Audit 339546

FY End
2024-06-30
Total Expended
$6.97M
Findings
2
Programs
6
Organization: Transylvania University (KY)
Year: 2024 Accepted: 2025-01-23
Auditor: Blue & CO LLC

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
520046 2024-001 Significant Deficiency - L
1096488 2024-001 Significant Deficiency - L

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $4.78M Yes 1
84.063 Federal Pell Grant Program $1.42M Yes 0
84.038 Federal Perkins Loans $479,854 Yes 0
84.033 Federal Work-Study Program $149,339 Yes 0
84.007 Federal Supplemental Educational Opportunity Grants $91,143 Yes 0
47.083 Integrative Activities $52,420 - 0

Contacts

Name Title Type
RAJVK3PRXTA7 Lisa Custardo, CPA Auditee
8592338208 Rick Shields, CPA Auditor
No contacts on file

Notes to SEFA

Title: General Accounting Policies: The accompanying schedule of expenditures of federal awards is presented on the accrual basis of accounting. 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, therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements. De Minimis Rate Used: N Rate Explanation: The University did not elect to use the 10% de minimis indirect cost rate. The accompanying schedule of expenditures of federal awards presents the activity of all federal financial assistance programs of Transylvania University (the University). The grant revenue amounts received and expensed are subject to audit and adjustment. If any expenditures are disallowed by the grantor as a result of such an audit, any claim for reimbursement to the grantor would become a liability of the University. In the opinion of management, all grant expenditures are in compliance with the terms of the grant agreements and applicable federal laws and regulations. The University did not elect to use the 10% de minimis indirect cost rate and no amounts were provided to subrecipients.
Title: Basis of Presentation Accounting Policies: The accompanying schedule of expenditures of federal awards is presented on the accrual basis of accounting. 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, therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements. De Minimis Rate Used: N Rate Explanation: The University did not elect to use the 10% de minimis indirect cost rate. The accompanying schedule of expenditures of federal awards is presented on the accrual basis of accounting. 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, therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements.
Title: Federal Supplemental Educational Opportunity Grants Accounting Policies: The accompanying schedule of expenditures of federal awards is presented on the accrual basis of accounting. 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, therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements. De Minimis Rate Used: N Rate Explanation: The University did not elect to use the 10% de minimis indirect cost rate. The University administers a Federal Supplemental Educational Opportunity Grants Program (Assistance Listing (AL) No. 84.007) funded by the U.S. Department of Education. Total federal disbursements under the program for the year ended June 30, 2024 are as follows: Institution Federal amount amount Total Student grants $ 29,857 $ 90,750 $ 120,607 Administrative cost allowance 0 393 393 $ 29,857 $ 91,143 $ 121,000
Title: Federal Direct Student Loans Accounting Policies: The accompanying schedule of expenditures of federal awards is presented on the accrual basis of accounting. 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, therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements. De Minimis Rate Used: N Rate Explanation: The University did not elect to use the 10% de minimis indirect cost rate. For the year ended June 30, 2024, the University processed $4,776,202 (net of loan and origination fees) of new loans under the Federal Direct Student Loans Program (AL No. 84.268) (which includes subsidized, unsubsidized, and Parents' Loans for Undergraduate Students). The University is responsible only for the performance of certain administrative duties with respect to the Federal Direct Student Loan Program. Accordingly, it is not practical to determine the balance of loans outstanding to students and former students of the University under the program at June 30, 2024.
Title: Federal Work-Study Program Accounting Policies: The accompanying schedule of expenditures of federal awards is presented on the accrual basis of accounting. 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, therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements. De Minimis Rate Used: N Rate Explanation: The University did not elect to use the 10% de minimis indirect cost rate. The University administers a Federal Work-Study Program (AL No. 84.033) funded by the U.S. Department of Education. Total disbursements under the program, including the non-federal institutional share amount the University was not obligated to provide, for the year ended June 30, 2024 are as follows: Institution Federal amount amount Total Earned compensation $ 172,584 $ 149,339 $ 321,923
Title: Federal Perkins Loans Accounting Policies: The accompanying schedule of expenditures of federal awards is presented on the accrual basis of accounting. 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, therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements. De Minimis Rate Used: N Rate Explanation: The University did not elect to use the 10% de minimis indirect cost rate. The University administers a Federal Perkins Loans Program (AL No. 84.038) funded by the U.S. Department of Education. Student loans receivable under the program at June 30, 2024 were $334,251. Total cash on hand for Perkins Program at June 30, 2024 was $156,290. Total amount considered federal expenditures for the year ended June 30, 2024 are as follows: Amount Current advances to students $ 0 Student loan receivables July 1, 2023 479,854 Administrative cost allowance 0 $ 479,854
Title: Federal Pell Grant Program Accounting Policies: The accompanying schedule of expenditures of federal awards is presented on the accrual basis of accounting. 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, therefore, some amounts presented in this schedule may differ from amounts presented in, or used in the preparation of, the consolidated financial statements. De Minimis Rate Used: N Rate Explanation: The University did not elect to use the 10% de minimis indirect cost rate. The University administers a Federal Pell Grant Program (AL No. 84.063) funded by the U.S. Department of Education. Total disbursements under the program for the year June 30, 2024 are as follows: Amount Student grants $ 1,420,604 Administrative cost allowance 1,350 $ 1,421,954

