Audit 295860

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268 Program Expenditures: $38,687,691 Program Name: Federal Pell Grant Program, Federal Direct Student Loans Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, and P268K231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely enrollment reporting for all students within the required time period. During our testing of Pell or Direct Loan borrowers, we noted 21 out of 40 (53%) students campus-level record and program-level record were not updated within the required time frame, ranging from 11-52 days late. For 19 out of the 21 students noted above, we also noted the enrollment effective date was incorrect (19 out of 40 students tested, 48%). The sample was not a statistically valid sample. The University is required to report enrollment reporting changes no less than every 60 days. During the year, there were underlying problems with how data was being submitted to the National Student Clearinghouse (NSC), resulting in enrollment status changes and degree confirmations not being reported timely for 21 students tested or accurately for 19 students tested. Noted, while the University had a policy in place to ensure enrollment reporting for degree confirmations and status changes were being submitted to the NSC at least every 30 days, there was a flaw in the University’s process that caused enrollment status changes and degree confirmations submitted to the NSC to not ultimately be submitted to National Student Loan Data System (NSLDS), resulting in enrollment reporting changes to be reported greater than 60 days after program enrollment effective date (for 21 students tested) and in some cases, with incorrect enrollment effective date (for 19 out of the 21 students noted above). For the Federal Pell Grant Program, 34 CFR Section 690.83(b)(2) requires an institution to submit in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct. For the Federal Direct Student Loans, 34 CFR Section 685.309(b) requires changes in student status to be reported to the NSLDS within 30 days of the change or included in a Student Status Confirmation Report (SSCR) sent to the NSLDS within 60 days of the status change. Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is accurate and timely. University officials indicated the University did not have adequate procedures in place to ensure all required campus-level data and program-level data was being reported to NSLDS via NSC due to a flaw in their process causing degree confirmations to be overridden with other enrollment information prior to submission. The University did not have an appropriate enrollment reporting timeline to ensure student status changes were reported in the required time frame. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately or timely. Inaccurate or untimely reporting of student enrollment data can result in inconsistencies between the University’s records and the National Students Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2023-001, 2022-002) RECOMMENDATION We recommend the University implement controls to ensure that all enrollment status changes and degree confirmations are being appropriately reported through NSC to NSLDS and that submissions of degree confirmations to NSC are appropriate to ensure enrollment status changes are reported at least every 60 days. We also recommend these controls be monitored to ensure that all necessary information is reported within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Procedural changes have been identified and internal controls will be implemented moving forward to ensure that enrollment status changes and degree confirmations are being appropriately submitted and reported, and that they are done so in a timely manner.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268 Program Expenditures: $38,687,691 Program Name: Federal Pell Grant Program, Federal Direct Student Loans Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, and P268K231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely enrollment reporting for all students within the required time period. During our testing of Pell or Direct Loan borrowers, we noted 21 out of 40 (53%) students campus-level record and program-level record were not updated within the required time frame, ranging from 11-52 days late. For 19 out of the 21 students noted above, we also noted the enrollment effective date was incorrect (19 out of 40 students tested, 48%). The sample was not a statistically valid sample. The University is required to report enrollment reporting changes no less than every 60 days. During the year, there were underlying problems with how data was being submitted to the National Student Clearinghouse (NSC), resulting in enrollment status changes and degree confirmations not being reported timely for 21 students tested or accurately for 19 students tested. Noted, while the University had a policy in place to ensure enrollment reporting for degree confirmations and status changes were being submitted to the NSC at least every 30 days, there was a flaw in the University’s process that caused enrollment status changes and degree confirmations submitted to the NSC to not ultimately be submitted to National Student Loan Data System (NSLDS), resulting in enrollment reporting changes to be reported greater than 60 days after program enrollment effective date (for 21 students tested) and in some cases, with incorrect enrollment effective date (for 19 out of the 21 students noted above). For the Federal Pell Grant Program, 34 CFR Section 690.83(b)(2) requires an institution to submit in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct. For the Federal Direct Student Loans, 34 CFR Section 685.309(b) requires changes in student status to be reported to the NSLDS within 30 days of the change or included in a Student Status Confirmation Report (SSCR) sent to the NSLDS within 60 days of the status change. Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is accurate and timely. University officials indicated the University did not have adequate procedures in place to ensure all required campus-level data and program-level data was being reported to NSLDS via NSC due to a flaw in their process causing degree confirmations to be overridden with other enrollment information prior to submission. The University did not have an appropriate enrollment reporting timeline to ensure student status changes were reported in the required time frame. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately or timely. Inaccurate or untimely reporting of student enrollment data can result in inconsistencies between the University’s records and the National Students Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2023-001, 2022-002) RECOMMENDATION We recommend the University implement controls to ensure that all enrollment status changes and degree confirmations are being appropriately reported through NSC to NSLDS and that submissions of degree confirmations to NSC are appropriate to ensure enrollment status changes are reported at least every 60 days. We also recommend these controls be monitored to ensure that all necessary information is reported within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Procedural changes have been identified and internal controls will be implemented moving forward to ensure that enrollment status changes and degree confirmations are being appropriately submitted and reported, and that they are done so in a timely manner.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268 Program Expenditures: $38,687,691 Program Name: Federal Pell Grant Program, Federal Direct Student Loans Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, and P268K231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely enrollment reporting for all students within the required time period. During our testing of Pell or Direct Loan borrowers, we noted 21 out of 40 (53%) students campus-level record and program-level record were not updated within the required time frame, ranging from 11-52 days late. For 19 out of the 21 students noted above, we also noted the enrollment effective date was incorrect (19 out of 40 students tested, 48%). The sample was not a statistically valid sample. The University is required to report enrollment reporting changes no less than every 60 days. During the year, there were underlying problems with how data was being submitted to the National Student Clearinghouse (NSC), resulting in enrollment status changes and degree confirmations not being reported timely for 21 students tested or accurately for 19 students tested. Noted, while the University had a policy in place to ensure enrollment reporting for degree confirmations and status changes were being submitted to the NSC at least every 30 days, there was a flaw in the University’s process that caused enrollment status changes and degree confirmations submitted to the NSC to not ultimately be submitted to National Student Loan Data System (NSLDS), resulting in enrollment reporting changes to be reported greater than 60 days after program enrollment effective date (for 21 students tested) and in some cases, with incorrect enrollment effective date (for 19 out of the 21 students noted above). For the Federal Pell Grant Program, 34 CFR Section 690.83(b)(2) requires an institution to submit in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct. For the Federal Direct Student Loans, 34 CFR Section 685.309(b) requires changes in student status to be reported to the NSLDS within 30 days of the change or included in a Student Status Confirmation Report (SSCR) sent to the NSLDS within 60 days of the status change. Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is accurate and timely. University officials indicated the University did not have adequate procedures in place to ensure all required campus-level data and program-level data was being reported to NSLDS via NSC due to a flaw in their process causing degree confirmations to be overridden with other enrollment information prior to submission. The University did not have an appropriate enrollment reporting timeline to ensure student status changes were reported in the required time frame. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately or timely. Inaccurate or untimely reporting of student enrollment data can result in inconsistencies between the University’s records and the National Students Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2023-001, 2022-002) RECOMMENDATION We recommend the University implement controls to ensure that all enrollment status changes and degree confirmations are being appropriately reported through NSC to NSLDS and that submissions of degree confirmations to NSC are appropriate to ensure enrollment status changes are reported at least every 60 days. We also recommend these controls be monitored to ensure that all necessary information is reported within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Procedural changes have been identified and internal controls will be implemented moving forward to ensure that enrollment status changes and degree confirmations are being appropriately submitted and reported, and that they are done so in a timely manner.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268 Program Expenditures: $38,687,691 Program Name: Federal Pell Grant Program, Federal Direct Student Loans Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, and P268K231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely enrollment reporting for all students within the required time period. During our testing of Pell or Direct Loan borrowers, we noted 21 out of 40 (53%) students campus-level record and program-level record were not updated within the required time frame, ranging from 11-52 days late. For 19 out of the 21 students noted above, we also noted the enrollment effective date was incorrect (19 out of 40 students tested, 48%). The sample was not a statistically valid sample. The University is required to report enrollment reporting changes no less than every 60 days. During the year, there were underlying problems with how data was being submitted to the National Student Clearinghouse (NSC), resulting in enrollment status changes and degree confirmations not being reported timely for 21 students tested or accurately for 19 students tested. Noted, while the University had a policy in place to ensure enrollment reporting for degree confirmations and status changes were being submitted to the NSC at least every 30 days, there was a flaw in the University’s process that caused enrollment status changes and degree confirmations submitted to the NSC to not ultimately be submitted to National Student Loan Data System (NSLDS), resulting in enrollment reporting changes to be reported greater than 60 days after program enrollment effective date (for 21 students tested) and in some cases, with incorrect enrollment effective date (for 19 out of the 21 students noted above). For the Federal Pell Grant Program, 34 CFR Section 690.83(b)(2) requires an institution to submit in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct. For the Federal Direct Student Loans, 34 CFR Section 685.309(b) requires changes in student status to be reported to the NSLDS within 30 days of the change or included in a Student Status Confirmation Report (SSCR) sent to the NSLDS within 60 days of the status change. Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is accurate and timely. University officials indicated the University did not have adequate procedures in place to ensure all required campus-level data and program-level data was being reported to NSLDS via NSC due to a flaw in their process causing degree confirmations to be overridden with other enrollment information prior to submission. The University did not have an appropriate enrollment reporting timeline to ensure student status changes were reported in the required time frame. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately or timely. Inaccurate or untimely reporting of student enrollment data can result in inconsistencies between the University’s records and the National Students Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2023-001, 2022-002) RECOMMENDATION We recommend the University implement controls to ensure that all enrollment status changes and degree confirmations are being appropriately reported through NSC to NSLDS and that submissions of degree confirmations to NSC are appropriate to ensure enrollment status changes are reported at least every 60 days. We also recommend these controls be monitored to ensure that all necessary information is reported within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Procedural changes have been identified and internal controls will be implemented moving forward to ensure that enrollment status changes and degree confirmations are being appropriately submitted and reported, and that they are done so in a timely manner.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268 Program Expenditures: $38,687,691 Program Name: Federal Pell Grant Program, Federal Direct Student Loans Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, and P268K231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely enrollment reporting for all students within the required time period. During our testing of Pell or Direct Loan borrowers, we noted 21 out of 40 (53%) students campus-level record and program-level record were not updated within the required time frame, ranging from 11-52 days late. For 19 out of the 21 students noted above, we also noted the enrollment effective date was incorrect (19 out of 40 students tested, 48%). The sample was not a statistically valid sample. The University is required to report enrollment reporting changes no less than every 60 days. During the year, there were underlying problems with how data was being submitted to the National Student Clearinghouse (NSC), resulting in enrollment status changes and degree confirmations not being reported timely for 21 students tested or accurately for 19 students tested. Noted, while the University had a policy in place to ensure enrollment reporting for degree confirmations and status changes were being submitted to the NSC at least every 30 days, there was a flaw in the University’s process that caused enrollment status changes and degree confirmations submitted to the NSC to not ultimately be submitted to National Student Loan Data System (NSLDS), resulting in enrollment reporting changes to be reported greater than 60 days after program enrollment effective date (for 21 students tested) and in some cases, with incorrect enrollment effective date (for 19 out of the 21 students noted above). For the Federal Pell Grant Program, 34 CFR Section 690.83(b)(2) requires an institution to submit in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct. For the Federal Direct Student Loans, 34 CFR Section 685.309(b) requires changes in student status to be reported to the NSLDS within 30 days of the change or included in a Student Status Confirmation Report (SSCR) sent to the NSLDS within 60 days of the status change. Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is accurate and timely. University officials indicated the University did not have adequate procedures in place to ensure all required campus-level data and program-level data was being reported to NSLDS via NSC due to a flaw in their process causing degree confirmations to be overridden with other enrollment information prior to submission. The University did not have an appropriate enrollment reporting timeline to ensure student status changes were reported in the required time frame. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately or timely. Inaccurate or untimely reporting of student enrollment data can result in inconsistencies between the University’s records and the National Students Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2023-001, 2022-002) RECOMMENDATION We recommend the University implement controls to ensure that all enrollment status changes and degree confirmations are being appropriately reported through NSC to NSLDS and that submissions of degree confirmations to NSC are appropriate to ensure enrollment status changes are reported at least every 60 days. We also recommend these controls be monitored to ensure that all necessary information is reported within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Procedural changes have been identified and internal controls will be implemented moving forward to ensure that enrollment status changes and degree confirmations are being appropriately submitted and reported, and that they are done so in a timely manner.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268, 84.007, 84.379 Program Expenditures: $39,082,749 Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Education Opportunity Grants, Teacher Education Assistance for College and Higher Education Grants Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, P268K231391, P007A231313, P379T221391, and P379T231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete timely return of title IV funds for all students within the required time period. During our testing of borrowers that withdrew from the University, we noted 6 out of 25 (24%) students return of title IV funds were not processed within the 45 day window, ranging from 2-12 days late. The sample was not a statistically valid sample. A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns within 45 days after the determined date of withdrawal (34 CFR 668.173(b)). Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure return of title IV funds is accurate and timely. University management indicated staffing shortages during the 2022-2023 aid year caused this to occur. Without sufficient controls in place to return title IV funds there is a greater risk that the school does not return funds timely or that students may not receive post-withdrawal disbursements timely. (Finding Code No. 2023-002) RECOMMENDATION We recommend the University implement controls to ensure that all refunds of title IV funds are initiated within 45 days of the date of determination for the students withdrawal. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Additional procedures have been put in place and additional staffing efforts will be allocated to ensure timing requirements are met as it relates to Title IV funds.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268, 84.007, 84.379 Program Expenditures: $39,082,749 Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Education Opportunity Grants, Teacher Education Assistance for College and Higher Education Grants Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, P268K231391, P007A231313, P379T221391, and P379T231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete timely return of title IV funds for all students within the required time period. During our testing of borrowers that withdrew from the University, we noted 6 out of 25 (24%) students return of title IV funds were not processed within the 45 day window, ranging from 2-12 days late. The sample was not a statistically valid sample. A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns within 45 days after the determined date of withdrawal (34 CFR 668.173(b)). Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure return of title IV funds is accurate and timely. University management indicated staffing shortages during the 2022-2023 aid year caused this to occur. Without sufficient controls in place to return title IV funds there is a greater risk that the school does not return funds timely or that students may not receive post-withdrawal disbursements timely. (Finding Code No. 2023-002) RECOMMENDATION We recommend the University implement controls to ensure that all refunds of title IV funds are initiated within 45 days of the date of determination for the students withdrawal. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Additional procedures have been put in place and additional staffing efforts will be allocated to ensure timing requirements are met as it relates to Title IV funds.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268, 84.007, 84.379 Program Expenditures: $39,082,749 Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Education Opportunity Grants, Teacher Education Assistance for College and Higher Education Grants Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, P268K231391, P007A231313, P379T221391, and P379T231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete timely return of title IV funds for all students within the required time period. During our testing of borrowers that withdrew from the University, we noted 6 out of 25 (24%) students return of title IV funds were not processed within the 45 day window, ranging from 2-12 days late. The sample was not a statistically valid sample. A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns within 45 days after the determined date of withdrawal (34 CFR 668.173(b)). Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure return of title IV funds is accurate and timely. University management indicated staffing shortages during the 2022-2023 aid year caused this to occur. Without sufficient controls in place to return title IV funds there is a greater risk that the school does not return funds timely or that students may not receive post-withdrawal disbursements timely. (Finding Code No. 2023-002) RECOMMENDATION We recommend the University implement controls to ensure that all refunds of title IV funds are initiated within 45 days of the date of determination for the students withdrawal. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Additional procedures have been put in place and additional staffing efforts will be allocated to ensure timing requirements are met as it relates to Title IV funds.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268, 84.007, 84.379 Program Expenditures: $39,082,749 Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Education Opportunity Grants, Teacher Education Assistance for College and Higher Education Grants Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, P268K231391, P007A231313, P379T221391, and P379T231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete timely return of title IV funds for all students within the required time period. During our testing of borrowers that withdrew from the University, we noted 6 out of 25 (24%) students return of title IV funds were not processed within the 45 day window, ranging from 2-12 days late. The sample was not a statistically valid sample. A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns within 45 days after the determined date of withdrawal (34 CFR 668.173(b)). Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure return of title IV funds is accurate and timely. University management indicated staffing shortages during the 2022-2023 aid year caused this to occur. Without sufficient controls in place to return title IV funds there is a greater risk that the school does not return funds timely or that students may not receive post-withdrawal disbursements timely. (Finding Code No. 2023-002) RECOMMENDATION We recommend the University implement controls to ensure that all refunds of title IV funds are initiated within 45 days of the date of determination for the students withdrawal. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Additional procedures have been put in place and additional staffing efforts will be allocated to ensure timing requirements are met as it relates to Title IV funds.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268, 84.007, 84.379 Program Expenditures: $39,082,749 Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Education Opportunity Grants, Teacher Education Assistance for College and Higher Education Grants Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, P268K231391, P007A231313, P379T221391, and P379T231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete timely return of title IV funds for all students within the required time period. During our testing of borrowers that withdrew from the University, we noted 6 out of 25 (24%) students return of title IV funds were not processed within the 45 day window, ranging from 2-12 days late. The sample was not a statistically valid sample. A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns within 45 days after the determined date of withdrawal (34 CFR 668.173(b)). Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure return of title IV funds is accurate and timely. University management indicated staffing shortages during the 2022-2023 aid year caused this to occur. Without sufficient controls in place to return title IV funds there is a greater risk that the school does not return funds timely or that students may not receive post-withdrawal disbursements timely. (Finding Code No. 2023-002) RECOMMENDATION We recommend the University implement controls to ensure that all refunds of title IV funds are initiated within 45 days of the date of determination for the students withdrawal. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Additional procedures have been put in place and additional staffing efforts will be allocated to ensure timing requirements are met as it relates to Title IV funds.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268, 84.007, 84.379 Program Expenditures: $39,082,749 Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Education Opportunity Grants, Teacher Education Assistance for College and Higher Education Grants Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, P268K231391, P007A231313, P379T221391, and P379T231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete timely return of title IV funds for all students within the required time period. During our testing of borrowers that withdrew from the University, we noted 6 out of 25 (24%) students return of title IV funds were not processed within the 45 day window, ranging from 2-12 days late. The sample was not a statistically valid sample. A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns within 45 days after the determined date of withdrawal (34 CFR 668.173(b)). Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure return of title IV funds is accurate and timely. University management indicated staffing shortages during the 2022-2023 aid year caused this to occur. Without sufficient controls in place to return title IV funds there is a greater risk that the school does not return funds timely or that students may not receive post-withdrawal disbursements timely. (Finding Code No. 2023-002) RECOMMENDATION We recommend the University implement controls to ensure that all refunds of title IV funds are initiated within 45 days of the date of determination for the students withdrawal. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Additional procedures have been put in place and additional staffing efforts will be allocated to ensure timing requirements are met as it relates to Title IV funds.