Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268
Program Expenditures: $38,764,799
Program Name: Federal Pell Grant Program, Federal Direct Student Loans
Award Number(s): P063P211391, P063P221391, P063P231391, P268K231391, and P268K241391
Questioned Costs: None
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate enrollment reporting for all students. During our testing of Pell or Direct Loan borrowers, we noted 8 out of 40 (20%) students campus-level record and program-level record were not updated with accurate enrollment status changes. The sample was not a statistically valid sample. The University is required to report enrollment reporting changes accurately. 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 to be inaccurate for 8 students tested out of 40 students tested (20% of 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, there was a flaw in the University’s process that caused the fall graduate batch of students to be initially coded to “G-Not Applied” in the National Student Loan Data System (NSLDS). This was due to an error in the upload compared with underlying information in the NSLDS system. When the next batch of students were submitted to the NSLDS, this resulted in all “G-Not Applied” students to auto-update to “Withdrawn” in the NSLDS system.
Criteria: 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 in accordance with enrollment reporting in transmissions sent to the NSLDS, including updating all flagged information by NSLDS. 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.
Cause and Effect: University officials indicated staff turnover required reassessment of internal documentation and procedure that were in place to ensure all required campus-level data and program-level data was being reported to NSLDS via NSC accurately due to a flaw in their process causing degree confirmations to be overridden with other enrollment information prior to submission. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately. Inaccurate reporting of student enrollment data can result in inconsistencies between the University’s records and the National Student Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2024-001, 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 accurately.
University Response: The University agrees with the finding. The University is implementing enhanced internal controls to ensure enrollment status changes and degree confirmations are being appropriately submitted and reported.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268
Program Expenditures: $38,764,799
Program Name: Federal Pell Grant Program, Federal Direct Student Loans
Award Number(s): P063P211391, P063P221391, P063P231391, P268K231391, and P268K241391
Questioned Costs: None
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate enrollment reporting for all students. During our testing of Pell or Direct Loan borrowers, we noted 8 out of 40 (20%) students campus-level record and program-level record were not updated with accurate enrollment status changes. The sample was not a statistically valid sample. The University is required to report enrollment reporting changes accurately. 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 to be inaccurate for 8 students tested out of 40 students tested (20% of 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, there was a flaw in the University’s process that caused the fall graduate batch of students to be initially coded to “G-Not Applied” in the National Student Loan Data System (NSLDS). This was due to an error in the upload compared with underlying information in the NSLDS system. When the next batch of students were submitted to the NSLDS, this resulted in all “G-Not Applied” students to auto-update to “Withdrawn” in the NSLDS system.
Criteria: 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 in accordance with enrollment reporting in transmissions sent to the NSLDS, including updating all flagged information by NSLDS. 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.
Cause and Effect: University officials indicated staff turnover required reassessment of internal documentation and procedure that were in place to ensure all required campus-level data and program-level data was being reported to NSLDS via NSC accurately due to a flaw in their process causing degree confirmations to be overridden with other enrollment information prior to submission. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately. Inaccurate reporting of student enrollment data can result in inconsistencies between the University’s records and the National Student Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2024-001, 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 accurately.
University Response: The University agrees with the finding. The University is implementing enhanced internal controls to ensure enrollment status changes and degree confirmations are being appropriately submitted and reported.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268
Program Expenditures: $38,764,799
Program Name: Federal Pell Grant Program, Federal Direct Student Loans
Award Number(s): P063P211391, P063P221391, P063P231391, P268K231391, and P268K241391
Questioned Costs: None
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate enrollment reporting for all students. During our testing of Pell or Direct Loan borrowers, we noted 8 out of 40 (20%) students campus-level record and program-level record were not updated with accurate enrollment status changes. The sample was not a statistically valid sample. The University is required to report enrollment reporting changes accurately. 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 to be inaccurate for 8 students tested out of 40 students tested (20% of 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, there was a flaw in the University’s process that caused the fall graduate batch of students to be initially coded to “G-Not Applied” in the National Student Loan Data System (NSLDS). This was due to an error in the upload compared with underlying information in the NSLDS system. When the next batch of students were submitted to the NSLDS, this resulted in all “G-Not Applied” students to auto-update to “Withdrawn” in the NSLDS system.
