FAC Explorer

Audit 3792

FY End
2023-06-30
Total Expended
$2.47M
Findings
16
Programs
6
Organization: Bethany Fellowship, Inc. (CO)
Year: 2023 Accepted: 2023-11-20
Auditor: Capincrouse LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
2210 2023-002 Significant Deficiency - N
2211 2023-002 Significant Deficiency - N
2212 2023-003 - - E
2213 2023-004 - - E
2214 2023-005 - - N
2215 2023-005 - - N
2216 2023-005 - - N
2217 2023-005 - - N
578652 2023-002 Significant Deficiency - N
578653 2023-002 Significant Deficiency - N
578654 2023-003 - - E
578655 2023-004 - - E
578656 2023-005 - - N
578657 2023-005 - - N
578658 2023-005 - - N
578659 2023-005 - - N

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $750,832 Yes 3
84.063 Federal Pell Grant Program $627,419 Yes 2
84.033 Federal Work-Study Program $435,550 Yes 2
84.425 Covid-19 Education Stabilization Fund Heerf - Student Aid Portion $390,260 - 0
84.425 Covid-19 Education Stabilization Fund Heerf - Institutional Portion $256,895 - 0
84.007 Federal Supplemental Educational Opportunity Grants $12,000 Yes 1

Contacts

Name Title Type
N2MQFMZVQ1C3 David Entler Auditee
9529464193 Tyler Vanderven, CPA Auditor
No contacts on file

Notes to SEFA

Title: RELATIONSHIP TO THE CONSOLIDATED FINANCIAL STATEMENTS Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Bethany Fellowship, Inc. dba Bethany International dba Bethany Global University (Bethany) under programs of the federal government for the year ending June 30, 2023. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If Bethany is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate See the Notes to the SEFA for chart/table
Title: SUBRECIPIENTS, NON-CASH ASSISTANCE, FEDERAL INSURANCE, LOANS, AND LOAN GUARANTEES Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Bethany Fellowship, Inc. dba Bethany International dba Bethany Global University (Bethany) under programs of the federal government for the year ending June 30, 2023. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If Bethany is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate Bethany did not provide any federal funds to subrecipients nor did they receive any federal non-cash assistance, insurance, loans, or loan guarantees.

