FAC Explorer

Audit 395694

FY End
2025-06-30
Total Expended
$1.62M
Findings
2
Programs
1
Organization: Payne Theological Seminary (OH)
Year: 2025 Accepted: 2026-03-30
Auditor: CLIFTONLARSONALLEN LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
1200659 2025-001 Material Weakness Yes L
1200660 2025-002 Material Weakness Yes N

Programs

ALN Program Spent Major Findings
84.268 FEDERAL DIRECT STUDENT LOANS $1.62M Yes 2

Contacts

Name Title Type
KYNLFYN41TV5 Raymond Ingram Auditee
9373762946 Chad Lassen Auditor
No contacts on file

Notes to SEFA

The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal award activity of Payne Theological Seminary under programs of the federal government for the year ended June 30, 2025. The information in this Schedule is presented in accordance with the requirements of 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of Payne Theological Seminary, it is not intended to and does not present the financial position, changes in net assets, or cash flows of Payne Theological Seminary. There were no subrecipients in the current year.
The Institution is in compliance with the following institutional and program eligibility requirements under the Higher Education Act of 1965 and Federal regulations under 34 CFR 668.23:  Correspondence courses the institution offers under 34 CFR 600.7(b) and (g)  Regular students that enroll in correspondence courses under 34 CFR 600.7(b) and (g)  Institution’s regular students that are incarcerated under 34 CFR 600.7(c) and (g)  Completion rates for confined or incarcerated individuals enrolled in non-degree programs at nonprofit institutions under 34 CFR 600.7(c)(3)(ii) and (g)  Institution’s regular students that lack a high school diploma or its equivalent under 34 CFR 600.7(d) and (g)  Completion rates for short-term programs under 34 CFR 668.8(f) and (g)  Placement rates for short-term programs under https://www.ecfr.gov/current/title- 34/subtitle-B/chapter-VI/part-668/subpart-A/section-668.8 34 CFR 668.8(e)(2)

Finding Details

Finding 2025-001
2025-001: Common Origination and Disbursement (COD) Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster ALN Numbers: 84.268 – Federal Direct Loan Program Award Period: July 1, 2024 through June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted 9 out of the 29 student's disbursement date per the Seminary’s record did not match the date reported to COD. Questioned Costs: None Context: During our testing, it was noted the Seminary does not have a process in place to ensure accurate reporting of disbursement dates to COD based on the regulations set forth by the Department of Education. Cause: The Seminary does not have a process in place to accurately report the date of disbursements. Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: Yes – See 2024-001 Recommendation: We recommend the Seminary evaluate its procedures and policies around reporting Unsubsidized loan disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2025-002
2025-002: Gramm-Leach Bliley Act (GLBA) Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster ALN Numbers: 84.268 – Federal Direct Loan Program Award Period: July 1, 2024 through June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program (WISP) for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Condition: During our testing, we noted several steps missing from the Written Information Security Program (WISP). Questioned Costs: None Context: There are elements missing from the Seminary’s WISP that are part of the GLBA requirements. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: Student personal information could be vulnerable. Repeat Finding: Yes – See 2024-003 Recommendation: We recommend that the Seminary review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials: There is no disagreement with the audit finding.