Criteria: 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 in accordance with enrollment reporting in transmissions sent to the NSLDS, including updating all flagged information by NSLDS. 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.
Cause and Effect: University officials indicated staff turnover required reassessment of internal documentation and procedure that were in place to ensure all required campus-level data and program-level data was being reported to NSLDS via NSC accurately due to a flaw in their process causing degree confirmations to be overridden with other enrollment information prior to submission. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately. Inaccurate reporting of student enrollment data can result in inconsistencies between the University’s records and the National Student Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2024-001, 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 accurately.
University Response: The University agrees with the finding. The University is implementing enhanced internal controls to ensure enrollment status changes and degree confirmations are being appropriately submitted and reported.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268
Program Expenditures: $38,764,799
Program Name: Federal Pell Grant Program, Federal Direct Student Loans
Award Number(s): P063P211391, P063P221391, P063P231391, P268K231391, and P268K241391
Questioned Costs: None
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate enrollment reporting for all students. During our testing of Pell or Direct Loan borrowers, we noted 8 out of 40 (20%) students campus-level record and program-level record were not updated with accurate enrollment status changes. The sample was not a statistically valid sample. The University is required to report enrollment reporting changes accurately. 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 to be inaccurate for 8 students tested out of 40 students tested (20% of 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, there was a flaw in the University’s process that caused the fall graduate batch of students to be initially coded to “G-Not Applied” in the National Student Loan Data System (NSLDS). This was due to an error in the upload compared with underlying information in the NSLDS system. When the next batch of students were submitted to the NSLDS, this resulted in all “G-Not Applied” students to auto-update to “Withdrawn” in the NSLDS system.
Criteria: 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 in accordance with enrollment reporting in transmissions sent to the NSLDS, including updating all flagged information by NSLDS. 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.
Cause and Effect: University officials indicated staff turnover required reassessment of internal documentation and procedure that were in place to ensure all required campus-level data and program-level data was being reported to NSLDS via NSC accurately due to a flaw in their process causing degree confirmations to be overridden with other enrollment information prior to submission. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately. Inaccurate reporting of student enrollment data can result in inconsistencies between the University’s records and the National Student Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2024-001, 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 accurately.
University Response: The University agrees with the finding. The University is implementing enhanced internal controls to ensure enrollment status changes and degree confirmations are being appropriately submitted and reported.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268
Program Expenditures: $38,764,799
Program Name: Federal Pell Grant Program, Federal Direct Student Loans
Award Number(s): P063P211391, P063P221391, P063P231391, P268K231391, and P268K241391
Questioned Costs: None
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate enrollment reporting for all students. During our testing of Pell or Direct Loan borrowers, we noted 8 out of 40 (20%) students campus-level record and program-level record were not updated with accurate enrollment status changes. The sample was not a statistically valid sample. The University is required to report enrollment reporting changes accurately. 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 to be inaccurate for 8 students tested out of 40 students tested (20% of 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, there was a flaw in the University’s process that caused the fall graduate batch of students to be initially coded to “G-Not Applied” in the National Student Loan Data System (NSLDS). This was due to an error in the upload compared with underlying information in the NSLDS system. When the next batch of students were submitted to the NSLDS, this resulted in all “G-Not Applied” students to auto-update to “Withdrawn” in the NSLDS system.
Criteria: 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 in accordance with enrollment reporting in transmissions sent to the NSLDS, including updating all flagged information by NSLDS. 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.
Cause and Effect: University officials indicated staff turnover required reassessment of internal documentation and procedure that were in place to ensure all required campus-level data and program-level data was being reported to NSLDS via NSC accurately due to a flaw in their process causing degree confirmations to be overridden with other enrollment information prior to submission. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately. Inaccurate reporting of student enrollment data can result in inconsistencies between the University’s records and the National Student Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2024-001, 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 accurately.