Finding Details

Finding 2024-001: Enrollment Reporting Information on the Federal Program: Federal Direct Student Loan Program, AL Number 84.268 (Student Financial Aid Cluster) - U.S. Department of Education Criteria: Per 34 CFR 685.309(b)(2)(i), unless the school expects to submit its next enrollment report within 60 days, the school must notify the lender or the guaranty agency within 30 days after the discovery that a student who received a loan under the Title IV Act either did not enroll or ceased to be enrolled on at least a half-time basis. Per the National Loan Student Database System (NSLDS) Enrollment Reporting Guide and the GEN-14-07 Dear Colleague Letter issued by the U.S. Department of Education, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Condition: For students who completed their graduation requirements in May 2024, their graduated status change was reported via a third-party servicer on June 2, 2024, but was then subsequently overwritten by the third-party servicer with a status of full-time on June 20, 2024. The status of full-time remained active until October 3, 2024 when it was then changed to a status of withdrawn. Questioned Cost: $ 0 Cause: The University did not ensure that enrollment information submitted to NSLDS by its third-party servicer reflected accurate student enrollment data. Effect: The enrollment status for students who completed their graduation requirements in May 2024 was incorrect for more than 120 days. Recommendation: We recommend the University regularly review NSLDS to ensure that the information for its students is accurate. Views of responsible officials and planned corrective actions: The University concurs with this finding and will implement oversight procedures to ensure any status errors in NSLDS are corrected timely.
Finding 2024-001: Enrollment Reporting Information on the Federal Program: Federal Direct Student Loan Program, AL Number 84.268 (Student Financial Aid Cluster) - U.S. Department of Education Criteria: Per 34 CFR 685.309(b)(2)(i), unless the school expects to submit its next enrollment report within 60 days, the school must notify the lender or the guaranty agency within 30 days after the discovery that a student who received a loan under the Title IV Act either did not enroll or ceased to be enrolled on at least a half-time basis. Per the National Loan Student Database System (NSLDS) Enrollment Reporting Guide and the GEN-14-07 Dear Colleague Letter issued by the U.S. Department of Education, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely. Condition: For students who completed their graduation requirements in May 2024, their graduated status change was reported via a third-party servicer on June 2, 2024, but was then subsequently overwritten by the third-party servicer with a status of full-time on June 20, 2024. The status of full-time remained active until October 3, 2024 when it was then changed to a status of withdrawn. Questioned Cost: $ 0 Cause: The University did not ensure that enrollment information submitted to NSLDS by its third-party servicer reflected accurate student enrollment data. Effect: The enrollment status for students who completed their graduation requirements in May 2024 was incorrect for more than 120 days. Recommendation: We recommend the University regularly review NSLDS to ensure that the information for its students is accurate. Views of responsible officials and planned corrective actions: The University concurs with this finding and will implement oversight procedures to ensure any status errors in NSLDS are corrected timely.