FAC Explorer

Audit 323327

FY End
2023-12-31
Total Expended
$3.19M
Findings
6
Programs
1
Organization: Virginia University of Integrative Medicine (VA)
Year: 2023 Accepted: 2024-09-30
Auditor: Chapinsandstrom LLC

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
501062 2023-001 - - N
501063 2023-002 - - N
501064 2023-003 Significant Deficiency - N
1077504 2023-001 - - N
1077505 2023-002 - - N
1077506 2023-003 Significant Deficiency - N

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $3.19M Yes 3

Contacts

Name Title Type
DDZCEV5EGC99 John Yoo Auditee
7033235690 Dan Sandstrom Auditor
No contacts on file

Notes to SEFA

Title: 1. BASIS OF PRESENTATION Accounting Policies: 1. BASIS OF PRESENTATION: The above schedule of expenditures of federal awards is for the federal financial assistance received by Virginia University of Integrative Medicine. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). This schedule only presents a selected portion of the University’s operations and, as such, does not present the financial position, changes in net assets or cash flows of the University. 2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES: Expenditures are reported on the accrual basis of accounting, consistent with the basis of accounting used to prepare the University’s audited financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance wherein certain types of expenditures are not allowable or are limited as to reimbursement. The University does not use the predetermined indirect rate of 10 percent. The Uniform Guidance requires that when loans are made to students but the institution of higher education does not make the loans, the value of the loans made during the year is considered federal awards expended for which the balance of loans for the previous audit period is not included as federal awards expended because the lender (U.S. Department of Education) accounts for these prior balances. De Minimis Rate Used: N Rate Explanation: Funding in the form of student loans - no indirect reimbursement. The above schedule of expenditures of federal awards is for the federal financial assistance received by Virginia University of Integrative Medicine. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). This schedule only presents a selected portion of the University’s operations and, as such, does not present the financial position, changes in net assets or cash flows of the University.
Title: 2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Accounting Policies: 1. BASIS OF PRESENTATION: The above schedule of expenditures of federal awards is for the federal financial assistance received by Virginia University of Integrative Medicine. The information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). This schedule only presents a selected portion of the University’s operations and, as such, does not present the financial position, changes in net assets or cash flows of the University. 2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES: Expenditures are reported on the accrual basis of accounting, consistent with the basis of accounting used to prepare the University’s audited financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance wherein certain types of expenditures are not allowable or are limited as to reimbursement. The University does not use the predetermined indirect rate of 10 percent. The Uniform Guidance requires that when loans are made to students but the institution of higher education does not make the loans, the value of the loans made during the year is considered federal awards expended for which the balance of loans for the previous audit period is not included as federal awards expended because the lender (U.S. Department of Education) accounts for these prior balances. De Minimis Rate Used: N Rate Explanation: Funding in the form of student loans - no indirect reimbursement. Expenditures are reported on the accrual basis of accounting, consistent with the basis of accounting used to prepare the University’s audited financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance wherein certain types of expenditures are not allowable or are limited as to reimbursement. The University does not use the predetermined indirect rate of 10 percent. The Uniform Guidance requires that when loans are made to students but the institution of higher education does not make the loans, the value of the loans made during the year is considered federal awards expended for which the balance of loans for the previous audit period is not included as federal awards expended because the lender (U.S. Department of Education) accounts for these prior balances.