University Response: The University agrees with the finding. The University is implementing enhanced internal controls to ensure enrollment status changes and degree confirmations are being appropriately submitted and reported.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268, 84.007, 84.379
Program Expenditures: $39,166,408
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, P268K231391, P268K241391,
P007A241313, P379T231391, and P379T241391
Questioned Costs: $50
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate and 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 3 out of 40 (7.5%) students return of Title IV funds were not processed within the 45 day window, ranging from 4-25 days late. Additionally, we noted 1 student out of 40 (2.5%) had an incorrect calculation performed, resulting in $50 in excess Pell funds being returned to the Department of Education. The sample was not a statistically valid sample.
Criteria: A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns accurately within 45 days after the determined date of withdrawal (34 CFR 668.173(b)), and accurately calculate the amount of unearned title IV assistance to be returned to the Department of Education (34 CFR 668.22(g)). 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.
Cause and Effect: University management indicated staffing shortages as well as regulatory and systemic changes during the 2023-2024 aid year caused this to occur. There were questioned costs of $50 due to the calculation error, resulting in a $50 overpayment to the
Department of Education. Without sufficient controls in place to return Title IV funds there is a greater risk that the school does not return funds timely or accurately or that students may not receive post-withdrawal disbursements timely or accurately. (Finding Code No. 2024-002, 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 and additional controls to ensure proper review of the return of Title IV calculations. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame and accurately.
University Response: The University agrees with the finding. The University is committed to developing a comprehensive plan to ensure compliance with return of Title IV funds policies and procedures.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268, 84.007, 84.379
Program Expenditures: $39,166,408
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, P268K231391, P268K241391,
P007A241313, P379T231391, and P379T241391
Questioned Costs: $50
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate and 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 3 out of 40 (7.5%) students return of Title IV funds were not processed within the 45 day window, ranging from 4-25 days late. Additionally, we noted 1 student out of 40 (2.5%) had an incorrect calculation performed, resulting in $50 in excess Pell funds being returned to the Department of Education. The sample was not a statistically valid sample.
Criteria: A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns accurately within 45 days after the determined date of withdrawal (34 CFR 668.173(b)), and accurately calculate the amount of unearned title IV assistance to be returned to the Department of Education (34 CFR 668.22(g)). 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.
Cause and Effect: University management indicated staffing shortages as well as regulatory and systemic changes during the 2023-2024 aid year caused this to occur. There were questioned costs of $50 due to the calculation error, resulting in a $50 overpayment to the
Department of Education. Without sufficient controls in place to return Title IV funds there is a greater risk that the school does not return funds timely or accurately or that students may not receive post-withdrawal disbursements timely or accurately. (Finding Code No. 2024-002, 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 and additional controls to ensure proper review of the return of Title IV calculations. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame and accurately.
University Response: The University agrees with the finding. The University is committed to developing a comprehensive plan to ensure compliance with return of Title IV funds policies and procedures.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268, 84.007, 84.379
Program Expenditures: $39,166,408
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, P268K231391, P268K241391,
P007A241313, P379T231391, and P379T241391
Questioned Costs: $50
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate and 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 3 out of 40 (7.5%) students return of Title IV funds were not processed within the 45 day window, ranging from 4-25 days late. Additionally, we noted 1 student out of 40 (2.5%) had an incorrect calculation performed, resulting in $50 in excess Pell funds being returned to the Department of Education. The sample was not a statistically valid sample.
Criteria: A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns accurately within 45 days after the determined date of withdrawal (34 CFR 668.173(b)), and accurately calculate the amount of unearned title IV assistance to be returned to the Department of Education (34 CFR 668.22(g)). 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.