Finding Details

Finding 2023-002
Incorrect and Untimely Return of Title IV (R2T4) Funds Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew, Bethany did not always return unearned Title IV aid timely as an attendance taking school. Additionally, there was one incorrect calculation of returned funds for a student that withdrew during a term due to an incorrect calendar setup. Criteria: 34 CFR 668.22 Questioned Costs: $-0- Context: Out of 6 students, 1 student who withdrew during the audit period tested had funds returned 78 days late while the financial aid director was unavailable. The fall 2022 traditional calendar did not include the weekends as break days, resulting in one student with an overreturn of $183 of subsidized loans. Because of the error rate, this is classified as a significant deficiency. Cause: This was an oversight by Bethany in reviewing the calendar setups and cross training for while an individual was out of the office. Effect: Incorrect amounts of federal funding were returned. There was an over-return of subsidized loans of $183. Additionally one return was made late. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany run a listing of withdrawals after each semester or each module and compare the list of students who had R2T4’s completed to ensure completeness. We further recommend a 0-credit report be run at the end of each semester or module to ensure all unofficial withdrawals are followed up on so that R2T4’s are completed timely when required. We recommend an individual with appropriate return calculation knowledge review each calendar set up and recalculate the first few withdrawals manually to ensure the system is functioning as intended. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-002
Incorrect and Untimely Return of Title IV (R2T4) Funds Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew, Bethany did not always return unearned Title IV aid timely as an attendance taking school. Additionally, there was one incorrect calculation of returned funds for a student that withdrew during a term due to an incorrect calendar setup. Criteria: 34 CFR 668.22 Questioned Costs: $-0- Context: Out of 6 students, 1 student who withdrew during the audit period tested had funds returned 78 days late while the financial aid director was unavailable. The fall 2022 traditional calendar did not include the weekends as break days, resulting in one student with an overreturn of $183 of subsidized loans. Because of the error rate, this is classified as a significant deficiency. Cause: This was an oversight by Bethany in reviewing the calendar setups and cross training for while an individual was out of the office. Effect: Incorrect amounts of federal funding were returned. There was an over-return of subsidized loans of $183. Additionally one return was made late. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany run a listing of withdrawals after each semester or each module and compare the list of students who had R2T4’s completed to ensure completeness. We further recommend a 0-credit report be run at the end of each semester or module to ensure all unofficial withdrawals are followed up on so that R2T4’s are completed timely when required. We recommend an individual with appropriate return calculation knowledge review each calendar set up and recalculate the first few withdrawals manually to ensure the system is functioning as intended. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-003
Noncompliance with Federal Work Study/Federal Work Colleges Regulations DEPARTMENT OF EDUCATION ALN #: 84.033 Federal Work Study/Federal Work Colleges Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Bethany paid a student who was on SAP suspension federal work colleges dollars. Criteria: 34 CFR 668.32(f) Questioned Costs: $327 Context: Bethany had not received an approved appeal for one student after the fall semester. The student continued to work and was coded as federal work colleges instead of institutional work colleges. Cause: Bethany removed all aid except the coding of the federal work colleges after the student was on financial aid suspension. Effect: Noncompliance with federal work colleges requirements Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany review eligibility each semester in light of any satisfactory academic progress suspensions. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-004
Need Analysis DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: A student was not appropriately paid subsidized aid based on need. Criteria: 34 CFR 685.203 Questioned Costs: $-0- Context: 1 student out of 51 was initially under awarded subsidized loans of $1,592. Cause: Bethany awarded the student the full eligibility of subsidized and unsubsidized loans. The student declined a portion of the subsidized loans and all of the unsubsidized loans. Bethany’s clean up reports did not identify this student as needing to have paid the full subsidized eligibility first. Effect: Incorrect allocation of subsidized versus unsubsidized affects the amount and timing of interest the student must repay. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany add a step in the clean up reports that looks for students with remaining need and acceptance of loans to ensure proper allocation has occurred. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-005
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Bethany did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: Bethany has contracted with a third party to assist with compliance with GLBA. Bethany is in the process of fully documenting its information security program. Bethany has implemented multi-factor authentication (MFA) on some systems that contain personally identifiable information and is working to implement MFA on the remaining systems. Bethany is also working to implement sufficient continuous monitoring, such as penetration testing and vulnerability scanning. Cause: The timing of the contracting by Bethany has not allowed all updated components of GLBA to be addressed and documented during the audit process. Effect: Bethany may have unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany work with the third party and determine timeframes remaining to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-005
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Bethany did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: Bethany has contracted with a third party to assist with compliance with GLBA. Bethany is in the process of fully documenting its information security program. Bethany has implemented multi-factor authentication (MFA) on some systems that contain personally identifiable information and is working to implement MFA on the remaining systems. Bethany is also working to implement sufficient continuous monitoring, such as penetration testing and vulnerability scanning. Cause: The timing of the contracting by Bethany has not allowed all updated components of GLBA to be addressed and documented during the audit process. Effect: Bethany may have unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany work with the third party and determine timeframes remaining to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-005
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Bethany did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: Bethany has contracted with a third party to assist with compliance with GLBA. Bethany is in the process of fully documenting its information security program. Bethany has implemented multi-factor authentication (MFA) on some systems that contain personally identifiable information and is working to implement MFA on the remaining systems. Bethany is also working to implement sufficient continuous monitoring, such as penetration testing and vulnerability scanning. Cause: The timing of the contracting by Bethany has not allowed all updated components of GLBA to be addressed and documented during the audit process. Effect: Bethany may have unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany work with the third party and determine timeframes remaining to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-005
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Bethany did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: Bethany has contracted with a third party to assist with compliance with GLBA. Bethany is in the process of fully documenting its information security program. Bethany has implemented multi-factor authentication (MFA) on some systems that contain personally identifiable information and is working to implement MFA on the remaining systems. Bethany is also working to implement sufficient continuous monitoring, such as penetration testing and vulnerability scanning. Cause: The timing of the contracting by Bethany has not allowed all updated components of GLBA to be addressed and documented during the audit process. Effect: Bethany may have unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany work with the third party and determine timeframes remaining to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-002
