EDEN THEOLOGICAL SEMINARY

U.S. Department of Education Finding 2021-001 (continuing finding): Policies and Procedures Related to Withdrawals ? SFA Cluster (significant deficiency) Statement of Condition: This is a continuing finding from the prior audit. We found instances for which the Seminary did not properly comply with the U.S. Department of Education?s requirements for reporting changes in student status to the National Student Loan Data System (NSLDS). Criteria: Requirements for processing and reporting Title IV withdrawals are provided in 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdraws. These procedures should be followed by all schools administering Title IV funding. Cause of Condition: The Seminary?s policies and procedures are inadequate to allow for the institution?s student aid personnel to comply with the requirements set forth by the U.S. Department of Education related to the Title IV withdrawal process. Effect of Condition: The lack of review over the withdrawal process resulted in the Seminary incorrectly processing withdrawals. We found instances where changes in student status due to withdrawal were not reported to the NSLDS in the time frame required by the U.S. Department of Education. Recommendation: We recommend the Seminary properly report any student status changes to the NSLDS. Management?s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.

Finding 2021-002: Inaccurate Reporting of Disbursement Dates to the COD System -SFA Cluster Statement of Condition: The Seminary does not c011sistently report disbursement dates in the COD system correctly. Effect of Condition: The Seminary's inconsistent reporting caused one (I) out of five (5) students tested to be incorrectly reported in the COD system. Recommendation: The auditors recommend the Seminary establish and follow COD reporting procedures to ensure that the institution consistently repo1is the correct date that the institution disburses Title IV funds to each student's ledger account in the COD system. Corrective Action Plan: Step One - Root Cause Analysis: Eden recognizes that it did not consistently follow their own policy related to COD reporting. This led to inaccurate reporting of award dates that did not agree with the information listed in the COD files. Step Two - Corrective Measure: Eden Seminary's Financial Aid Director, Registrar and Accounting Personnel will work together to ensure that all members work to have access to the COD system so that the accuracy of such information can be verified and updated as needed. Step Three - Expected Outcomes: Eden Seminary will implement new updates to its COD, NSLDS and all Financial Aid databases so that new perso1111el can access these systems to ensure that all information is accurate. In addition, Eden perso1111el will work to create a policy as it relates to the timely review and updating of COD files to ensure accuracy going forward. The policy shall require the monthly review of disbursements in COD are completed ensuring that all disbursements for the month are posted with the correct disbursement dates. Step Four - Follow-Up and Monitor Compliance: Eden Seminary's Financial Aid Director, Registrar and Accounting Personnel will work together to ensure the accuracy of the data that is communicated to all Title IV system according to the US Department of Education, 34 CFR 668. I 64(a), Disbursing Funds, an institution makes a disbursement of Title IV, HEA funds on the date that the institution credits a student's account at the institution or pays a student or parent directly with funds received from the Secretary; or institutional funds used in advance of receiving Title IV, HEA funds.

2020-001

Finding 2021-002 (continuing finding): Inaccurate Reporting of Disbursement Dates to the COD System ? SFA Cluster (significant deficiency) Statement of Condition: This is a continuing finding from the prior audit. The Seminary does not consistently report disbursement dates in the COD system correctly. Criteria: According to 34 CFR 668.164(a), Disbursing Funds, an institution makes a disbursement of Title IV, HEA funds on the date that the institution credits a student?s account at the institution or pays a student or parent directly with funds received from the Secretary; or institutional funds used in advance of receiving Title IV, HEA funds. Cause of Condition: The Seminary did not consistently follow their policy related to COD reporting to ensure that the date awards are disbursed to students agrees to the date the disbursement is reported in the COD system. Effect of Condition: The Seminary?s inconsistent reporting caused five (5) out of five (5) students tested to be incorrectly reported in the COD system. Recommendation: We recommend the Seminary establish and follow COD reporting procedures to ensure that the institution consistently reports the correct date that the institution disburses Title IV funds to each student?s ledger account in the COD system. Management?s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.

Finding 2021-001 (continuing finding): Policies and Procedures Related to Withdrawals - SFA Cluster (significant deficiency) Statement of Condition: This is a continuing finding from the prior audit. We found instances for which the Seminary did not properly comply with the U.S. Department of Education's requirements for reporting changes in student status to the National Student Loan Data System (NSLDS). Criteria: Requirements for processing and reporting Title IV withdrawals are provided in 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdraws. These procedures should be followed by all schools administering Title IV funding. Cause of Condition: The Seminary's policies and procedures are inadequate to allow for the institution's student aid personnel to comply with the requirements set forth by the U.S. Department of Education related to the Title IV withdrawal process. Effect of Condition: The lack of review over the withdrawal process resulted in the Seminary incorrectly processing withdrawals. We found instances where changes in student status due to withdrawal were not reported to the NSLDS in the time frame required by the U.S. Department of Education. Recommendation: We recommend the Seminary properly report any student status changes to the NSLDS. Corrective Action Plan Response Outline: Step One: Root Cause Analysis. For Eden to be able to give a solution to any problem, we must recognize the nature of the issues involved. The nature of the errors made in this finding are related to a misunderstanding of the process by which enrollment was being submitted to NSLDS. In early October 2021, the staff member responsible for reporting enrollment to third party agencies, including NSLDS, found that our third party federal loan processor, Campus Ivy, was not reporting enrollment to NSLDS. This was a change in process that we were unaware of. Upon discovery, all records in NSLDS were updated immediately. Step Two: Corrective Measures To correct this, Eden Seminary's Registrar has implemented a monthly NSLDS reporting schedule. Rosters will be sent to Eden's SAIG mailbox on the 15th of each month and updated via enrollment submittal files directly to NSLDS.Step Three: Expected Outcomes The expected outcomes of implementing our stated corrective measures is a reduction in errors made related to student's withdrawals and returns of federal loan monies. Step Four: Implement the Plan The implementation of this plan will be the responsibility of the Registrar with oversight by the Dean of the Seminary.