Cause and Effect: University management indicated staffing shortages as well as regulatory and systemic changes during the 2023-2024 aid year caused this to occur. There were questioned costs of $50 due to the calculation error, resulting in a $50 overpayment to the
Department of Education. Without sufficient controls in place to return Title IV funds there is a greater risk that the school does not return funds timely or accurately or that students may not receive post-withdrawal disbursements timely or accurately. (Finding Code No. 2024-002, 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 and additional controls to ensure proper review of the return of Title IV calculations. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame and accurately.
University Response: The University agrees with the finding. The University is committed to developing a comprehensive plan to ensure compliance with return of Title IV funds policies and procedures.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268, 84.007, 84.379
Program Expenditures: $39,166,408
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, P268K231391, P268K241391,
P007A241313, P379T231391, and P379T241391
Questioned Costs: $50
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate and 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 3 out of 40 (7.5%) students return of Title IV funds were not processed within the 45 day window, ranging from 4-25 days late. Additionally, we noted 1 student out of 40 (2.5%) had an incorrect calculation performed, resulting in $50 in excess Pell funds being returned to the Department of Education. The sample was not a statistically valid sample.
Criteria: A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns accurately within 45 days after the determined date of withdrawal (34 CFR 668.173(b)), and accurately calculate the amount of unearned title IV assistance to be returned to the Department of Education (34 CFR 668.22(g)). 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.
Cause and Effect: University management indicated staffing shortages as well as regulatory and systemic changes during the 2023-2024 aid year caused this to occur. There were questioned costs of $50 due to the calculation error, resulting in a $50 overpayment to the
Department of Education. Without sufficient controls in place to return Title IV funds there is a greater risk that the school does not return funds timely or accurately or that students may not receive post-withdrawal disbursements timely or accurately. (Finding Code No. 2024-002, 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 and additional controls to ensure proper review of the return of Title IV calculations. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame and accurately.
University Response: The University agrees with the finding. The University is committed to developing a comprehensive plan to ensure compliance with return of Title IV funds policies and procedures.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268, 84.007, 84.379
Program Expenditures: $39,166,408
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, P268K231391, P268K241391,
P007A241313, P379T231391, and P379T241391
Questioned Costs: $50
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate and 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 3 out of 40 (7.5%) students return of Title IV funds were not processed within the 45 day window, ranging from 4-25 days late. Additionally, we noted 1 student out of 40 (2.5%) had an incorrect calculation performed, resulting in $50 in excess Pell funds being returned to the Department of Education. The sample was not a statistically valid sample.
Criteria: A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns accurately within 45 days after the determined date of withdrawal (34 CFR 668.173(b)), and accurately calculate the amount of unearned title IV assistance to be returned to the Department of Education (34 CFR 668.22(g)). 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.
Cause and Effect: University management indicated staffing shortages as well as regulatory and systemic changes during the 2023-2024 aid year caused this to occur. There were questioned costs of $50 due to the calculation error, resulting in a $50 overpayment to the
Department of Education. Without sufficient controls in place to return Title IV funds there is a greater risk that the school does not return funds timely or accurately or that students may not receive post-withdrawal disbursements timely or accurately. (Finding Code No. 2024-002, 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 and additional controls to ensure proper review of the return of Title IV calculations. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame and accurately.
University Response: The University agrees with the finding. The University is committed to developing a comprehensive plan to ensure compliance with return of Title IV funds policies and procedures.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268, 84.007, 84.379
Program Expenditures: $39,166,408
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, P268K231391, P268K241391,
P007A241313, P379T231391, and P379T241391
Questioned Costs: $50
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate and 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 3 out of 40 (7.5%) students return of Title IV funds were not processed within the 45 day window, ranging from 4-25 days late. Additionally, we noted 1 student out of 40 (2.5%) had an incorrect calculation performed, resulting in $50 in excess Pell funds being returned to the Department of Education. The sample was not a statistically valid sample.
Criteria: A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns accurately within 45 days after the determined date of withdrawal (34 CFR 668.173(b)), and accurately calculate the amount of unearned title IV assistance to be returned to the Department of Education (34 CFR 668.22(g)). 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.
