DENVER SEMINARY

Untimely Returns of Title IV Funds (R2T4) Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2023-2024 Award Year Condition: There were 2 late returns of funds for students that withdrew during the term and 1 additional late return of funds for a student that did not attend the term. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: 2 of 7 withdrawals tested had returns that were 109 and 259 days late totaling $622 and $668, respectively. 1 out of 7 had a late return of 128 days for $4,750 due to a delayed determination of non-attendance. These errors were discovered and corrected during the audit. After these errors were discovered, the Seminary completed a full file review of all 16 withdrawals to ensure accurate and timely R2T4 calculations noting no additional errors. Cause: The Seminary had staff turnover in the registrar’s office which caused miscommunication between the registrar and financial aid office as well as inaccurate system reports. Because of the inaccurate system reports, the student who didn’t attend wasn’t identified. Additionally, because of the reporting problem, the original returns for students that formally withdrew were based on an inaccurate last day of attendance used in the R2T4 calculation and the late return was due to the correction of the original returns. Effect: Federal funding was returned late. Identification as repeat finding, if applicable: N/A Recommendation: We recommend that the Seminary review all dates provided by Campus Nexus reports to verify correct last day of attendance is used in R2T4 calculations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.033 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The Seminary did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The Seminary has not implemented multi-factor authentication on all systems containing personally identifiable information (PII) or had the qualified individual approve in writing the exception. Additionally, the written, annual report to the board does not include all the required areas based on the updated regulations. Cause: The Seminary has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA. Effect: The Seminary has a couple of gaps to adequately address the updated requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We commend the Seminary for the work completed on GLBA. We recommend the Seminary allocate sufficient resources to address the remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.