost centers and revenue streams to ensure that the College is maximizing fiscal efficiency while still achieving the mission of the College. Views Of Responsible Officials (Unaudited): The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: August 2023 Contact Person: Krista Harris, Chief Financial Officer
Finding 2022-004 - Significant Deficiency, Compliance Federal Award No. 84.268, 84.007, 84.379, 84.063 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to the 2021-2022 Federal Student Aid Handbook a College must exclude institutionally scheduled breaks of five or more consecutive days from the Return to Title IV (R2T4) calculation as periods of nonattendance. The length of the scheduled break is determined by taking the last day that class is held before a scheduled break ? the next day is the first day of the scheduled break and the last day of the scheduled break is the day before the next class. Condition: In our nonstatistical sample of six students, it was noted for two students that the College used 105 days as the total days in the semester for the Fall 2021 semester when the College should have used 107 days as the total days in the semester for the Fall 2021 semester in the R2T4 calculation due to improperly counting two extra days for the institutionally scheduled break. Context: The College counted the last day of classes of November 19th, 2021 before the Thanksgiving break and the first day that classes resumed of November 29th, 2021 totaling 11 days as an institutionally scheduled break that reduced the total days used in the R2T4 calculation for the Fall 2021 semester. However, the College should have only used 9 days as the institutionally scheduled break was from November 20th, 2021 through November 28th, 2021. Effect: The improper calculation of the institutionally scheduled break dates resulted in the students retaining additional aid. Questioned Costs: Known questioned costs for the two students in which the exceptions were noted totaled $125. Likely questioned costs were not expected to exceed $1,000 for the R2T4 calculations performed in the Fall 2021 semester. Cause: Bethany College did not have proper processes and related controls in place to ensure that the correct number of days were used for institutionally scheduled breaks in the Fall 2021 semester. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to calculate the number of days included in institutionally scheduled breaks for the R2T4 calculation. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through adding additional review of the calculation of institutionally scheduled breaks and total days used in the R2T4 calculations. Completion Date: May 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-006 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.268, 84.033, 84.038, 84.379, 84.063 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: Per guidance in 34 CF 668.46(b), 34 CFR 668.49(b), and 34 CFR 668.41(e) the College is required to distribute its Annual Security Report and Annual Fire Safety Report by October 1st of each year to all enrolled students and current employees. Condition/Context: The College did not distribute its report due on October 1, 2022 on or before October 1, 2022 as the report was not completed until late October 2022. Effect: The College did not timely inform the enrolled students and current employees of the required statistics and information related to campus security and fire safety for the preceding year. Questioned Costs: There were no questioned costs identified as a result of this finding. Cause: The College was delayed in gathering information needed to prepare the report for distribution. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the College implement controls and processes to ensure that the Annual Security Report and Annual Fire Safety report is distributed timely. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through distributing the Annual Security Report and Fire Safety Report as well as establishing appropriate timelines for distribution in future years. Completion Date: October 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-001 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: In accordance with Federal Regulations 34 CFR 668.171, an institution administering Federal Student Financial Aid must obtain a minimum composite score of 1.5 to fulfill the requirements of financial responsibility and be above 1.0 to be considered for ?Zone Alternative? treatment. Condition: For the year under audit, the College?s financial responsibility composite score will fail to meet the numeric standard of responsibility as set by the Department of Education (ED). However, when an institution cannot meet the criteria for financial responsibility through the composite score, ED provides other ways to comply with this standard. One way the College can comply with this standard is by obtaining an irrevocable letter of credit from a bank. In addition, the College must make Federal Student Financial Aid disbursements under the heightened cash monitoring method described in 34 CFR 668.162. Context: The College?s ED financial responsibility composite fell below 1.0 in previous years and was between 1.0 and 1.5 in the past two fiscal years. The College has not been able to bring its score above 1.5, therefore will continue to have to obtain a letter of credit and follow heightened cash monitoring procedures. Effect: The College will have to obtain a letter of credit and follow heightened cash monitoring procedures. Additionally, the College may be required to provide further documentation of its financial plans and progress to accreditation agencies in which it may seek accreditation through. Questioned Costs: None noted. Cause: Bethany College does not have proper processes and related controls in place to ensure that the required financial responsibility composite score does not fall below 1.5. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: We recommend that the College implement controls and processes for monitoring budgets that include all expenses including non-cash transactions in order to adequately anticipate the revenue needed to cover the expenses of the College. We recommend that the College evaluate all of its cost centers and revenue streams to ensure that the College is maximizing fiscal efficiency while still achieving the mission of the College. Views Of Responsible Officials (Unaudited): The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: August 2023 Contact Person: Krista Harris, Chief Financial Officer
Finding 2022-003 - Significant Deficiency, Compliance Federal Award No. 84.268 U.S. Department Of Education Student Financial Aid Cluster - Special Tests and Provisions Criteria: According to the 2021-2022 COD Technical Reference and 2021-2022 SFA Handbook, the College must report accurate disbursement dates to Common Origination Disbursement (COD) for all direct loan disbursements made to students. Condition: In our nonstatistical sample of 40 students, we noted 24 students whose disbursement dates listed in the College?s student records (8/27/21) differed by one day from the date of disbursement dates reported to COD (8/28/21) for the students? direct loans disbursed in the Fall 2021 semester. Context: The students in question had anticipated disbursement dates of 8/28/21 that were not updated for the actual date of disbursement once the disbursements were made by the College. Effect: Improperly reported disbursement dates could impact the amount of interest charged to a student. Questioned Costs: There were no questioned costs to report as this finding relates only to COD reporting. Cause: Bethany College did not have proper processes and related controls in place to ensure that the disbursement dates reported in COD agreed with the disbursement dates in the College?s records. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: The Financial Aid department should put in place controls that would ensure that all disbursements would be processed on the anticipated disbursement dates as planned and controls that would detect if disbursements were processed at a later or earlier date and adjustments to amounts reported to COD were necessary. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to report disbursement dates to COD. Completion Date: January 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-004 - Significant Deficiency, Compliance Federal Award No. 84.268, 84.007, 84.379, 84.063 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to the 2021-2022 Federal Student Aid Handbook a College must exclude institutionally scheduled breaks of five or more consecutive days from the Return to Title IV (R2T4) calculation as periods of nonattendance. The length of the scheduled break is determined by taking the last day that class is held before a scheduled break ? the next day is the first day of the scheduled break and the last day of the scheduled break is the day before the next class. Condition: In our nonstatistical sample of six students, it was noted for two students that the College used 105 days as the total days in the semester for the Fall 2021 semester when the College should have used 107 days as the total days in the semester for the Fall 2021 semester in the R2T4 calculation due to improperly counting two extra days for the institutionally scheduled break. Context: The College counted the last day of classes of November 19th, 2021 before the Thanksgiving break and the first day that classes resumed of November 29th, 2021 totaling 11 days as an institutionally scheduled break that reduced the total days used in the R2T4 calculation for the Fall 2021 semester. However, the College should have only used 9 days as the institutionally scheduled break was from November 20th, 2021 through November 28th, 2021. Effect: The improper calculation of the institutionally scheduled break dates resulted in the students retaining additional aid. Questioned Costs: Known questioned costs for the two students in which the exceptions were noted totaled $125. Likely questioned costs were not expected to exceed $1,000 for the R2T4 calculations performed in the Fall 2021 semester. Cause: Bethany College did not have proper processes and related controls in place to ensure that the correct number of days were used for institutionally scheduled breaks in the Fall 2021 semester. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to calculate the number of days included in institutionally scheduled breaks for the R2T4 calculation. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through adding additional review of the calculation of institutionally scheduled breaks and total days used in the R2T4 calculations. Completion Date: May 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-006 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.268, 84.033, 84.038, 84.379, 84.063 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: Per guidance in 34 CF 668.46(b), 34 CFR 668.49(b), and 34 CFR 668.41(e) the College is required to distribute its Annual Security Report and Annual Fire Safety Report by October 1st of each year to all enrolled students and current employees. Condition/Context: The College did not distribute its report due on October 1, 2022 on or before October 1, 2022 as the report was not completed until late October 2022. Effect: The College did not timely inform the enrolled students and current employees of the required statistics and information related to campus security and fire safety for the preceding year. Questioned Costs: There were no questioned costs identified as a result of this finding. Cause: The College was delayed in gathering information needed to prepare the report for distribution. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the College implement controls and processes to ensure that the Annual Security Report and Annual Fire Safety report is distributed timely. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through distributing the Annual Security Report and Fire Safety Report as well as establishing appropriate timelines for distribution in future years. Completion Date: October 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-001 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: In accordance with Federal Regulations 34 CFR 668.171, an institution administering Federal Student Financial Aid must obtain a minimum composite score of 1.5 to fulfill the requirements of financial responsibility and be above 1.0 to be considered for ?Zone Alternative? treatment. Condition: For the year under audit, the College?s financial responsibility composite score will fail to meet the numeric standard of responsibility as set by the Department of Education (ED). However, when an institution cannot meet the criteria for financial responsibility through the composite score, ED provides other ways to comply with this standard. One way the College can comply with this standard is by obtaining an irrevocable letter of credit from a bank. In addition, the College must make Federal Student Financial Aid disbursements under the heightened cash monitoring method described in 34 CFR 668.162. Context: The College?s ED financial responsibility composite fell below 1.0 in previous years and was between 1.0 and 1.5 in the past two fiscal years. The College has not been able to bring its score above 1.5, therefore will continue to have to obtain a letter of credit and follow heightened cash monitoring procedures. Effect: The College will have to obtain a letter of credit and follow heightened cash monitoring procedures. Additionally, the College may be required to provide further documentation of its financial plans and progress to accreditation agencies in which it may seek accreditation through. Questioned Costs: None noted. Cause: Bethany College does not have proper processes and related controls in place to ensure that the required financial responsibility composite score does not fall below 1.5. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: We recommend that the College implement controls and processes for monitoring budgets that include all expenses including non-cash transactions in order to adequately anticipate the revenue needed to cover the expenses of the College. We recommend that the College evaluate all of its cost centers and revenue streams to ensure that the College is maximizing fiscal efficiency while still achieving the mission of the College. Views Of Responsible Officials (Unaudited): The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: August 2023 Contact Person: Krista Harris, Chief Financial Officer
Finding 2022-006 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.268, 84.033, 84.038, 84.379, 84.063 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: Per guidance in 34 CF 668.46(b), 34 CFR 668.49(b), and 34 CFR 668.41(e) the College is required to distribute its Annual Security Report and Annual Fire Safety Report by October 1st of each year to all enrolled students and current employees. Condition/Context: The College did not distribute its report due on October 1, 2022 on or before October 1, 2022 as the report was not completed until late October 2022. Effect: The College did not timely inform the enrolled students and current employees of the required statistics and information related to campus security and fire safety for the preceding year. Questioned Costs: There were no questioned costs identified as a result of this finding. Cause: The College was delayed in gathering information needed to prepare the report for distribution. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the College implement controls and processes to ensure that the Annual Security Report and Annual Fire Safety report is distributed timely. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through distributing the Annual Security Report and Fire Safety Report as well as establishing appropriate timelines for distribution in future years. Completion Date: October 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-001 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: In accordance with Federal Regulations 34 CFR 668.171, an institution administering Federal Student Financial Aid must obtain a minimum composite score of 1.5 to fulfill the requirements of financial responsibility and be above 1.0 to be considered for ?Zone Alternative? treatment. Condition: For the year under audit, the College?s financial responsibility composite score will fail to meet the numeric standard of responsibility as set by the Department of Education (ED). However, when an institution cannot meet the criteria for financial responsibility through the composite score, ED provides other ways to comply with this standard. One way the College can comply with this standard is by obtaining an irrevocable letter of credit from a bank. In addition, the College must make Federal Student Financial Aid disbursements under the heightened cash monitoring method described in 34 CFR 668.162. Context: The College?s ED financial responsibility composite fell below 1.0 in previous years and was between 1.0 and 1.5 in the past two fiscal years. The College has not been able to bring its score above 1.5, therefore will continue to have to obtain a letter of credit and follow heightened cash monitoring procedures. Effect: The College will have to obtain a letter of credit and follow heightened cash monitoring procedures. Additionally, the College may be required to provide further documentation of its financial plans and progress to accreditation agencies in which it may seek accreditation through. Questioned Costs: None noted. Cause: Bethany College does not have proper processes and related controls in place to ensure that the required financial responsibility composite score does not fall below 1.5. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: We recommend that the College implement controls and processes for monitoring budgets that include all expenses including non-cash transactions in order to adequately anticipate the revenue needed to cover the expenses of the College. We recommend that the College evaluate all of its cost centers and revenue streams to ensure that the College is maximizing fiscal efficiency while still achieving the mission of the College. Views Of Responsible Officials (Unaudited): The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: August 2023 Contact Person: Krista Harris, Chief Financial Officer