Cause and Effect: University management indicated staffing shortages as well as regulatory and systemic changes during the 2023-2024 aid year caused this to occur. There were questioned costs of $50 due to the calculation error, resulting in a $50 overpayment to the
Department of Education. Without sufficient controls in place to return Title IV funds there is a greater risk that the school does not return funds timely or accurately or that students may not receive post-withdrawal disbursements timely or accurately. (Finding Code No. 2024-002, 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 and additional controls to ensure proper review of the return of Title IV calculations. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame and accurately.
University Response: The University agrees with the finding. The University is committed to developing a comprehensive plan to ensure compliance with return of Title IV funds policies and procedures.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268, 84.007, 84.379
Program Expenditures: $39,166,408
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, P268K231391, P268K241391,
P007A241313, P379T231391, and P379T241391
Questioned Costs: $50
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate and 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 3 out of 40 (7.5%) students return of Title IV funds were not processed within the 45 day window, ranging from 4-25 days late. Additionally, we noted 1 student out of 40 (2.5%) had an incorrect calculation performed, resulting in $50 in excess Pell funds being returned to the Department of Education. The sample was not a statistically valid sample.
Criteria: A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns accurately within 45 days after the determined date of withdrawal (34 CFR 668.173(b)), and accurately calculate the amount of unearned title IV assistance to be returned to the Department of Education (34 CFR 668.22(g)). 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.
Cause and Effect: University management indicated staffing shortages as well as regulatory and systemic changes during the 2023-2024 aid year caused this to occur. There were questioned costs of $50 due to the calculation error, resulting in a $50 overpayment to the
Department of Education. Without sufficient controls in place to return Title IV funds there is a greater risk that the school does not return funds timely or accurately or that students may not receive post-withdrawal disbursements timely or accurately. (Finding Code No. 2024-002, 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 and additional controls to ensure proper review of the return of Title IV calculations. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame and accurately.
University Response: The University agrees with the finding. The University is committed to developing a comprehensive plan to ensure compliance with return of Title IV funds policies and procedures.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268, 84.007, 84.379
Program Expenditures: $39,166,408
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, P268K231391, P268K241391,
P007A241313, P379T231391, and P379T241391
Questioned Costs: $50
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate and 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 3 out of 40 (7.5%) students return of Title IV funds were not processed within the 45 day window, ranging from 4-25 days late. Additionally, we noted 1 student out of 40 (2.5%) had an incorrect calculation performed, resulting in $50 in excess Pell funds being returned to the Department of Education. The sample was not a statistically valid sample.
Criteria: A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns accurately within 45 days after the determined date of withdrawal (34 CFR 668.173(b)), and accurately calculate the amount of unearned title IV assistance to be returned to the Department of Education (34 CFR 668.22(g)). 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.
Cause and Effect: University management indicated staffing shortages as well as regulatory and systemic changes during the 2023-2024 aid year caused this to occur. There were questioned costs of $50 due to the calculation error, resulting in a $50 overpayment to the
Department of Education. Without sufficient controls in place to return Title IV funds there is a greater risk that the school does not return funds timely or accurately or that students may not receive post-withdrawal disbursements timely or accurately. (Finding Code No. 2024-002, 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 and additional controls to ensure proper review of the return of Title IV calculations. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame and accurately.
University Response: The University agrees with the finding. The University is committed to developing a comprehensive plan to ensure compliance with return of Title IV funds policies and procedures.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268
Program Expenditures: $38,764,799
Program Name: Federal Pell Grant Program, Federal Direct Student Loans
Award Number(s): P063P211391, P063P221391, P063P231391, P268K231391, and P268K241391
Questioned Costs: None
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate enrollment reporting for all students. During our testing of Pell or Direct Loan borrowers, we noted 8 out of 40 (20%) students campus-level record and program-level record were not updated with accurate enrollment status changes. The sample was not a statistically valid sample. The University is required to report enrollment reporting changes accurately. 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 to be inaccurate for 8 students tested out of 40 students tested (20% of 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, there was a flaw in the University’s process that caused the fall graduate batch of students to be initially coded to “G-Not Applied” in the National Student Loan Data System (NSLDS). This was due to an error in the upload compared with underlying information in the NSLDS system. When the next batch of students were submitted to the NSLDS, this resulted in all “G-Not Applied” students to auto-update to “Withdrawn” in the NSLDS system.