2020-002

U.S. Department of Education Finding 2020-001: Policies and Procedures Related to Withdrawals ? SFA Cluster (significant deficiency) Statement of Condition: From our testing sample, we found numerous instances for which the Seminary did not properly comply with the U.S. Department of Education?s requirements for reporting and returning student financial aid. Criteria: Requirements for processing and reporting Title IV withdrawals are provided in 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdraws. These procedures should be followed by all schools administering Title IV funding. Cause of Condition: The Seminary?s policies and procedures are inadequate to allow for the institution?s student aid personnel to comply with the requirements set forth by the U.S. Department of Education related to the Title IV withdrawal process. Effect of Condition: The lack of review over the withdrawal process resulted in the Seminary incorrectly processing withdrawals. We found instances where the Return to Title IV (R2T4) calculations did not have the correct payment period length, instances where changes in student status due to withdrawal were not reported timely, an instance where an R2T4 was completed for a student who was on an approved leave of absence, and instances where the incorrect date of determination of withdrawal was used. Recommendation: We recommend the Seminary correct any amounts and R2T4 forms incorrectly calculated during the year ended June 30, 2020, and properly report any student changes to the NSLDS. We also recommend the Seminary update internal control procedures to ensure that the Department of Education?s guidelines are properly followed to calculate Title IV withdrawals. Management?s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.

Finding 2020-001: Policies and Procedures Related to Withdrawals ? SFA Cluster Statement of Condition: From the auditors? testing sample, they found numerous instances for which the Seminary did not properly comply with the U.S. Department of Education?s requirements for reporting and returning student financial aid. Effect of Condition: The lack of review over the withdrawal process resulted in the Seminary incorrectly processing withdrawals. The auditors found instances where the Return to Title IV (R2T4) calculations did not have the correct payment period length, instances where changes in student status due to withdrawal were not reported timely, an instance where an R2T4 was completed for a student who was on an approved leave of absence, and instances where the incorrect date of determination of withdrawal was used. Recommendation: The auditors recommend the Seminary correct any amounts and R2T4 forms incorrectly calculated during the year ended June 30, 2020, and properly report any student changes to the NSLDS. The auditors also recommend the Seminary update internal control procedures to ensure that the Department of Education?s guidelines are properly followed to calculate Title IV withdrawals. Corrective Action Plan: Root Cause Analysis: The Accounting Department posts disbursement dates and corrections based primarily on the date funds were deposited or returned by request of the US Department of Education or the Financial Aid Officer. However, due to a need for better controls regarding R2T4s related to a better definition of ?Leave of Absences? vs. ?Withdrawal? status, funds were not posted in a timely manner on the request. Corrective Measures: The Financial Aid Director, Registrar, and Accounting Personnel will work together to create policies for the accurate return of funds based on the criteria found in the Requirements for processing and reporting Title IV withdrawals as provided in 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdraws. This policy will be reviewed and edited annually to assure compliance is met and controls are enforced as indicated by the US Department of Education related to the Title IV withdrawal process. Expected Outcome: By following the criteria for timely processing of refunds related to withdrawals found in 34 CFR 668.22, Treatment of Title IV Funds When a Student Withdraws, financial aid personnel will work together to return funds, post the correct dates for return of funds, and review standards for compliance going forward. Implementation Plan: The oversight of this process will be managed by the Financial Aid Director with oversight by the Dean of Students (see included ?Updated Withdrawal/Return Procedures?). Follow-up and Monitor Compliance: In addition to oversight by a designated Financial Aid Director and the Dean of Students, Eden contracts with a virtual financial aid office (VFAO) who processes their R2T4s with the US Department of Education. In the fall of 2020, we converted to a new VFAO who will assists to ensure that the requirements laid out by the US Department of Education in 34 CFR 68.22 are met. Updated Withdrawal/Return Procedures When a student chooses to stop attending classes prior to the completion of a term, the student, in consultation with the Dean of Students, will either withdraw from classes or begin an official Leave of Absence (LOA). Students who go on an approved LOA at Eden do not return to their studies within the course of the term in which they went on an LOA, therefore both of these statuses (Withdrawal and LOA) are treated as Withdrawals for the purpose of R2T4 calculations and enrollment status in NSLDS. The Dean of Students will notify the Registrar when a student?s status has changed from enrolled to Withdrawn or Leave of Absence. The Registrar will then notify the Financial Aid Director of the student?s status change and determine if an R2T4 calculation is necessary. If necessary, the Financial Aid Director will begin the R2T4 process, utilizing Eden?s Refund policy for refunds of institutional charges. Once the withdrawal calc is completed, the Registrar will review form for accuracy in dates used to perform calculations. Accounting personnel will review the form for accuracy in tuition and aid calculations. The Financial Aid Director prepares a letter to the student explaining the results of the calculation and verifies the final amounts with Accounting who will also make the necessary changes to the student's account. Documentation is then uploaded to Campus Ivy who performs the return in G5. A copy of the G5 return confirmation is then sent back to the Accounting Office so they can verify the accuracy and timely return of funds. When the Seminary determines a student has withdrawn from classes but has failed to go through the withdrawal process, the Dean?s Office or Registrar contacts the student and ensures the appropriate documentation is received from the student. Should a student not respond with the appropriate documentation within a 2-week period, the student will be administratively withdrawn from the institution and processed according to our procedures stated above. At the end of each semester, the Registrar?s Office reviews a list of students who earned a 0.00 GPA for that semester. If there is any question on the students' status the Registrar?s Office will verify with the professors whether a grade was earned. For those considered an unofficial withdrawal receiving federal funds, a R2T4 calculation is performed. If the last date of attendance cannot be determined, the midpoint of the semester is used as the withdrawal date in the calculation. Students are informed of their exit counseling requirement via email from the Financial Aid Officer to complete the exit counseling online at StudentLoans.gov. They are asked to complete this requirement within 30 days of the date of withdrawal.