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268, 84.007, 84.379 Program Expenditures: $39,082,749 Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Education Opportunity Grants, Teacher Education Assistance for College and Higher Education Grants Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, P268K231391, P007A231313, P379T221391, and P379T231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete timely return of title IV funds for all students within the required time period. During our testing of borrowers that withdrew from the University, we noted 6 out of 25 (24%) students return of title IV funds were not processed within the 45 day window, ranging from 2-12 days late. The sample was not a statistically valid sample. A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns within 45 days after the determined date of withdrawal (34 CFR 668.173(b)). Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure return of title IV funds is accurate and timely. University management indicated staffing shortages during the 2022-2023 aid year caused this to occur. Without sufficient controls in place to return title IV funds there is a greater risk that the school does not return funds timely or that students may not receive post-withdrawal disbursements timely. (Finding Code No. 2023-002) RECOMMENDATION We recommend the University implement controls to ensure that all refunds of title IV funds are initiated within 45 days of the date of determination for the students withdrawal. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Additional procedures have been put in place and additional staffing efforts will be allocated to ensure timing requirements are met as it relates to Title IV funds.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268, 84.007, 84.379 Program Expenditures: $39,082,749 Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Education Opportunity Grants, Teacher Education Assistance for College and Higher Education Grants Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, P268K231391, P007A231313, P379T221391, and P379T231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete timely return of title IV funds for all students within the required time period. During our testing of borrowers that withdrew from the University, we noted 6 out of 25 (24%) students return of title IV funds were not processed within the 45 day window, ranging from 2-12 days late. The sample was not a statistically valid sample. A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns within 45 days after the determined date of withdrawal (34 CFR 668.173(b)). Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure return of title IV funds is accurate and timely. University management indicated staffing shortages during the 2022-2023 aid year caused this to occur. Without sufficient controls in place to return title IV funds there is a greater risk that the school does not return funds timely or that students may not receive post-withdrawal disbursements timely. (Finding Code No. 2023-002) RECOMMENDATION We recommend the University implement controls to ensure that all refunds of title IV funds are initiated within 45 days of the date of determination for the students withdrawal. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Additional procedures have been put in place and additional staffing efforts will be allocated to ensure timing requirements are met as it relates to Title IV funds.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063 Program Expenditures: $12,171,226 Program Name: Federal Pell Grant Program Award Number(s): P063P211391, P063P221391, and P063P231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely updating of verification statuses in the Common Origination and Disbursement (COD) database for all students within the required time period. During our testing of borrowers that had been selected for verification at the University, we noted 6 out of 25 (24%) students whose verification status was not properly reflected in the COD records. The sample was not a statistically valid sample. The University is required to update the verification status for all borrowers in the COD timely for those selected for verification. During the year, there was a misunderstanding of the waived verification requirements allowable under Dear Colleague Letter “Changes to 2022-2023 Verification Requirements” (GEN-22-06), which caused 6 out of 25 students to not have their verification status updated in the COD. A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and verify an applicant’s FAFSA information and maintain up to date accurate information in COD (34 CFR 668.53(a)). Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure verification status for students is updated accurately and timely. University management indicated there was a misunderstanding of the waived verification requirements which caused this error. Failure to have sufficient controls around verification requirements, resulted in the University not accurately or timely updating the verification status in the COD to report that required verifications occurred for students selected by the Department of Education for verification. (Finding Code No. 2023-003) RECOMMENDATION We recommend the University implement controls to ensure that all students verification statuses are updated accurately and timely in the COD. UNIVERSITY RESPONSE The University agrees with the finding. The University's internal controls have been updated as the Department of Education has released the COVID suspension of the verification process.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063 Program Expenditures: $12,171,226 Program Name: Federal Pell Grant Program Award Number(s): P063P211391, P063P221391, and P063P231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely updating of verification statuses in the Common Origination and Disbursement (COD) database for all students within the required time period. During our testing of borrowers that had been selected for verification at the University, we noted 6 out of 25 (24%) students whose verification status was not properly reflected in the COD records. The sample was not a statistically valid sample. The University is required to update the verification status for all borrowers in the COD timely for those selected for verification. During the year, there was a misunderstanding of the waived verification requirements allowable under Dear Colleague Letter “Changes to 2022-2023 Verification Requirements” (GEN-22-06), which caused 6 out of 25 students to not have their verification status updated in the COD. A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and verify an applicant’s FAFSA information and maintain up to date accurate information in COD (34 CFR 668.53(a)). Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure verification status for students is updated accurately and timely. University management indicated there was a misunderstanding of the waived verification requirements which caused this error. Failure to have sufficient controls around verification requirements, resulted in the University not accurately or timely updating the verification status in the COD to report that required verifications occurred for students selected by the Department of Education for verification. (Finding Code No. 2023-003) RECOMMENDATION We recommend the University implement controls to ensure that all students verification statuses are updated accurately and timely in the COD. UNIVERSITY RESPONSE The University agrees with the finding. The University's internal controls have been updated as the Department of Education has released the COVID suspension of the verification process.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063 Program Expenditures: $12,171,226 Program Name: Federal Pell Grant Program Award Number(s): P063P211391, P063P221391, and P063P231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely updating of verification statuses in the Common Origination and Disbursement (COD) database for all students within the required time period. During our testing of borrowers that had been selected for verification at the University, we noted 6 out of 25 (24%) students whose verification status was not properly reflected in the COD records. The sample was not a statistically valid sample. The University is required to update the verification status for all borrowers in the COD timely for those selected for verification. During the year, there was a misunderstanding of the waived verification requirements allowable under Dear Colleague Letter “Changes to 2022-2023 Verification Requirements” (GEN-22-06), which caused 6 out of 25 students to not have their verification status updated in the COD. A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and verify an applicant’s FAFSA information and maintain up to date accurate information in COD (34 CFR 668.53(a)). Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure verification status for students is updated accurately and timely. University management indicated there was a misunderstanding of the waived verification requirements which caused this error. Failure to have sufficient controls around verification requirements, resulted in the University not accurately or timely updating the verification status in the COD to report that required verifications occurred for students selected by the Department of Education for verification. (Finding Code No. 2023-003) RECOMMENDATION We recommend the University implement controls to ensure that all students verification statuses are updated accurately and timely in the COD. UNIVERSITY RESPONSE The University agrees with the finding. The University's internal controls have been updated as the Department of Education has released the COVID suspension of the verification process.