Finding Details

Finding 2023-001
Federal Program: 84.268 Criteria: Under 34 CFR 685.309, institutions are required to report enrollment information in a timely manner – at a minimum, institutions are required to certify enrollment every 60 days or every other month. Condition: For the year under audit, one of the students selected for testing had a reportable change in enrollment status (from less than half time to deceased) the end of Summer 2023 term yet the University did not report this change until May 2024. Cause: This was a unique circumstance and the University’s staff was unsure how to respond. Effect: The University did not comply with the time reporting requirement under 34 CFR 685.309. Context: This circumstance involved one student out of a sample of three for a population of 29 for those students having a reportable change in enrollment status. Recommendation: The University should bolster its enrollment reporting procedures to address unusual circumstances for changes in enrollment which includes bringing the matter to the attention of senior management and to consult with the third-party servicer within the prescribed 60 days. Management’s View: See Corrective Action Plan.
Finding 2023-002
Federal Program: 84.268 Criteria: Under 34 CFR 668.164(h)(2), institutions must pay the resulting credit balance directly to the student or parent borrower within 14 days after 1) the first day of class of a payment period if the credit balance occurred on or before that day, or 2) the balance occurred if occurring after the first day of class. Condition: For the year under audit, the University was one day late in paying a credit balance to the student. Cause: There was a delay by senior management in authorizing the wire transfer (the request had been processed on time). Effect: The University did not comply with 34 CFR 668.164(h)(2). Context: This circumstance involved one student out of a sample of 23 for a population of 227. Recommendation: The University should bolster its processing procedures to help ensure delays are monitored and, if necessary, have a second member of senior management available to authorize these transfers. Management’s View: See Corrective Action Plan.
Finding 2023-003
Federal Program: 84.268 Criteria: Under 34 CFR 668.164(l)(3), checks sent to students that are not returned to the institution (i.e., not cashed) must be returned to the Secretary no later than 240 days after the date the checks were issued. Condition: For the year under audit, the University reported $17,809 of outstanding (uncleared) refund checks to students in excess of 240 days. Cause: Management was unaware of the 240 day requirement. Effect: The University did not comply with 34 CFR 668.164(l)(3). Context: N/A. Recommendation: The University should implement a policy that future uncleared student checks are monitored for compliance with the 240 day requirement and one or more procedures that provides reasonable assurance of complying with this policy (possibly as part of reviewing bank reconciliations). Also, all checks older than 240 days should be sent (returned) to the Secretary. Management’s View: See Corrective Action Plan.
Finding 2023-001
Federal Program: 84.268 Criteria: Under 34 CFR 685.309, institutions are required to report enrollment information in a timely manner – at a minimum, institutions are required to certify enrollment every 60 days or every other month. Condition: For the year under audit, one of the students selected for testing had a reportable change in enrollment status (from less than half time to deceased) the end of Summer 2023 term yet the University did not report this change until May 2024. Cause: This was a unique circumstance and the University’s staff was unsure how to respond. Effect: The University did not comply with the time reporting requirement under 34 CFR 685.309. Context: This circumstance involved one student out of a sample of three for a population of 29 for those students having a reportable change in enrollment status. Recommendation: The University should bolster its enrollment reporting procedures to address unusual circumstances for changes in enrollment which includes bringing the matter to the attention of senior management and to consult with the third-party servicer within the prescribed 60 days. Management’s View: See Corrective Action Plan.
Finding 2023-002
Federal Program: 84.268 Criteria: Under 34 CFR 668.164(h)(2), institutions must pay the resulting credit balance directly to the student or parent borrower within 14 days after 1) the first day of class of a payment period if the credit balance occurred on or before that day, or 2) the balance occurred if occurring after the first day of class. Condition: For the year under audit, the University was one day late in paying a credit balance to the student. Cause: There was a delay by senior management in authorizing the wire transfer (the request had been processed on time). Effect: The University did not comply with 34 CFR 668.164(h)(2). Context: This circumstance involved one student out of a sample of 23 for a population of 227. Recommendation: The University should bolster its processing procedures to help ensure delays are monitored and, if necessary, have a second member of senior management available to authorize these transfers. Management’s View: See Corrective Action Plan.
Finding 2023-003
Federal Program: 84.268 Criteria: Under 34 CFR 668.164(l)(3), checks sent to students that are not returned to the institution (i.e., not cashed) must be returned to the Secretary no later than 240 days after the date the checks were issued. Condition: For the year under audit, the University reported $17,809 of outstanding (uncleared) refund checks to students in excess of 240 days. Cause: Management was unaware of the 240 day requirement. Effect: The University did not comply with 34 CFR 668.164(l)(3). Context: N/A. Recommendation: The University should implement a policy that future uncleared student checks are monitored for compliance with the 240 day requirement and one or more procedures that provides reasonable assurance of complying with this policy (possibly as part of reviewing bank reconciliations). Also, all checks older than 240 days should be sent (returned) to the Secretary. Management’s View: See Corrective Action Plan.