Emmanuel UniversityHigher Education

Finding: Item 2022-001 ? Special Tests and Provisions: Return of Title IV Funds Federal Program ? Federal Direct Student Loans Federal Agency ? Department of Education CFDA Number 84.268 Federal Award Number ? P268K221302 Federal Award Year ? June 30, 2022 Pass-Through Entity ? Not Applicable Criteria: Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew per 34 CFR 668.173(b). Condition: Out of a sample of 108 students there were 20 who withdrew. We decided to test all 20 of those students as it related to return of Title IV funds. Return of funds were sent in by the required date except for two instances. One was late due to the Thanksgiving Holiday. The school was closed on that Thursday and Friday, so the funds were not submitted until the following Monday. This was not a big deal; however, the other instance was simply late by 4 days and no Holidays were involved. Cause: Simply an oversight in which the date simply slipped by them. Effect: The Department of Education received the transferred return of funds 4 days later than they were required to be deposited into the SFA account. Recommendation: College management should design and implement procedures to ensure that there are checks and balances to make sure that when a student withdraws and the return of funds are calculated that the required return date is flagged and sent to whomever is responsible for submitting those funds to the SFA account. Management?s Response and Corrective Action Plan: Financial Aid personnel will utilize a built in Return to Title IV feature of the financial aid software, PowerFaids, to function as a quality assurance measure for Accounting Office staff. The PowerFaids function archives the date of withdrawal and calculates the deadline for return of funds. This feature will allow for quality assurance reports to be pulled no less than a week before the deadline so that Financial Aid staff can serve as an accountability partner for Accounting staff in ensuring funds are returned in a timely fashion and in compliance with all federal guidelines.

Finding: Item 2021-001 ? Special Tests and Provisions: Disbursements to or on Behalf of Students Federal Program ? Federal Direct Student Loans Federal Agency ? Department of Education CFDA Number 84.268 Federal Award Number ? P268K211302 Federal Award Year ? June 30, 2021 Pass-Through Entity ? Not Applicable Criteria: Institutions may not disburse or deliver the first installment of Direct Loans to first-year undergraduates who are first-time borrowers until 30 days after the student?s first day of classes per 34 CFR 668.164(i)(2) unless the institution has low default rates of less than 15 percent for each of the three most recent fiscal years for which data are available. Condition: Out of a sample of 103 students in which 7 were first-year undergraduates, all 7 of those students received their loan funds prior to the 30 day wait period required due to the cohort default rate issues. Cause: On the Administration side of PowerFAIDS, the First-Time Borrower Wait Period was set to 30 days. However, the First-Time Borrower box was not populated on each of the individual loans under each first-time borrower. Effect: Some first-time borrowers received their loan disbursements before the 30 day hold period was up. Recommendation: College management should design and implement procedures to ensure that there are checks and balances to make sure that what is entered into PowerFAIDS is being populated correctly and hence carried out as expected. Management?s Response and Corrective Action Plan: This was corrected last year after the 2020 audit, but was not found until after two years had been done incorrectly. Once management noticed that first-time loans were being disbursed, they reached out to PowerFAIDS to let them know. They informed management that they were missing the step of populating the First-Time Borrower box within each individual loan for each first-time borrower. Once this was known, this problem was corrected. Nothing more needs to be done.

Finding: Item 2020-001 ? Special Tests and Provisions: Disbursements to or on Behalf of Students Federal Program ? Federal Direct Student Loans Federal Agency ? Department of Education CFDA Number 84.268 Federal Award Number ? P268K201302 Federal Award Year ? June 30, 2020 Pass-Through Entity ? Not Applicable Criteria: Institutions may not disburse or deliver the first installment of Direct Loans to first-year undergraduates who are first-time borrowers until 30 days after the student?s first day of classes per 34 CFR 668.164(i)(2) unless the institution has low default rates of less than 15 percent for each of the three most recent fiscal years for which data are available. Condition: Out of a sample of 111 students in which 21 were first-year undergraduates, 17 of those students received their loan funds prior to the 30 day wait period required due to the cohort default rate issues. Cause: On the Administration side of PowerFAIDS, the First-Time Borrower Wait Period was set to30 days. However, the First-Time Borrower box was not populated on each of the individual loans under each first-time borrower. Effect: Some first-time borrowers received their loan disbursements before the 30 day hold period was up. Recommendation: College management should design and implement procedures to ensure that there are checks and balances to make sure that what is entered into PowerFAIDS is being populated correctly and hence carried out as expected.