Finding 2022-006 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.268, 84.033, 84.038, 84.379, 84.063 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: Per guidance in 34 CF 668.46(b), 34 CFR 668.49(b), and 34 CFR 668.41(e) the College is required to distribute its Annual Security Report and Annual Fire Safety Report by October 1st of each year to all enrolled students and current employees. Condition/Context: The College did not distribute its report due on October 1, 2022 on or before October 1, 2022 as the report was not completed until late October 2022. Effect: The College did not timely inform the enrolled students and current employees of the required statistics and information related to campus security and fire safety for the preceding year. Questioned Costs: There were no questioned costs identified as a result of this finding. Cause: The College was delayed in gathering information needed to prepare the report for distribution. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the College implement controls and processes to ensure that the Annual Security Report and Annual Fire Safety report is distributed timely. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through distributing the Annual Security Report and Fire Safety Report as well as establishing appropriate timelines for distribution in future years. Completion Date: October 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-001 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: In accordance with Federal Regulations 34 CFR 668.171, an institution administering Federal Student Financial Aid must obtain a minimum composite score of 1.5 to fulfill the requirements of financial responsibility and be above 1.0 to be considered for ?Zone Alternative? treatment. Condition: For the year under audit, the College?s financial responsibility composite score will fail to meet the numeric standard of responsibility as set by the Department of Education (ED). However, when an institution cannot meet the criteria for financial responsibility through the composite score, ED provides other ways to comply with this standard. One way the College can comply with this standard is by obtaining an irrevocable letter of credit from a bank. In addition, the College must make Federal Student Financial Aid disbursements under the heightened cash monitoring method described in 34 CFR 668.162. Context: The College?s ED financial responsibility composite fell below 1.0 in previous years and was between 1.0 and 1.5 in the past two fiscal years. The College has not been able to bring its score above 1.5, therefore will continue to have to obtain a letter of credit and follow heightened cash monitoring procedures. Effect: The College will have to obtain a letter of credit and follow heightened cash monitoring procedures. Additionally, the College may be required to provide further documentation of its financial plans and progress to accreditation agencies in which it may seek accreditation through. Questioned Costs: None noted. Cause: Bethany College does not have proper processes and related controls in place to ensure that the required financial responsibility composite score does not fall below 1.5. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: We recommend that the College implement controls and processes for monitoring budgets that include all expenses including non-cash transactions in order to adequately anticipate the revenue needed to cover the expenses of the College. We recommend that the College evaluate all of its cost centers and revenue streams to ensure that the College is maximizing fiscal efficiency while still achieving the mission of the College. Views Of Responsible Officials (Unaudited): The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: August 2023 Contact Person: Krista Harris, Chief Financial Officer
Finding 2022-004 - Significant Deficiency, Compliance Federal Award No. 84.268, 84.007, 84.379, 84.063 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to the 2021-2022 Federal Student Aid Handbook a College must exclude institutionally scheduled breaks of five or more consecutive days from the Return to Title IV (R2T4) calculation as periods of nonattendance. The length of the scheduled break is determined by taking the last day that class is held before a scheduled break ? the next day is the first day of the scheduled break and the last day of the scheduled break is the day before the next class. Condition: In our nonstatistical sample of six students, it was noted for two students that the College used 105 days as the total days in the semester for the Fall 2021 semester when the College should have used 107 days as the total days in the semester for the Fall 2021 semester in the R2T4 calculation due to improperly counting two extra days for the institutionally scheduled break. Context: The College counted the last day of classes of November 19th, 2021 before the Thanksgiving break and the first day that classes resumed of November 29th, 2021 totaling 11 days as an institutionally scheduled break that reduced the total days used in the R2T4 calculation for the Fall 2021 semester. However, the College should have only used 9 days as the institutionally scheduled break was from November 20th, 2021 through November 28th, 2021. Effect: The improper calculation of the institutionally scheduled break dates resulted in the students retaining additional aid. Questioned Costs: Known questioned costs for the two students in which the exceptions were noted totaled $125. Likely questioned costs were not expected to exceed $1,000 for the R2T4 calculations performed in the Fall 2021 semester. Cause: Bethany College did not have proper processes and related controls in place to ensure that the correct number of days were used for institutionally scheduled breaks in the Fall 2021 semester. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to calculate the number of days included in institutionally scheduled breaks for the R2T4 calculation. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through adding additional review of the calculation of institutionally scheduled breaks and total days used in the R2T4 calculations. Completion Date: May 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-006 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.268, 84.033, 84.038, 84.379, 84.063 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: Per guidance in 34 CF 668.46(b), 34 CFR 668.49(b), and 34 CFR 668.41(e) the College is required to distribute its Annual Security Report and Annual Fire Safety Report by October 1st of each year to all enrolled students and current employees. Condition/Context: The College did not distribute its report due on October 1, 2022 on or before October 1, 2022 as the report was not completed until late October 2022. Effect: The College did not timely inform the enrolled students and current employees of the required statistics and information related to campus security and fire safety for the preceding year. Questioned Costs: There were no questioned costs identified as a result of this finding. Cause: The College was delayed in gathering information needed to prepare the report for distribution. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the College implement controls and processes to ensure that the Annual Security Report and Annual Fire Safety report is distributed timely. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through distributing the Annual Security Report and Fire Safety Report as well as establishing appropriate timelines for distribution in future years. Completion Date: October 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-001 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: In accordance with Federal Regulations 34 CFR 668.171, an institution administering Federal Student Financial Aid must obtain a minimum composite score of 1.5 to fulfill the requirements of financial responsibility and be above 1.0 to be considered for ?Zone Alternative? treatment. Condition: For the year under audit, the College?s financial responsibility composite score will fail to meet the numeric standard of responsibility as set by the Department of Education (ED). However, when an institution cannot meet the criteria for financial responsibility through the composite score, ED provides other ways to comply with this standard. One way the College can comply with this standard is by obtaining an irrevocable letter of credit from a bank. In addition, the College must make Federal Student Financial Aid disbursements under the heightened cash monitoring method described in 34 CFR 668.162. Context: The College?s ED financial responsibility composite fell below 1.0 in previous years and was between 1.0 and 1.5 in the past two fiscal years. The College has not been able to bring its score above 1.5, therefore will continue to have to obtain a letter of credit and follow heightened cash monitoring procedures. Effect: The College will have to obtain a letter of credit and follow heightened cash monitoring procedures. Additionally, the College may be required to provide further documentation of its financial plans and progress to accreditation agencies in which it may seek accreditation through. Questioned Costs: None noted. Cause: Bethany College does not have proper processes and related controls in place to ensure that the required financial responsibility composite score does not fall below 1.5. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: We recommend that the College implement controls and processes for monitoring budgets that include all expenses including non-cash transactions in order to adequately anticipate the revenue needed to cover the expenses of the College. We recommend that the College evaluate all of its cost centers and revenue streams to ensure that the College is maximizing fiscal efficiency while still achieving the mission of the College. Views Of Responsible Officials (Unaudited): The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: August 2023 Contact Person: Krista Harris, Chief Financial Officer