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268 Program Expenditures: $38,687,691 Program Name: Federal Pell Grant Program, Federal Direct Student Loans Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, and P268K231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely enrollment reporting for all students within the required time period. During our testing of Pell or Direct Loan borrowers, we noted 21 out of 40 (53%) students campus-level record and program-level record were not updated within the required time frame, ranging from 11-52 days late. For 19 out of the 21 students noted above, we also noted the enrollment effective date was incorrect (19 out of 40 students tested, 48%). The sample was not a statistically valid sample. The University is required to report enrollment reporting changes no less than every 60 days. During the year, there were underlying problems with how data was being submitted to the National Student Clearinghouse (NSC), resulting in enrollment status changes and degree confirmations not being reported timely for 21 students tested or accurately for 19 students tested. Noted, while the University had a policy in place to ensure enrollment reporting for degree confirmations and status changes were being submitted to the NSC at least every 30 days, there was a flaw in the University’s process that caused enrollment status changes and degree confirmations submitted to the NSC to not ultimately be submitted to National Student Loan Data System (NSLDS), resulting in enrollment reporting changes to be reported greater than 60 days after program enrollment effective date (for 21 students tested) and in some cases, with incorrect enrollment effective date (for 19 out of the 21 students noted above). For the Federal Pell Grant Program, 34 CFR Section 690.83(b)(2) requires an institution to submit in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct. For the Federal Direct Student Loans, 34 CFR Section 685.309(b) requires changes in student status to be reported to the NSLDS within 30 days of the change or included in a Student Status Confirmation Report (SSCR) sent to the NSLDS within 60 days of the status change. Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is accurate and timely. University officials indicated the University did not have adequate procedures in place to ensure all required campus-level data and program-level data was being reported to NSLDS via NSC due to a flaw in their process causing degree confirmations to be overridden with other enrollment information prior to submission. The University did not have an appropriate enrollment reporting timeline to ensure student status changes were reported in the required time frame. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately or timely. Inaccurate or untimely reporting of student enrollment data can result in inconsistencies between the University’s records and the National Students Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2023-001, 2022-002) RECOMMENDATION We recommend the University implement controls to ensure that all enrollment status changes and degree confirmations are being appropriately reported through NSC to NSLDS and that submissions of degree confirmations to NSC are appropriate to ensure enrollment status changes are reported at least every 60 days. We also recommend these controls be monitored to ensure that all necessary information is reported within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Procedural changes have been identified and internal controls will be implemented moving forward to ensure that enrollment status changes and degree confirmations are being appropriately submitted and reported, and that they are done so in a timely manner.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268 Program Expenditures: $38,687,691 Program Name: Federal Pell Grant Program, Federal Direct Student Loans Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, and P268K231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely enrollment reporting for all students within the required time period. During our testing of Pell or Direct Loan borrowers, we noted 21 out of 40 (53%) students campus-level record and program-level record were not updated within the required time frame, ranging from 11-52 days late. For 19 out of the 21 students noted above, we also noted the enrollment effective date was incorrect (19 out of 40 students tested, 48%). The sample was not a statistically valid sample. The University is required to report enrollment reporting changes no less than every 60 days. During the year, there were underlying problems with how data was being submitted to the National Student Clearinghouse (NSC), resulting in enrollment status changes and degree confirmations not being reported timely for 21 students tested or accurately for 19 students tested. Noted, while the University had a policy in place to ensure enrollment reporting for degree confirmations and status changes were being submitted to the NSC at least every 30 days, there was a flaw in the University’s process that caused enrollment status changes and degree confirmations submitted to the NSC to not ultimately be submitted to National Student Loan Data System (NSLDS), resulting in enrollment reporting changes to be reported greater than 60 days after program enrollment effective date (for 21 students tested) and in some cases, with incorrect enrollment effective date (for 19 out of the 21 students noted above). For the Federal Pell Grant Program, 34 CFR Section 690.83(b)(2) requires an institution to submit in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct. For the Federal Direct Student Loans, 34 CFR Section 685.309(b) requires changes in student status to be reported to the NSLDS within 30 days of the change or included in a Student Status Confirmation Report (SSCR) sent to the NSLDS within 60 days of the status change. Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is accurate and timely. University officials indicated the University did not have adequate procedures in place to ensure all required campus-level data and program-level data was being reported to NSLDS via NSC due to a flaw in their process causing degree confirmations to be overridden with other enrollment information prior to submission. The University did not have an appropriate enrollment reporting timeline to ensure student status changes were reported in the required time frame. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately or timely. Inaccurate or untimely reporting of student enrollment data can result in inconsistencies between the University’s records and the National Students Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2023-001, 2022-002) RECOMMENDATION We recommend the University implement controls to ensure that all enrollment status changes and degree confirmations are being appropriately reported through NSC to NSLDS and that submissions of degree confirmations to NSC are appropriate to ensure enrollment status changes are reported at least every 60 days. We also recommend these controls be monitored to ensure that all necessary information is reported within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Procedural changes have been identified and internal controls will be implemented moving forward to ensure that enrollment status changes and degree confirmations are being appropriately submitted and reported, and that they are done so in a timely manner.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268 Program Expenditures: $38,687,691 Program Name: Federal Pell Grant Program, Federal Direct Student Loans Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, and P268K231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely enrollment reporting for all students within the required time period. During our testing of Pell or Direct Loan borrowers, we noted 21 out of 40 (53%) students campus-level record and program-level record were not updated within the required time frame, ranging from 11-52 days late. For 19 out of the 21 students noted above, we also noted the enrollment effective date was incorrect (19 out of 40 students tested, 48%). The sample was not a statistically valid sample. The University is required to report enrollment reporting changes no less than every 60 days. During the year, there were underlying problems with how data was being submitted to the National Student Clearinghouse (NSC), resulting in enrollment status changes and degree confirmations not being reported timely for 21 students tested or accurately for 19 students tested. Noted, while the University had a policy in place to ensure enrollment reporting for degree confirmations and status changes were being submitted to the NSC at least every 30 days, there was a flaw in the University’s process that caused enrollment status changes and degree confirmations submitted to the NSC to not ultimately be submitted to National Student Loan Data System (NSLDS), resulting in enrollment reporting changes to be reported greater than 60 days after program enrollment effective date (for 21 students tested) and in some cases, with incorrect enrollment effective date (for 19 out of the 21 students noted above). For the Federal Pell Grant Program, 34 CFR Section 690.83(b)(2) requires an institution to submit in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct. For the Federal Direct Student Loans, 34 CFR Section 685.309(b) requires changes in student status to be reported to the NSLDS within 30 days of the change or included in a Student Status Confirmation Report (SSCR) sent to the NSLDS within 60 days of the status change. Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is accurate and timely. University officials indicated the University did not have adequate procedures in place to ensure all required campus-level data and program-level data was being reported to NSLDS via NSC due to a flaw in their process causing degree confirmations to be overridden with other enrollment information prior to submission. The University did not have an appropriate enrollment reporting timeline to ensure student status changes were reported in the required time frame. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately or timely. Inaccurate or untimely reporting of student enrollment data can result in inconsistencies between the University’s records and the National Students Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2023-001, 2022-002) RECOMMENDATION We recommend the University implement controls to ensure that all enrollment status changes and degree confirmations are being appropriately reported through NSC to NSLDS and that submissions of degree confirmations to NSC are appropriate to ensure enrollment status changes are reported at least every 60 days. We also recommend these controls be monitored to ensure that all necessary information is reported within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Procedural changes have been identified and internal controls will be implemented moving forward to ensure that enrollment status changes and degree confirmations are being appropriately submitted and reported, and that they are done so in a timely manner.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268 Program Expenditures: $38,687,691 Program Name: Federal Pell Grant Program, Federal Direct Student Loans Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, and P268K231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely enrollment reporting for all students within the required time period. During our testing of Pell or Direct Loan borrowers, we noted 21 out of 40 (53%) students campus-level record and program-level record were not updated within the required time frame, ranging from 11-52 days late. For 19 out of the 21 students noted above, we also noted the enrollment effective date was incorrect (19 out of 40 students tested, 48%). The sample was not a statistically valid sample. The University is required to report enrollment reporting changes no less than every 60 days. During the year, there were underlying problems with how data was being submitted to the National Student Clearinghouse (NSC), resulting in enrollment status changes and degree confirmations not being reported timely for 21 students tested or accurately for 19 students tested. Noted, while the University had a policy in place to ensure enrollment reporting for degree confirmations and status changes were being submitted to the NSC at least every 30 days, there was a flaw in the University’s process that caused enrollment status changes and degree confirmations submitted to the NSC to not ultimately be submitted to National Student Loan Data System (NSLDS), resulting in enrollment reporting changes to be reported greater than 60 days after program enrollment effective date (for 21 students tested) and in some cases, with incorrect enrollment effective date (for 19 out of the 21 students noted above). For the Federal Pell Grant Program, 34 CFR Section 690.83(b)(2) requires an institution to submit in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct. For the Federal Direct Student Loans, 34 CFR Section 685.309(b) requires changes in student status to be reported to the NSLDS within 30 days of the change or included in a Student Status Confirmation Report (SSCR) sent to the NSLDS within 60 days of the status change. Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is accurate and timely. University officials indicated the University did not have adequate procedures in place to ensure all required campus-level data and program-level data was being reported to NSLDS via NSC due to a flaw in their process causing degree confirmations to be overridden with other enrollment information prior to submission. The University did not have an appropriate enrollment reporting timeline to ensure student status changes were reported in the required time frame. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately or timely. Inaccurate or untimely reporting of student enrollment data can result in inconsistencies between the University’s records and the National Students Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2023-001, 2022-002) RECOMMENDATION We recommend the University implement controls to ensure that all enrollment status changes and degree confirmations are being appropriately reported through NSC to NSLDS and that submissions of degree confirmations to NSC are appropriate to ensure enrollment status changes are reported at least every 60 days. We also recommend these controls be monitored to ensure that all necessary information is reported within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Procedural changes have been identified and internal controls will be implemented moving forward to ensure that enrollment status changes and degree confirmations are being appropriately submitted and reported, and that they are done so in a timely manner.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268 Program Expenditures: $38,687,691 Program Name: Federal Pell Grant Program, Federal Direct Student Loans Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, and P268K231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely enrollment reporting for all students within the required time period. During our testing of Pell or Direct Loan borrowers, we noted 21 out of 40 (53%) students campus-level record and program-level record were not updated within the required time frame, ranging from 11-52 days late. For 19 out of the 21 students noted above, we also noted the enrollment effective date was incorrect (19 out of 40 students tested, 48%). The sample was not a statistically valid sample. The University is required to report enrollment reporting changes no less than every 60 days. During the year, there were underlying problems with how data was being submitted to the National Student Clearinghouse (NSC), resulting in enrollment status changes and degree confirmations not being reported timely for 21 students tested or accurately for 19 students tested. Noted, while the University had a policy in place to ensure enrollment reporting for degree confirmations and status changes were being submitted to the NSC at least every 30 days, there was a flaw in the University’s process that caused enrollment status changes and degree confirmations submitted to the NSC to not ultimately be submitted to National Student Loan Data System (NSLDS), resulting in enrollment reporting changes to be reported greater than 60 days after program enrollment effective date (for 21 students tested) and in some cases, with incorrect enrollment effective date (for 19 out of the 21 students noted above). For the Federal Pell Grant Program, 34 CFR Section 690.83(b)(2) requires an institution to submit in accordance with deadline dates established by the secretary, through publication in the Federal Register, other reports and information the secretary requires and shall comply with the procedures the secretary finds necessary to ensure that the reports are correct. For the Federal Direct Student Loans, 34 CFR Section 685.309(b) requires changes in student status to be reported to the NSLDS within 30 days of the change or included in a Student Status Confirmation Report (SSCR) sent to the NSLDS within 60 days of the status change. Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is accurate and timely. University officials indicated the University did not have adequate procedures in place to ensure all required campus-level data and program-level data was being reported to NSLDS via NSC due to a flaw in their process causing degree confirmations to be overridden with other enrollment information prior to submission. The University did not have an appropriate enrollment reporting timeline to ensure student status changes were reported in the required time frame. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately or timely. Inaccurate or untimely reporting of student enrollment data can result in inconsistencies between the University’s records and the National Students Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2023-001, 2022-002) RECOMMENDATION We recommend the University implement controls to ensure that all enrollment status changes and degree confirmations are being appropriately reported through NSC to NSLDS and that submissions of degree confirmations to NSC are appropriate to ensure enrollment status changes are reported at least every 60 days. We also recommend these controls be monitored to ensure that all necessary information is reported within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Procedural changes have been identified and internal controls will be implemented moving forward to ensure that enrollment status changes and degree confirmations are being appropriately submitted and reported, and that they are done so in a timely manner.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268, 84.007, 84.379 Program Expenditures: $39,082,749 Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Education Opportunity Grants, Teacher Education Assistance for College and Higher Education Grants Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, P268K231391, P007A231313, P379T221391, and P379T231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete timely return of title IV funds for all students within the required time period. During our testing of borrowers that withdrew from the University, we noted 6 out of 25 (24%) students return of title IV funds were not processed within the 45 day window, ranging from 2-12 days late. The sample was not a statistically valid sample. A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns within 45 days after the determined date of withdrawal (34 CFR 668.173(b)). Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure return of title IV funds is accurate and timely. University management indicated staffing shortages during the 2022-2023 aid year caused this to occur. Without sufficient controls in place to return title IV funds there is a greater risk that the school does not return funds timely or that students may not receive post-withdrawal disbursements timely. (Finding Code No. 2023-002) RECOMMENDATION We recommend the University implement controls to ensure that all refunds of title IV funds are initiated within 45 days of the date of determination for the students withdrawal. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Additional procedures have been put in place and additional staffing efforts will be allocated to ensure timing requirements are met as it relates to Title IV funds.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268, 84.007, 84.379 Program Expenditures: $39,082,749 Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Education Opportunity Grants, Teacher Education Assistance for College and Higher Education Grants Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, P268K231391, P007A231313, P379T221391, and P379T231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete timely return of title IV funds for all students within the required time period. During our testing of borrowers that withdrew from the University, we noted 6 out of 25 (24%) students return of title IV funds were not processed within the 45 day window, ranging from 2-12 days late. The sample was not a statistically valid sample. A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns within 45 days after the determined date of withdrawal (34 CFR 668.173(b)). Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure return of title IV funds is accurate and timely. University management indicated staffing shortages during the 2022-2023 aid year caused this to occur. Without sufficient controls in place to return title IV funds there is a greater risk that the school does not return funds timely or that students may not receive post-withdrawal disbursements timely. (Finding Code No. 2023-002) RECOMMENDATION We recommend the University implement controls to ensure that all refunds of title IV funds are initiated within 45 days of the date of determination for the students withdrawal. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Additional procedures have been put in place and additional staffing efforts will be allocated to ensure timing requirements are met as it relates to Title IV funds.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268, 84.007, 84.379 Program Expenditures: $39,082,749 Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Education Opportunity Grants, Teacher Education Assistance for College and Higher Education Grants Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, P268K231391, P007A231313, P379T221391, and P379T231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete timely return of title IV funds for all students within the required time period. During our testing of borrowers that withdrew from the University, we noted 6 out of 25 (24%) students return of title IV funds were not processed within the 45 day window, ranging from 2-12 days late. The sample was not a statistically valid sample. A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns within 45 days after the determined date of withdrawal (34 CFR 668.173(b)). Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure return of title IV funds is accurate and timely. University management indicated staffing shortages during the 2022-2023 aid year caused this to occur. Without sufficient controls in place to return title IV funds there is a greater risk that the school does not return funds timely or that students may not receive post-withdrawal disbursements timely. (Finding Code No. 2023-002) RECOMMENDATION We recommend the University implement controls to ensure that all refunds of title IV funds are initiated within 45 days of the date of determination for the students withdrawal. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Additional procedures have been put in place and additional staffing efforts will be allocated to ensure timing requirements are met as it relates to Title IV funds.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268, 84.007, 84.379 Program Expenditures: $39,082,749 Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Education Opportunity Grants, Teacher Education Assistance for College and Higher Education Grants Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, P268K231391, P007A231313, P379T221391, and P379T231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete timely return of title IV funds for all students within the required time period. During our testing of borrowers that withdrew from the University, we noted 6 out of 25 (24%) students return of title IV funds were not processed within the 45 day window, ranging from 2-12 days late. The sample was not a statistically valid sample. A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns within 45 days after the determined date of withdrawal (34 CFR 668.173(b)). Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure return of title IV funds is accurate and timely. University management indicated staffing shortages during the 2022-2023 aid year caused this to occur. Without sufficient controls in place to return title IV funds there is a greater risk that the school does not return funds timely or that students may not receive post-withdrawal disbursements timely. (Finding Code No. 2023-002) RECOMMENDATION We recommend the University implement controls to ensure that all refunds of title IV funds are initiated within 45 days of the date of determination for the students withdrawal. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Additional procedures have been put in place and additional staffing efforts will be allocated to ensure timing requirements are met as it relates to Title IV funds.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268, 84.007, 84.379 Program Expenditures: $39,082,749 Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Education Opportunity Grants, Teacher Education Assistance for College and Higher Education Grants Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, P268K231391, P007A231313, P379T221391, and P379T231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete timely return of title IV funds for all students within the required time period. During our testing of borrowers that withdrew from the University, we noted 6 out of 25 (24%) students return of title IV funds were not processed within the 45 day window, ranging from 2-12 days late. The sample was not a statistically valid sample. A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns within 45 days after the determined date of withdrawal (34 CFR 668.173(b)). Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure return of title IV funds is accurate and timely. University management indicated staffing shortages during the 2022-2023 aid year caused this to occur. Without sufficient controls in place to return title IV funds there is a greater risk that the school does not return funds timely or that students may not receive post-withdrawal disbursements timely. (Finding Code No. 2023-002) RECOMMENDATION We recommend the University implement controls to ensure that all refunds of title IV funds are initiated within 45 days of the date of determination for the students withdrawal. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Additional procedures have been put in place and additional staffing efforts will be allocated to ensure timing requirements are met as it relates to Title IV funds.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268, 84.007, 84.379 Program Expenditures: $39,082,749 Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Education Opportunity Grants, Teacher Education Assistance for College and Higher Education Grants Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, P268K231391, P007A231313, P379T221391, and P379T231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete timely return of title IV funds for all students within the required time period. During our testing of borrowers that withdrew from the University, we noted 6 out of 25 (24%) students return of title IV funds were not processed within the 45 day window, ranging from 2-12 days late. The sample was not a statistically valid sample. A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns within 45 days after the determined date of withdrawal (34 CFR 668.173(b)). Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure return of title IV funds is accurate and timely. University management indicated staffing shortages during the 2022-2023 aid year caused this to occur. Without sufficient controls in place to return title IV funds there is a greater risk that the school does not return funds timely or that students may not receive post-withdrawal disbursements timely. (Finding Code No. 2023-002) RECOMMENDATION We recommend the University implement controls to ensure that all refunds of title IV funds are initiated within 45 days of the date of determination for the students withdrawal. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Additional procedures have been put in place and additional staffing efforts will be allocated to ensure timing requirements are met as it relates to Title IV funds.