Finding 2020-002: Inaccurate Reporting of Disbursement Dates to the COD System ? SFA Cluster (significant deficiency) Statement of Condition: The Seminary does not consistently report disbursement dates in the COD system correctly. Criteria: According to 34 CFR 668.164(a), Disbursing Funds, an institution makes a disbursement of Title IV, HEA funds on the date that the institution credits a student?s account at the institution or pays a student or parent directly with funds received from the Secretary; or institutional funds used in advance of receiving Title IV, HEA funds. Cause of Condition: The Seminary did not consistently follow their policy related to COD reporting to ensure that the date awards are disbursed to students agrees to the date the disbursement is reported in the COD system. Effect of Condition: The Seminary?s inconsistent reporting caused one (1) out of five (5) students tested to be incorrectly reported in the COD system. Recommendation: We recommend the Seminary establish and follow COD reporting procedures to ensure that the institution consistently reports the correct date that the institution disburses Title IV funds to each student?s ledger account in the COD system. Management?s Response: Management agrees and will submit a Corrective Action Plan to implement these recommendations immediately.

Finding 2020-002: Inaccurate Reporting of Disbursement Dates to the COD System ? SFA Cluster Statement of Condition: The Seminary does not consistently report disbursement dates in the COD system correctly. Effect of Condition: The Seminary?s inconsistent reporting caused one (1) out of five (5) students tested to be incorrectly reported in the COD system. Recommendation: The auditors recommend the Seminary establish and follow COD reporting procedures to ensure that the institution consistently reports the correct date that the institution disburses Title IV funds to each student?s ledger account in the COD system. Corrective Action Plan: Root Cause Analysis: Eden recognizes that it did not consistently follow their own policy related to COD reporting. This led to inaccurate reporting of award dates that did not agree with the information listed in the COD files. Corrective Measure: Eden Seminary?s Financial Aid Director, Registrar, and Accounting Personnel will work together to ensure that all members work to have access to the COD system so that the accuracy of such information can be verified and updated as needed. Expected Outcomes: Eden Seminary will implement new updates to its COD, NSLDS, and all Financial Aid databases so that new personnel can access these systems to ensure that all information is accurate. In addition, Eden personnel will work to create a policy as it relates to the timely review and updating of COD files to ensure accuracy going forward. Implementation Plan: The current DPA will be updated to reflect following changes: ? Update the name and contact information for the president of the seminary; ? Update the name and contact information for the chief fiscal officer, and ? Update the name and contact information for the individual designated as the lead program administrator for the FSA programs. In addition, the COD systems and access to these systems will be turned over for updating and maintenance to the Director of Admissions and Financial Aid. Follow-Up and Monitor Compliance: Eden Seminary?s Financial Aid Director, Registrar, and Accounting Personnel will work together to ensure the accuracy of the data that is communicated to all Title IV system according to the US Department of Education, 34 CFR 668.164(a), Disbursing Funds, an institution makes a disbursement of Title IV, HEA funds on the date that the institution credits a student?s account at the institution or pays a student or parent directly with funds received from the Secretary; or institutional funds used in advance of receiving Title IV, HEA funds. In addition, Eden will revisit our internal policies annually to ensure that all Financial Aid personnel are aware of and maintain accurate records in accordance with the US Department of Education?s requirements for disbursement of Title IV funds.