Incorrect and Untimely Return of Title IV (R2T4) Funds Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew, Bethany did not always return unearned Title IV aid timely as an attendance taking school. Additionally, there was one incorrect calculation of returned funds for a student that withdrew during a term due to an incorrect calendar setup. Criteria: 34 CFR 668.22 Questioned Costs: $-0- Context: Out of 6 students, 1 student who withdrew during the audit period tested had funds returned 78 days late while the financial aid director was unavailable. The fall 2022 traditional calendar did not include the weekends as break days, resulting in one student with an overreturn of $183 of subsidized loans. Because of the error rate, this is classified as a significant deficiency. Cause: This was an oversight by Bethany in reviewing the calendar setups and cross training for while an individual was out of the office. Effect: Incorrect amounts of federal funding were returned. There was an over-return of subsidized loans of $183. Additionally one return was made late. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany run a listing of withdrawals after each semester or each module and compare the list of students who had R2T4’s completed to ensure completeness. We further recommend a 0-credit report be run at the end of each semester or module to ensure all unofficial withdrawals are followed up on so that R2T4’s are completed timely when required. We recommend an individual with appropriate return calculation knowledge review each calendar set up and recalculate the first few withdrawals manually to ensure the system is functioning as intended. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-002
Incorrect and Untimely Return of Title IV (R2T4) Funds Calculations Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew, Bethany did not always return unearned Title IV aid timely as an attendance taking school. Additionally, there was one incorrect calculation of returned funds for a student that withdrew during a term due to an incorrect calendar setup. Criteria: 34 CFR 668.22 Questioned Costs: $-0- Context: Out of 6 students, 1 student who withdrew during the audit period tested had funds returned 78 days late while the financial aid director was unavailable. The fall 2022 traditional calendar did not include the weekends as break days, resulting in one student with an overreturn of $183 of subsidized loans. Because of the error rate, this is classified as a significant deficiency. Cause: This was an oversight by Bethany in reviewing the calendar setups and cross training for while an individual was out of the office. Effect: Incorrect amounts of federal funding were returned. There was an over-return of subsidized loans of $183. Additionally one return was made late. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany run a listing of withdrawals after each semester or each module and compare the list of students who had R2T4’s completed to ensure completeness. We further recommend a 0-credit report be run at the end of each semester or module to ensure all unofficial withdrawals are followed up on so that R2T4’s are completed timely when required. We recommend an individual with appropriate return calculation knowledge review each calendar set up and recalculate the first few withdrawals manually to ensure the system is functioning as intended. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-003
Noncompliance with Federal Work Study/Federal Work Colleges Regulations DEPARTMENT OF EDUCATION ALN #: 84.033 Federal Work Study/Federal Work Colleges Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Bethany paid a student who was on SAP suspension federal work colleges dollars. Criteria: 34 CFR 668.32(f) Questioned Costs: $327 Context: Bethany had not received an approved appeal for one student after the fall semester. The student continued to work and was coded as federal work colleges instead of institutional work colleges. Cause: Bethany removed all aid except the coding of the federal work colleges after the student was on financial aid suspension. Effect: Noncompliance with federal work colleges requirements Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany review eligibility each semester in light of any satisfactory academic progress suspensions. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-004
Need Analysis DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: A student was not appropriately paid subsidized aid based on need. Criteria: 34 CFR 685.203 Questioned Costs: $-0- Context: 1 student out of 51 was initially under awarded subsidized loans of $1,592. Cause: Bethany awarded the student the full eligibility of subsidized and unsubsidized loans. The student declined a portion of the subsidized loans and all of the unsubsidized loans. Bethany’s clean up reports did not identify this student as needing to have paid the full subsidized eligibility first. Effect: Incorrect allocation of subsidized versus unsubsidized affects the amount and timing of interest the student must repay. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany add a step in the clean up reports that looks for students with remaining need and acceptance of loans to ensure proper allocation has occurred. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-005
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Bethany did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: Bethany has contracted with a third party to assist with compliance with GLBA. Bethany is in the process of fully documenting its information security program. Bethany has implemented multi-factor authentication (MFA) on some systems that contain personally identifiable information and is working to implement MFA on the remaining systems. Bethany is also working to implement sufficient continuous monitoring, such as penetration testing and vulnerability scanning. Cause: The timing of the contracting by Bethany has not allowed all updated components of GLBA to be addressed and documented during the audit process. Effect: Bethany may have unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany work with the third party and determine timeframes remaining to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-005
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Bethany did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: Bethany has contracted with a third party to assist with compliance with GLBA. Bethany is in the process of fully documenting its information security program. Bethany has implemented multi-factor authentication (MFA) on some systems that contain personally identifiable information and is working to implement MFA on the remaining systems. Bethany is also working to implement sufficient continuous monitoring, such as penetration testing and vulnerability scanning. Cause: The timing of the contracting by Bethany has not allowed all updated components of GLBA to be addressed and documented during the audit process. Effect: Bethany may have unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany work with the third party and determine timeframes remaining to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-005
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Bethany did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: Bethany has contracted with a third party to assist with compliance with GLBA. Bethany is in the process of fully documenting its information security program. Bethany has implemented multi-factor authentication (MFA) on some systems that contain personally identifiable information and is working to implement MFA on the remaining systems. Bethany is also working to implement sufficient continuous monitoring, such as penetration testing and vulnerability scanning. Cause: The timing of the contracting by Bethany has not allowed all updated components of GLBA to be addressed and documented during the audit process. Effect: Bethany may have unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany work with the third party and determine timeframes remaining to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-005
Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Bethany did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $-0- Context: Bethany has contracted with a third party to assist with compliance with GLBA. Bethany is in the process of fully documenting its information security program. Bethany has implemented multi-factor authentication (MFA) on some systems that contain personally identifiable information and is working to implement MFA on the remaining systems. Bethany is also working to implement sufficient continuous monitoring, such as penetration testing and vulnerability scanning. Cause: The timing of the contracting by Bethany has not allowed all updated components of GLBA to be addressed and documented during the audit process. Effect: Bethany may have unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend Bethany work with the third party and determine timeframes remaining to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.