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268, 84.007, 84.379 Program Expenditures: $39,082,749 Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Education Opportunity Grants, Teacher Education Assistance for College and Higher Education Grants Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, P268K231391, P007A231313, P379T221391, and P379T231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete timely return of title IV funds for all students within the required time period. During our testing of borrowers that withdrew from the University, we noted 6 out of 25 (24%) students return of title IV funds were not processed within the 45 day window, ranging from 2-12 days late. The sample was not a statistically valid sample. A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns within 45 days after the determined date of withdrawal (34 CFR 668.173(b)). Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure return of title IV funds is accurate and timely. University management indicated staffing shortages during the 2022-2023 aid year caused this to occur. Without sufficient controls in place to return title IV funds there is a greater risk that the school does not return funds timely or that students may not receive post-withdrawal disbursements timely. (Finding Code No. 2023-002) RECOMMENDATION We recommend the University implement controls to ensure that all refunds of title IV funds are initiated within 45 days of the date of determination for the students withdrawal. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Additional procedures have been put in place and additional staffing efforts will be allocated to ensure timing requirements are met as it relates to Title IV funds.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063, 84.268, 84.007, 84.379 Program Expenditures: $39,082,749 Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Education Opportunity Grants, Teacher Education Assistance for College and Higher Education Grants Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, P268K231391, P007A231313, P379T221391, and P379T231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete timely return of title IV funds for all students within the required time period. During our testing of borrowers that withdrew from the University, we noted 6 out of 25 (24%) students return of title IV funds were not processed within the 45 day window, ranging from 2-12 days late. The sample was not a statistically valid sample. A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns within 45 days after the determined date of withdrawal (34 CFR 668.173(b)). Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure return of title IV funds is accurate and timely. University management indicated staffing shortages during the 2022-2023 aid year caused this to occur. Without sufficient controls in place to return title IV funds there is a greater risk that the school does not return funds timely or that students may not receive post-withdrawal disbursements timely. (Finding Code No. 2023-002) RECOMMENDATION We recommend the University implement controls to ensure that all refunds of title IV funds are initiated within 45 days of the date of determination for the students withdrawal. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame. UNIVERSITY RESPONSE The University agrees with the finding. Additional procedures have been put in place and additional staffing efforts will be allocated to ensure timing requirements are met as it relates to Title IV funds.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063 Program Expenditures: $12,171,226 Program Name: Federal Pell Grant Program Award Number(s): P063P211391, P063P221391, and P063P231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely updating of verification statuses in the Common Origination and Disbursement (COD) database for all students within the required time period. During our testing of borrowers that had been selected for verification at the University, we noted 6 out of 25 (24%) students whose verification status was not properly reflected in the COD records. The sample was not a statistically valid sample. The University is required to update the verification status for all borrowers in the COD timely for those selected for verification. During the year, there was a misunderstanding of the waived verification requirements allowable under Dear Colleague Letter “Changes to 2022-2023 Verification Requirements” (GEN-22-06), which caused 6 out of 25 students to not have their verification status updated in the COD. A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and verify an applicant’s FAFSA information and maintain up to date accurate information in COD (34 CFR 668.53(a)). Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure verification status for students is updated accurately and timely. University management indicated there was a misunderstanding of the waived verification requirements which caused this error. Failure to have sufficient controls around verification requirements, resulted in the University not accurately or timely updating the verification status in the COD to report that required verifications occurred for students selected by the Department of Education for verification. (Finding Code No. 2023-003) RECOMMENDATION We recommend the University implement controls to ensure that all students verification statuses are updated accurately and timely in the COD. UNIVERSITY RESPONSE The University agrees with the finding. The University's internal controls have been updated as the Department of Education has released the COVID suspension of the verification process.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063 Program Expenditures: $12,171,226 Program Name: Federal Pell Grant Program Award Number(s): P063P211391, P063P221391, and P063P231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely updating of verification statuses in the Common Origination and Disbursement (COD) database for all students within the required time period. During our testing of borrowers that had been selected for verification at the University, we noted 6 out of 25 (24%) students whose verification status was not properly reflected in the COD records. The sample was not a statistically valid sample. The University is required to update the verification status for all borrowers in the COD timely for those selected for verification. During the year, there was a misunderstanding of the waived verification requirements allowable under Dear Colleague Letter “Changes to 2022-2023 Verification Requirements” (GEN-22-06), which caused 6 out of 25 students to not have their verification status updated in the COD. A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and verify an applicant’s FAFSA information and maintain up to date accurate information in COD (34 CFR 668.53(a)). Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure verification status for students is updated accurately and timely. University management indicated there was a misunderstanding of the waived verification requirements which caused this error. Failure to have sufficient controls around verification requirements, resulted in the University not accurately or timely updating the verification status in the COD to report that required verifications occurred for students selected by the Department of Education for verification. (Finding Code No. 2023-003) RECOMMENDATION We recommend the University implement controls to ensure that all students verification statuses are updated accurately and timely in the COD. UNIVERSITY RESPONSE The University agrees with the finding. The University's internal controls have been updated as the Department of Education has released the COVID suspension of the verification process.

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063 Program Expenditures: $12,171,226 Program Name: Federal Pell Grant Program Award Number(s): P063P211391, P063P221391, and P063P231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely updating of verification statuses in the Common Origination and Disbursement (COD) database for all students within the required time period. During our testing of borrowers that had been selected for verification at the University, we noted 6 out of 25 (24%) students whose verification status was not properly reflected in the COD records. The sample was not a statistically valid sample. The University is required to update the verification status for all borrowers in the COD timely for those selected for verification. During the year, there was a misunderstanding of the waived verification requirements allowable under Dear Colleague Letter “Changes to 2022-2023 Verification Requirements” (GEN-22-06), which caused 6 out of 25 students to not have their verification status updated in the COD. A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and verify an applicant’s FAFSA information and maintain up to date accurate information in COD (34 CFR 668.53(a)). Uniform Guidance (2 CFR 200.303(a)) requires non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure verification status for students is updated accurately and timely. University management indicated there was a misunderstanding of the waived verification requirements which caused this error. Failure to have sufficient controls around verification requirements, resulted in the University not accurately or timely updating the verification status in the COD to report that required verifications occurred for students selected by the Department of Education for verification. (Finding Code No. 2023-003) RECOMMENDATION We recommend the University implement controls to ensure that all students verification statuses are updated accurately and timely in the COD. UNIVERSITY RESPONSE The University agrees with the finding. The University's internal controls have been updated as the Department of Education has released the COVID suspension of the verification process.