Finding 2022-004 - Significant Deficiency, Compliance Federal Award No. 84.268, 84.007, 84.379, 84.063 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to the 2021-2022 Federal Student Aid Handbook a College must exclude institutionally scheduled breaks of five or more consecutive days from the Return to Title IV (R2T4) calculation as periods of nonattendance. The length of the scheduled break is determined by taking the last day that class is held before a scheduled break ? the next day is the first day of the scheduled break and the last day of the scheduled break is the day before the next class. Condition: In our nonstatistical sample of six students, it was noted for two students that the College used 105 days as the total days in the semester for the Fall 2021 semester when the College should have used 107 days as the total days in the semester for the Fall 2021 semester in the R2T4 calculation due to improperly counting two extra days for the institutionally scheduled break. Context: The College counted the last day of classes of November 19th, 2021 before the Thanksgiving break and the first day that classes resumed of November 29th, 2021 totaling 11 days as an institutionally scheduled break that reduced the total days used in the R2T4 calculation for the Fall 2021 semester. However, the College should have only used 9 days as the institutionally scheduled break was from November 20th, 2021 through November 28th, 2021. Effect: The improper calculation of the institutionally scheduled break dates resulted in the students retaining additional aid. Questioned Costs: Known questioned costs for the two students in which the exceptions were noted totaled $125. Likely questioned costs were not expected to exceed $1,000 for the R2T4 calculations performed in the Fall 2021 semester. Cause: Bethany College did not have proper processes and related controls in place to ensure that the correct number of days were used for institutionally scheduled breaks in the Fall 2021 semester. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to calculate the number of days included in institutionally scheduled breaks for the R2T4 calculation. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through adding additional review of the calculation of institutionally scheduled breaks and total days used in the R2T4 calculations. Completion Date: May 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-006 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.268, 84.033, 84.038, 84.379, 84.063 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: Per guidance in 34 CF 668.46(b), 34 CFR 668.49(b), and 34 CFR 668.41(e) the College is required to distribute its Annual Security Report and Annual Fire Safety Report by October 1st of each year to all enrolled students and current employees. Condition/Context: The College did not distribute its report due on October 1, 2022 on or before October 1, 2022 as the report was not completed until late October 2022. Effect: The College did not timely inform the enrolled students and current employees of the required statistics and information related to campus security and fire safety for the preceding year. Questioned Costs: There were no questioned costs identified as a result of this finding. Cause: The College was delayed in gathering information needed to prepare the report for distribution. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the College implement controls and processes to ensure that the Annual Security Report and Annual Fire Safety report is distributed timely. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through distributing the Annual Security Report and Fire Safety Report as well as establishing appropriate timelines for distribution in future years. Completion Date: October 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-002 ? Material Weakness, Compliance Federal Award No. 84.425F U.S. Department Of Education Higher Education Emergency Relief Fund ? Reporting Criteria: In accordance with the Department of Education?s Frequently Asked Questions for the Higher Education Emergency Relief Fund (HEERF) the College is required to post to its website a quarterly report covering the aggregate amounts spent for HEERF I, HEERF II, and HEERF III for each quarterly reporting period 10 day after the end of each calendar quarter. Condition: The College did not post to its website timely one of two HEERF institutional portion quarterly reports selected for testing. The report not posted timely was for the quarter ending March 31, 2022 and was not posted accurately until July 2022. Context: The College erroneously posted the March 31, 2021 HEERF institutional report within the link on its website for the March 31, 2022 HEERF report. This was not identified or corrected until July 2022. Effect: The College did not communicate to the public its use of the institutional portion of the HEERF grant timely. If the Department of Education identifies an institution as having an elevated risk or are suspected of improperly administering their HEERF grant funds, the Department has a range of possible enforcement actions which could include heightened or more frequent reporting, monitoring, or auditing of an institution and placing the HEERF grants on ?Route Payment Status?, which requires prior authorization from the Department to draw down any remaining funds. As of the audit report date, the College has not received any notifications of any enforcement actions taken against the College related to the HEERF program. Questioned Costs: None noted. Cause: Bethany College does not have proper processes and related controls in place to ensure that the HEERF institutional report was submitted accurately and timely. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2021-002. Recommendation: We recommend that the College implement controls and processes to ensure that all due dates for reporting are appropriately monitored and reports are submitted timely to meet the reporting due dates. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through posting the correct institutional report in July 2022 to its website. Completion Date: July 2022 Contact Person: Krista Harris, Chief Financial Officer
Finding 2022-005 - Significant Deficiency Federal Award No. 84.425F U.S. Department Of Education Higher Education Emergency Relief Fund ? Cash Management Criteria: The U.S. Department of Education (ED) communicated updated cash management guidance for the HEERF through the release of the HEERF II FAQs on January 14, 2021. The HEERF II FAQ #17 specified that grantees are under an obligation to minimize the time between drawing down funds from G5 and paying obligations incurred by the grantee. ED considered institutions compliant if they paid from the HEERF funds emergency grants to students within 15 days of the draw down and for all other uses within 3 days. The Uniform Guidance requires the identification and documentation of costs as federal expenditures to occur prior to or within the timeframe established for paying obligations when grantees must follow enhanced cash management requirements. Condition/Context: The College drew down approximately $840,000 of HEERF funds from the institutional portion in April 2022 to various costs allowed for the by HEERF institutional portion; however, the College had not identified or documented specific costs or lost revenues that would be applied at the time of the drawdown for approximately $48,000 of the costs requested. Subsequent to the 3-day requirement for obligating institutional portion funds, the College identified and documented the specific costs that occurred prior to the date of the drawdown that were to be applied against this draw. Therefore, the College did not have an adequate control in place at the time of the drawdown to ensure that costs would be allowable; however, subsequently the College was able to identify sufficient allowable costs had been incurred. Effect: The College could have drawn down funds for ineligible costs or with improper timing if sufficient allowable costs had not been identified that occurred prior to or within 3 days of the drawdown date. If the Department of Education identifies an institution as having an elevated risk or are suspected of improperly administering their HEERF grant funds, the Department has a range of possible enforcement actions which could include heightened or more frequent reporting, monitoring, or auditing of an institution and placing the HEERF grants on ?Route Payment Status?, which requires prior authorization from the Department to draw down any remaining funds. As of the audit report date, the College has not received any notifications of any enforcement actions taken against the College related to the HEERF program. Questioned Costs: There were no questioned costs identified as management was able to identify sufficient allowable costs. Cause: The College made an error in the calculation of its initial drawdown request which resulted in the additional approximately $48,000 being requested that had not yet been supported by allowable costs prior to the date of the drawdown or within 3 days after the date of the drawdown. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2021-006. Recommendation: We recommend that the College implement controls and processes to ensure that all expenses are properly identified and documented before any drawdowns are made. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through identification of specific costs incurred prior to drawdown of funds and additional review of the drawdown calculations. Completion Date: July 2022 Contact Person: Krista Harris, Chief Financial Officer
Finding 2022-001 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: In accordance with Federal Regulations 34 CFR 668.171, an institution administering Federal Student Financial Aid must obtain a minimum composite score of 1.5 to fulfill the requirements of financial responsibility and be above 1.0 to be considered for ?Zone Alternative? treatment. Condition: For the year under audit, the College?s financial responsibility composite score will fail to meet the numeric standard of responsibility as set by the Department of Education (ED). However, when an institution cannot meet the criteria for financial responsibility through the composite score, ED provides other ways to comply with this standard. One way the College can comply with this standard is by obtaining an irrevocable letter of credit from a bank. In addition, the College must make Federal Student Financial Aid disbursements under the heightened cash monitoring method described in 34 CFR 668.162. Context: The College?s ED financial responsibility composite fell below 1.0 in previous years and was between 1.0 and 1.5 in the past two fiscal years. The College has not been able to bring its score above 1.5, therefore will continue to have to obtain a letter of credit and follow heightened cash monitoring procedures. Effect: The College will have to obtain a letter of credit and follow heightened cash monitoring procedures. Additionally, the College may be required to provide further documentation of its financial plans and progress to accreditation agencies in which it may seek accreditation through. Questioned Costs: None noted. Cause: Bethany College does not have proper processes and related controls in place to ensure that the required financial responsibility composite score does not fall below 1.5. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: We recommend that the College implement controls and processes for monitoring budgets that include all expenses including non-cash transactions in order to adequately anticipate the revenue needed to cover the expenses of the College. We recommend that the College evaluate all of its cost centers and revenue streams to ensure that the College is maximizing fiscal efficiency while still achieving the mission of the College. Views Of Responsible Officials (Unaudited): The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: August 2023 Contact Person: Krista Harris, Chief Financial Officer