Criteria: 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 in accordance with enrollment reporting in transmissions sent to the NSLDS, including updating all flagged information by NSLDS. 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.
Cause and Effect: University officials indicated staff turnover required reassessment of internal documentation and procedure that were in place to ensure all required campus-level data and program-level data was being reported to NSLDS via NSC accurately due to a flaw in their process causing degree confirmations to be overridden with other enrollment information prior to submission. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately. Inaccurate reporting of student enrollment data can result in inconsistencies between the University’s records and the National Student Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2024-001, 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 accurately.
University Response: The University agrees with the finding. The University is implementing enhanced internal controls to ensure enrollment status changes and degree confirmations are being appropriately submitted and reported.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268
Program Expenditures: $38,764,799
Program Name: Federal Pell Grant Program, Federal Direct Student Loans
Award Number(s): P063P211391, P063P221391, P063P231391, P268K231391, and P268K241391
Questioned Costs: None
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate enrollment reporting for all students. During our testing of Pell or Direct Loan borrowers, we noted 8 out of 40 (20%) students campus-level record and program-level record were not updated with accurate enrollment status changes. The sample was not a statistically valid sample. The University is required to report enrollment reporting changes accurately. 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 to be inaccurate for 8 students tested out of 40 students tested (20% of 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, there was a flaw in the University’s process that caused the fall graduate batch of students to be initially coded to “G-Not Applied” in the National Student Loan Data System (NSLDS). This was due to an error in the upload compared with underlying information in the NSLDS system. When the next batch of students were submitted to the NSLDS, this resulted in all “G-Not Applied” students to auto-update to “Withdrawn” in the NSLDS system.
Criteria: 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 in accordance with enrollment reporting in transmissions sent to the NSLDS, including updating all flagged information by NSLDS. 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.
Cause and Effect: University officials indicated staff turnover required reassessment of internal documentation and procedure that were in place to ensure all required campus-level data and program-level data was being reported to NSLDS via NSC accurately due to a flaw in their process causing degree confirmations to be overridden with other enrollment information prior to submission. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately. Inaccurate reporting of student enrollment data can result in inconsistencies between the University’s records and the National Student Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2024-001, 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 accurately.
University Response: The University agrees with the finding. The University is implementing enhanced internal controls to ensure enrollment status changes and degree confirmations are being appropriately submitted and reported.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268
Program Expenditures: $38,764,799
Program Name: Federal Pell Grant Program, Federal Direct Student Loans
Award Number(s): P063P211391, P063P221391, P063P231391, P268K231391, and P268K241391
Questioned Costs: None
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate enrollment reporting for all students. During our testing of Pell or Direct Loan borrowers, we noted 8 out of 40 (20%) students campus-level record and program-level record were not updated with accurate enrollment status changes. The sample was not a statistically valid sample. The University is required to report enrollment reporting changes accurately. 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 to be inaccurate for 8 students tested out of 40 students tested (20% of 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, there was a flaw in the University’s process that caused the fall graduate batch of students to be initially coded to “G-Not Applied” in the National Student Loan Data System (NSLDS). This was due to an error in the upload compared with underlying information in the NSLDS system. When the next batch of students were submitted to the NSLDS, this resulted in all “G-Not Applied” students to auto-update to “Withdrawn” in the NSLDS system.
Criteria: 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 in accordance with enrollment reporting in transmissions sent to the NSLDS, including updating all flagged information by NSLDS. 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.