Finding 2022-004 - Significant Deficiency, Compliance Federal Award No. 84.268, 84.007, 84.379, 84.063 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to the 2021-2022 Federal Student Aid Handbook a College must exclude institutionally scheduled breaks of five or more consecutive days from the Return to Title IV (R2T4) calculation as periods of nonattendance. The length of the scheduled break is determined by taking the last day that class is held before a scheduled break ? the next day is the first day of the scheduled break and the last day of the scheduled break is the day before the next class. Condition: In our nonstatistical sample of six students, it was noted for two students that the College used 105 days as the total days in the semester for the Fall 2021 semester when the College should have used 107 days as the total days in the semester for the Fall 2021 semester in the R2T4 calculation due to improperly counting two extra days for the institutionally scheduled break. Context: The College counted the last day of classes of November 19th, 2021 before the Thanksgiving break and the first day that classes resumed of November 29th, 2021 totaling 11 days as an institutionally scheduled break that reduced the total days used in the R2T4 calculation for the Fall 2021 semester. However, the College should have only used 9 days as the institutionally scheduled break was from November 20th, 2021 through November 28th, 2021. Effect: The improper calculation of the institutionally scheduled break dates resulted in the students retaining additional aid. Questioned Costs: Known questioned costs for the two students in which the exceptions were noted totaled $125. Likely questioned costs were not expected to exceed $1,000 for the R2T4 calculations performed in the Fall 2021 semester. Cause: Bethany College did not have proper processes and related controls in place to ensure that the correct number of days were used for institutionally scheduled breaks in the Fall 2021 semester. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to calculate the number of days included in institutionally scheduled breaks for the R2T4 calculation. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through adding additional review of the calculation of institutionally scheduled breaks and total days used in the R2T4 calculations. Completion Date: May 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-006 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.268, 84.033, 84.038, 84.379, 84.063 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: Per guidance in 34 CF 668.46(b), 34 CFR 668.49(b), and 34 CFR 668.41(e) the College is required to distribute its Annual Security Report and Annual Fire Safety Report by October 1st of each year to all enrolled students and current employees. Condition/Context: The College did not distribute its report due on October 1, 2022 on or before October 1, 2022 as the report was not completed until late October 2022. Effect: The College did not timely inform the enrolled students and current employees of the required statistics and information related to campus security and fire safety for the preceding year. Questioned Costs: There were no questioned costs identified as a result of this finding. Cause: The College was delayed in gathering information needed to prepare the report for distribution. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the College implement controls and processes to ensure that the Annual Security Report and Annual Fire Safety report is distributed timely. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through distributing the Annual Security Report and Fire Safety Report as well as establishing appropriate timelines for distribution in future years. Completion Date: October 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-001 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: In accordance with Federal Regulations 34 CFR 668.171, an institution administering Federal Student Financial Aid must obtain a minimum composite score of 1.5 to fulfill the requirements of financial responsibility and be above 1.0 to be considered for ?Zone Alternative? treatment. Condition: For the year under audit, the College?s financial responsibility composite score will fail to meet the numeric standard of responsibility as set by the Department of Education (ED). However, when an institution cannot meet the criteria for financial responsibility through the composite score, ED provides other ways to comply with this standard. One way the College can comply with this standard is by obtaining an irrevocable letter of credit from a bank. In addition, the College must make Federal Student Financial Aid disbursements under the heightened cash monitoring method described in 34 CFR 668.162. Context: The College?s ED financial responsibility composite fell below 1.0 in previous years and was between 1.0 and 1.5 in the past two fiscal years. The College has not been able to bring its score above 1.5, therefore will continue to have to obtain a letter of credit and follow heightened cash monitoring procedures. Effect: The College will have to obtain a letter of credit and follow heightened cash monitoring procedures. Additionally, the College may be required to provide further documentation of its financial plans and progress to accreditation agencies in which it may seek accreditation through. Questioned Costs: None noted. Cause: Bethany College does not have proper processes and related controls in place to ensure that the required financial responsibility composite score does not fall below 1.5. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: We recommend that the College implement controls and processes for monitoring budgets that include all expenses including non-cash transactions in order to adequately anticipate the revenue needed to cover the expenses of the College. We recommend that the College evaluate all of its cost centers and revenue streams to ensure that the College is maximizing fiscal efficiency while still achieving the mission of the College. Views Of Responsible Officials (Unaudited): The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: August 2023 Contact Person: Krista Harris, Chief Financial Officer
Finding 2022-003 - Significant Deficiency, Compliance Federal Award No. 84.268 U.S. Department Of Education Student Financial Aid Cluster - Special Tests and Provisions Criteria: According to the 2021-2022 COD Technical Reference and 2021-2022 SFA Handbook, the College must report accurate disbursement dates to Common Origination Disbursement (COD) for all direct loan disbursements made to students. Condition: In our nonstatistical sample of 40 students, we noted 24 students whose disbursement dates listed in the College?s student records (8/27/21) differed by one day from the date of disbursement dates reported to COD (8/28/21) for the students? direct loans disbursed in the Fall 2021 semester. Context: The students in question had anticipated disbursement dates of 8/28/21 that were not updated for the actual date of disbursement once the disbursements were made by the College. Effect: Improperly reported disbursement dates could impact the amount of interest charged to a student. Questioned Costs: There were no questioned costs to report as this finding relates only to COD reporting. Cause: Bethany College did not have proper processes and related controls in place to ensure that the disbursement dates reported in COD agreed with the disbursement dates in the College?s records. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: The Financial Aid department should put in place controls that would ensure that all disbursements would be processed on the anticipated disbursement dates as planned and controls that would detect if disbursements were processed at a later or earlier date and adjustments to amounts reported to COD were necessary. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has reviewed and where appropriate made updates to the processes used to report disbursement dates to COD. Completion Date: January 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-004 - Significant Deficiency, Compliance Federal Award No. 84.268, 84.007, 84.379, 84.063 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to the 2021-2022 Federal Student Aid Handbook a College must exclude institutionally scheduled breaks of five or more consecutive days from the Return to Title IV (R2T4) calculation as periods of nonattendance. The length of the scheduled break is determined by taking the last day that class is held before a scheduled break ? the next day is the first day of the scheduled break and the last day of the scheduled break is the day before the next class. Condition: In our nonstatistical sample of six students, it was noted for two students that the College used 105 days as the total days in the semester for the Fall 2021 semester when the College should have used 107 days as the total days in the semester for the Fall 2021 semester in the R2T4 calculation due to improperly counting two extra days for the institutionally scheduled break. Context: The College counted the last day of classes of November 19th, 2021 before the Thanksgiving break and the first day that classes resumed of November 29th, 2021 totaling 11 days as an institutionally scheduled break that reduced the total days used in the R2T4 calculation for the Fall 2021 semester. However, the College should have only used 9 days as the institutionally scheduled break was from November 20th, 2021 through November 28th, 2021. Effect: The improper calculation of the institutionally scheduled break dates resulted in the students retaining additional aid. Questioned Costs: Known questioned costs for the two students in which the exceptions were noted totaled $125. Likely questioned costs were not expected to exceed $1,000 for the R2T4 calculations performed in the Fall 2021 semester. Cause: Bethany College did not have proper processes and related controls in place to ensure that the correct number of days were used for institutionally scheduled breaks in the Fall 2021 semester. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to calculate the number of days included in institutionally scheduled breaks for the R2T4 calculation. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through adding additional review of the calculation of institutionally scheduled breaks and total days used in the R2T4 calculations. Completion Date: May 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-006 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.268, 84.033, 84.038, 84.379, 84.063 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: Per guidance in 34 CF 668.46(b), 34 CFR 668.49(b), and 34 CFR 668.41(e) the College is required to distribute its Annual Security Report and Annual Fire Safety Report by October 1st of each year to all enrolled students and current employees. Condition/Context: The College did not distribute its report due on October 1, 2022 on or before October 1, 2022 as the report was not completed until late October 2022. Effect: The College did not timely inform the enrolled students and current employees of the required statistics and information related to campus security and fire safety for the preceding year. Questioned Costs: There were no questioned costs identified as a result of this finding. Cause: The College was delayed in gathering information needed to prepare the report for distribution. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the College implement controls and processes to ensure that the Annual Security Report and Annual Fire Safety report is distributed timely. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through distributing the Annual Security Report and Fire Safety Report as well as establishing appropriate timelines for distribution in future years. Completion Date: October 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-001 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: In accordance with Federal Regulations 34 CFR 668.171, an institution administering Federal Student Financial Aid must obtain a minimum composite score of 1.5 to fulfill the requirements of financial responsibility and be above 1.0 to be considered for ?Zone Alternative? treatment. Condition: For the year under audit, the College?s financial responsibility composite score will fail to meet the numeric standard of responsibility as set by the Department of Education (ED). However, when an institution cannot meet the criteria for financial responsibility through the composite score, ED provides other ways to comply with this standard. One way the College can comply with this standard is by obtaining an irrevocable letter of credit from a bank. In addition, the College must make Federal Student Financial Aid disbursements under the heightened cash monitoring method described in 34 CFR 668.162. Context: The College?s ED financial responsibility composite fell below 1.0 in previous years and was between 1.0 and 1.5 in the past two fiscal years. The College has not been able to bring its score above 1.5, therefore will continue to have to obtain a letter of credit and follow heightened cash monitoring procedures. Effect: The College will have to obtain a letter of credit and follow heightened cash monitoring procedures. Additionally, the College may be required to provide further documentation of its financial plans and progress to accreditation agencies in which it may seek accreditation through. Questioned Costs: None noted. Cause: Bethany College does not have proper processes and related controls in place to ensure that the required financial responsibility composite score does not fall below 1.5. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: We recommend that the College implement controls and processes for monitoring budgets that include all expenses including non-cash transactions in order to adequately anticipate the revenue needed to cover the expenses of the College. We recommend that the College evaluate all of its cost centers and revenue streams to ensure that the College is maximizing fiscal efficiency while still achieving the mission of the College. Views Of Responsible Officials (Unaudited): The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: August 2023 Contact Person: Krista Harris, Chief Financial Officer
Finding 2022-006 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.268, 84.033, 84.038, 84.379, 84.063 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: Per guidance in 34 CF 668.46(b), 34 CFR 668.49(b), and 34 CFR 668.41(e) the College is required to distribute its Annual Security Report and Annual Fire Safety Report by October 1st of each year to all enrolled students and current employees. Condition/Context: The College did not distribute its report due on October 1, 2022 on or before October 1, 2022 as the report was not completed until late October 2022. Effect: The College did not timely inform the enrolled students and current employees of the required statistics and information related to campus security and fire safety for the preceding year. Questioned Costs: There were no questioned costs identified as a result of this finding. Cause: The College was delayed in gathering information needed to prepare the report for distribution. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the College implement controls and processes to ensure that the Annual Security Report and Annual Fire Safety report is distributed timely. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through distributing the Annual Security Report and Fire Safety Report as well as establishing appropriate timelines for distribution in future years. Completion Date: October 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-001 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: In accordance with Federal Regulations 34 CFR 668.171, an institution administering Federal Student Financial Aid must obtain a minimum composite score of 1.5 to fulfill the requirements of financial responsibility and be above 1.0 to be considered for ?Zone Alternative? treatment. Condition: For the year under audit, the College?s financial responsibility composite score will fail to meet the numeric standard of responsibility as set by the Department of Education (ED). However, when an institution cannot meet the criteria for financial responsibility through the composite score, ED provides other ways to comply with this standard. One way the College can comply with this standard is by obtaining an irrevocable letter of credit from a bank. In addition, the College must make Federal Student Financial Aid disbursements under the heightened cash monitoring method described in 34 CFR 668.162. Context: The College?s ED financial responsibility composite fell below 1.0 in previous years and was between 1.0 and 1.5 in the past two fiscal years. The College has not been able to bring its score above 1.5, therefore will continue to have to obtain a letter of credit and follow heightened cash monitoring procedures. Effect: The College will have to obtain a letter of credit and follow heightened cash monitoring procedures. Additionally, the College may be required to provide further documentation of its financial plans and progress to accreditation agencies in which it may seek accreditation through. Questioned Costs: None noted. Cause: Bethany College does not have proper processes and related controls in place to ensure that the required financial responsibility composite score does not fall below 1.5. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: We recommend that the College implement controls and processes for monitoring budgets that include all expenses including non-cash transactions in order to adequately anticipate the revenue needed to cover the expenses of the College. We recommend that the College evaluate all of its cost centers and revenue streams to ensure that the College is maximizing fiscal efficiency while still achieving the mission of the College. Views Of Responsible Officials (Unaudited): The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: August 2023 Contact Person: Krista Harris, Chief Financial Officer
Finding 2022-006 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.268, 84.033, 84.038, 84.379, 84.063 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: Per guidance in 34 CF 668.46(b), 34 CFR 668.49(b), and 34 CFR 668.41(e) the College is required to distribute its Annual Security Report and Annual Fire Safety Report by October 1st of each year to all enrolled students and current employees. Condition/Context: The College did not distribute its report due on October 1, 2022 on or before October 1, 2022 as the report was not completed until late October 2022. Effect: The College did not timely inform the enrolled students and current employees of the required statistics and information related to campus security and fire safety for the preceding year. Questioned Costs: There were no questioned costs identified as a result of this finding. Cause: The College was delayed in gathering information needed to prepare the report for distribution. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the College implement controls and processes to ensure that the Annual Security Report and Annual Fire Safety report is distributed timely. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through distributing the Annual Security Report and Fire Safety Report as well as establishing appropriate timelines for distribution in future years. Completion Date: October 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-001 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: In accordance with Federal Regulations 34 CFR 668.171, an institution administering Federal Student Financial Aid must obtain a minimum composite score of 1.5 to fulfill the requirements of financial responsibility and be above 1.0 to be considered for ?Zone Alternative? treatment. Condition: For the year under audit, the College?s financial responsibility composite score will fail to meet the numeric standard of responsibility as set by the Department of Education (ED). However, when an institution cannot meet the criteria for financial responsibility through the composite score, ED provides other ways to comply with this standard. One way the College can comply with this standard is by obtaining an irrevocable letter of credit from a bank. In addition, the College must make Federal Student Financial Aid disbursements under the heightened cash monitoring method described in 34 CFR 668.162. Context: The College?s ED financial responsibility composite fell below 1.0 in previous years and was between 1.0 and 1.5 in the past two fiscal years. The College has not been able to bring its score above 1.5, therefore will continue to have to obtain a letter of credit and follow heightened cash monitoring procedures. Effect: The College will have to obtain a letter of credit and follow heightened cash monitoring procedures. Additionally, the College may be required to provide further documentation of its financial plans and progress to accreditation agencies in which it may seek accreditation through. Questioned Costs: None noted. Cause: Bethany College does not have proper processes and related controls in place to ensure that the required financial responsibility composite score does not fall below 1.5. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: We recommend that the College implement controls and processes for monitoring budgets that include all expenses including non-cash transactions in order to adequately anticipate the revenue needed to cover the expenses of the College. We recommend that the College evaluate all of its cost centers and revenue streams to ensure that the College is maximizing fiscal efficiency while still achieving the mission of the College. Views Of Responsible Officials (Unaudited): The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: August 2023 Contact Person: Krista Harris, Chief Financial Officer
Finding 2022-004 - Significant Deficiency, Compliance Federal Award No. 84.268, 84.007, 84.379, 84.063 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to the 2021-2022 Federal Student Aid Handbook a College must exclude institutionally scheduled breaks of five or more consecutive days from the Return to Title IV (R2T4) calculation as periods of nonattendance. The length of the scheduled break is determined by taking the last day that class is held before a scheduled break ? the next day is the first day of the scheduled break and the last day of the scheduled break is the day before the next class. Condition: In our nonstatistical sample of six students, it was noted for two students that the College used 105 days as the total days in the semester for the Fall 2021 semester when the College should have used 107 days as the total days in the semester for the Fall 2021 semester in the R2T4 calculation due to improperly counting two extra days for the institutionally scheduled break. Context: The College counted the last day of classes of November 19th, 2021 before the Thanksgiving break and the first day that classes resumed of November 29th, 2021 totaling 11 days as an institutionally scheduled break that reduced the total days used in the R2T4 calculation for the Fall 2021 semester. However, the College should have only used 9 days as the institutionally scheduled break was from November 20th, 2021 through November 28th, 2021. Effect: The improper calculation of the institutionally scheduled break dates resulted in the students retaining additional aid. Questioned Costs: Known questioned costs for the two students in which the exceptions were noted totaled $125. Likely questioned costs were not expected to exceed $1,000 for the R2T4 calculations performed in the Fall 2021 semester. Cause: Bethany College did not have proper processes and related controls in place to ensure that the correct number of days were used for institutionally scheduled breaks in the Fall 2021 semester. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to calculate the number of days included in institutionally scheduled breaks for the R2T4 calculation. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through adding additional review of the calculation of institutionally scheduled breaks and total days used in the R2T4 calculations. Completion Date: May 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-006 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.268, 84.033, 84.038, 84.379, 84.063 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: Per guidance in 34 CF 668.46(b), 34 CFR 668.49(b), and 34 CFR 668.41(e) the College is required to distribute its Annual Security Report and Annual Fire Safety Report by October 1st of each year to all enrolled students and current employees. Condition/Context: The College did not distribute its report due on October 1, 2022 on or before October 1, 2022 as the report was not completed until late October 2022. Effect: The College did not timely inform the enrolled students and current employees of the required statistics and information related to campus security and fire safety for the preceding year. Questioned Costs: There were no questioned costs identified as a result of this finding. Cause: The College was delayed in gathering information needed to prepare the report for distribution. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the College implement controls and processes to ensure that the Annual Security Report and Annual Fire Safety report is distributed timely. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through distributing the Annual Security Report and Fire Safety Report as well as establishing appropriate timelines for distribution in future years. Completion Date: October 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-001 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.033, 84.038, 84.063, 84.268, 84.379 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: In accordance with Federal Regulations 34 CFR 668.171, an institution administering Federal Student Financial Aid must obtain a minimum composite score of 1.5 to fulfill the requirements of financial responsibility and be above 1.0 to be considered for ?Zone Alternative? treatment. Condition: For the year under audit, the College?s financial responsibility composite score will fail to meet the numeric standard of responsibility as set by the Department of Education (ED). However, when an institution cannot meet the criteria for financial responsibility through the composite score, ED provides other ways to comply with this standard. One way the College can comply with this standard is by obtaining an irrevocable letter of credit from a bank. In addition, the College must make Federal Student Financial Aid disbursements under the heightened cash monitoring method described in 34 CFR 668.162. Context: The College?s ED financial responsibility composite fell below 1.0 in previous years and was between 1.0 and 1.5 in the past two fiscal years. The College has not been able to bring its score above 1.5, therefore will continue to have to obtain a letter of credit and follow heightened cash monitoring procedures. Effect: The College will have to obtain a letter of credit and follow heightened cash monitoring procedures. Additionally, the College may be required to provide further documentation of its financial plans and progress to accreditation agencies in which it may seek accreditation through. Questioned Costs: None noted. Cause: Bethany College does not have proper processes and related controls in place to ensure that the required financial responsibility composite score does not fall below 1.5. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2021-001. Recommendation: We recommend that the College implement controls and processes for monitoring budgets that include all expenses including non-cash transactions in order to adequately anticipate the revenue needed to cover the expenses of the College. We recommend that the College evaluate all of its cost centers and revenue streams to ensure that the College is maximizing fiscal efficiency while still achieving the mission of the College. Views Of Responsible Officials (Unaudited): The College has obtained the required letter of credit from a local bank and will comply with federal heightened cash monitoring requirements. The College continues to work to positively align revenues and expenses. The College regularly monitors its cash flows and expense budgets both for timing and savings. Efforts continue to increase net student revenues to reduce the need for current-year contributions and other income for operating expenses. The College will continue to carefully plan and manage institutional financial aid to yield stronger net student revenues to support operations. Anticipated Completion Date: August 2023 Contact Person: Krista Harris, Chief Financial Officer
Finding 2022-004 - Significant Deficiency, Compliance Federal Award No. 84.268, 84.007, 84.379, 84.063 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: According to the 2021-2022 Federal Student Aid Handbook a College must exclude institutionally scheduled breaks of five or more consecutive days from the Return to Title IV (R2T4) calculation as periods of nonattendance. The length of the scheduled break is determined by taking the last day that class is held before a scheduled break ? the next day is the first day of the scheduled break and the last day of the scheduled break is the day before the next class. Condition: In our nonstatistical sample of six students, it was noted for two students that the College used 105 days as the total days in the semester for the Fall 2021 semester when the College should have used 107 days as the total days in the semester for the Fall 2021 semester in the R2T4 calculation due to improperly counting two extra days for the institutionally scheduled break. Context: The College counted the last day of classes of November 19th, 2021 before the Thanksgiving break and the first day that classes resumed of November 29th, 2021 totaling 11 days as an institutionally scheduled break that reduced the total days used in the R2T4 calculation for the Fall 2021 semester. However, the College should have only used 9 days as the institutionally scheduled break was from November 20th, 2021 through November 28th, 2021. Effect: The improper calculation of the institutionally scheduled break dates resulted in the students retaining additional aid. Questioned Costs: Known questioned costs for the two students in which the exceptions were noted totaled $125. Likely questioned costs were not expected to exceed $1,000 for the R2T4 calculations performed in the Fall 2021 semester. Cause: Bethany College did not have proper processes and related controls in place to ensure that the correct number of days were used for institutionally scheduled breaks in the Fall 2021 semester. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: The Financial Aid department should review and consider revisions to its processes and related controls in place to calculate the number of days included in institutionally scheduled breaks for the R2T4 calculation. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through adding additional review of the calculation of institutionally scheduled breaks and total days used in the R2T4 calculations. Completion Date: May 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-006 - Significant Deficiency, Compliance Federal Award No. 84.007, 84.268, 84.033, 84.038, 84.379, 84.063 U.S. Department Of Education Student Financial Aid Cluster ? Special Tests and Provisions Criteria: Per guidance in 34 CF 668.46(b), 34 CFR 668.49(b), and 34 CFR 668.41(e) the College is required to distribute its Annual Security Report and Annual Fire Safety Report by October 1st of each year to all enrolled students and current employees. Condition/Context: The College did not distribute its report due on October 1, 2022 on or before October 1, 2022 as the report was not completed until late October 2022. Effect: The College did not timely inform the enrolled students and current employees of the required statistics and information related to campus security and fire safety for the preceding year. Questioned Costs: There were no questioned costs identified as a result of this finding. Cause: The College was delayed in gathering information needed to prepare the report for distribution. Indication Of Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the College implement controls and processes to ensure that the Annual Security Report and Annual Fire Safety report is distributed timely. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through distributing the Annual Security Report and Fire Safety Report as well as establishing appropriate timelines for distribution in future years. Completion Date: October 2022 Contact Person: Christoffer Larsen, Executive Director of Student Financial Services
Finding 2022-002 ? Material Weakness, Compliance Federal Award No. 84.425F U.S. Department Of Education Higher Education Emergency Relief Fund ? Reporting Criteria: In accordance with the Department of Education?s Frequently Asked Questions for the Higher Education Emergency Relief Fund (HEERF) the College is required to post to its website a quarterly report covering the aggregate amounts spent for HEERF I, HEERF II, and HEERF III for each quarterly reporting period 10 day after the end of each calendar quarter. Condition: The College did not post to its website timely one of two HEERF institutional portion quarterly reports selected for testing. The report not posted timely was for the quarter ending March 31, 2022 and was not posted accurately until July 2022. Context: The College erroneously posted the March 31, 2021 HEERF institutional report within the link on its website for the March 31, 2022 HEERF report. This was not identified or corrected until July 2022. Effect: The College did not communicate to the public its use of the institutional portion of the HEERF grant timely. If the Department of Education identifies an institution as having an elevated risk or are suspected of improperly administering their HEERF grant funds, the Department has a range of possible enforcement actions which could include heightened or more frequent reporting, monitoring, or auditing of an institution and placing the HEERF grants on ?Route Payment Status?, which requires prior authorization from the Department to draw down any remaining funds. As of the audit report date, the College has not received any notifications of any enforcement actions taken against the College related to the HEERF program. Questioned Costs: None noted. Cause: Bethany College does not have proper processes and related controls in place to ensure that the HEERF institutional report was submitted accurately and timely. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2021-002. Recommendation: We recommend that the College implement controls and processes to ensure that all due dates for reporting are appropriately monitored and reports are submitted timely to meet the reporting due dates. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through posting the correct institutional report in July 2022 to its website. Completion Date: July 2022 Contact Person: Krista Harris, Chief Financial Officer
Finding 2022-005 - Significant Deficiency Federal Award No. 84.425F U.S. Department Of Education Higher Education Emergency Relief Fund ? Cash Management Criteria: The U.S. Department of Education (ED) communicated updated cash management guidance for the HEERF through the release of the HEERF II FAQs on January 14, 2021. The HEERF II FAQ #17 specified that grantees are under an obligation to minimize the time between drawing down funds from G5 and paying obligations incurred by the grantee. ED considered institutions compliant if they paid from the HEERF funds emergency grants to students within 15 days of the draw down and for all other uses within 3 days. The Uniform Guidance requires the identification and documentation of costs as federal expenditures to occur prior to or within the timeframe established for paying obligations when grantees must follow enhanced cash management requirements. Condition/Context: The College drew down approximately $840,000 of HEERF funds from the institutional portion in April 2022 to various costs allowed for the by HEERF institutional portion; however, the College had not identified or documented specific costs or lost revenues that would be applied at the time of the drawdown for approximately $48,000 of the costs requested. Subsequent to the 3-day requirement for obligating institutional portion funds, the College identified and documented the specific costs that occurred prior to the date of the drawdown that were to be applied against this draw. Therefore, the College did not have an adequate control in place at the time of the drawdown to ensure that costs would be allowable; however, subsequently the College was able to identify sufficient allowable costs had been incurred. Effect: The College could have drawn down funds for ineligible costs or with improper timing if sufficient allowable costs had not been identified that occurred prior to or within 3 days of the drawdown date. If the Department of Education identifies an institution as having an elevated risk or are suspected of improperly administering their HEERF grant funds, the Department has a range of possible enforcement actions which could include heightened or more frequent reporting, monitoring, or auditing of an institution and placing the HEERF grants on ?Route Payment Status?, which requires prior authorization from the Department to draw down any remaining funds. As of the audit report date, the College has not received any notifications of any enforcement actions taken against the College related to the HEERF program. Questioned Costs: There were no questioned costs identified as management was able to identify sufficient allowable costs. Cause: The College made an error in the calculation of its initial drawdown request which resulted in the additional approximately $48,000 being requested that had not yet been supported by allowable costs prior to the date of the drawdown or within 3 days after the date of the drawdown. Indication Of Repeat Finding: This is a repeat of a finding in the immediately prior year; see Summary Schedule of Prior Audit Findings 2021-006. Recommendation: We recommend that the College implement controls and processes to ensure that all expenses are properly identified and documented before any drawdowns are made. Views Of Responsible Officials (Unaudited): The College concurs with the finding and has provided corrective action through identification of specific costs incurred prior to drawdown of funds and additional review of the drawdown calculations. Completion Date: July 2022 Contact Person: Krista Harris, Chief Financial Officer