Cause and Effect: University officials indicated staff turnover required reassessment of internal documentation and procedure that were in place to ensure all required campus-level data and program-level data was being reported to NSLDS via NSC accurately due to a flaw in their process causing degree confirmations to be overridden with other enrollment information prior to submission. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately. Inaccurate reporting of student enrollment data can result in inconsistencies between the University’s records and the National Student Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2024-001, 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 accurately.
University Response: The University agrees with the finding. The University is implementing enhanced internal controls to ensure enrollment status changes and degree confirmations are being appropriately submitted and reported.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268
Program Expenditures: $38,764,799
Program Name: Federal Pell Grant Program, Federal Direct Student Loans
Award Number(s): P063P211391, P063P221391, P063P231391, P268K231391, and P268K241391
Questioned Costs: None
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate enrollment reporting for all students. During our testing of Pell or Direct Loan borrowers, we noted 8 out of 40 (20%) students campus-level record and program-level record were not updated with accurate enrollment status changes. The sample was not a statistically valid sample. The University is required to report enrollment reporting changes accurately. 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 to be inaccurate for 8 students tested out of 40 students tested (20% of 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, there was a flaw in the University’s process that caused the fall graduate batch of students to be initially coded to “G-Not Applied” in the National Student Loan Data System (NSLDS). This was due to an error in the upload compared with underlying information in the NSLDS system. When the next batch of students were submitted to the NSLDS, this resulted in all “G-Not Applied” students to auto-update to “Withdrawn” in the NSLDS system.
Criteria: 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 in accordance with enrollment reporting in transmissions sent to the NSLDS, including updating all flagged information by NSLDS. 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.
Cause and Effect: University officials indicated staff turnover required reassessment of internal documentation and procedure that were in place to ensure all required campus-level data and program-level data was being reported to NSLDS via NSC accurately due to a flaw in their process causing degree confirmations to be overridden with other enrollment information prior to submission. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately. Inaccurate reporting of student enrollment data can result in inconsistencies between the University’s records and the National Student Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2024-001, 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 accurately.
University Response: The University agrees with the finding. The University is implementing enhanced internal controls to ensure enrollment status changes and degree confirmations are being appropriately submitted and reported.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268
Program Expenditures: $38,764,799
Program Name: Federal Pell Grant Program, Federal Direct Student Loans
Award Number(s): P063P211391, P063P221391, P063P231391, P268K231391, and P268K241391
Questioned Costs: None
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate enrollment reporting for all students. During our testing of Pell or Direct Loan borrowers, we noted 8 out of 40 (20%) students campus-level record and program-level record were not updated with accurate enrollment status changes. The sample was not a statistically valid sample. The University is required to report enrollment reporting changes accurately. 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 to be inaccurate for 8 students tested out of 40 students tested (20% of 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, there was a flaw in the University’s process that caused the fall graduate batch of students to be initially coded to “G-Not Applied” in the National Student Loan Data System (NSLDS). This was due to an error in the upload compared with underlying information in the NSLDS system. When the next batch of students were submitted to the NSLDS, this resulted in all “G-Not Applied” students to auto-update to “Withdrawn” in the NSLDS system.
Criteria: 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 in accordance with enrollment reporting in transmissions sent to the NSLDS, including updating all flagged information by NSLDS. 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.
Cause and Effect: University officials indicated staff turnover required reassessment of internal documentation and procedure that were in place to ensure all required campus-level data and program-level data was being reported to NSLDS via NSC accurately due to a flaw in their process causing degree confirmations to be overridden with other enrollment information prior to submission. Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data will not be reported accurately. Inaccurate reporting of student enrollment data can result in inconsistencies between the University’s records and the National Student Loan Data System as well as potential delays in the repayment of federal loans. (Finding Code No. 2024-001, 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 accurately.
University Response: The University agrees with the finding. The University is implementing enhanced internal controls to ensure enrollment status changes and degree confirmations are being appropriately submitted and reported.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268, 84.007, 84.379
Program Expenditures: $39,166,408
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, P268K231391, P268K241391,
P007A241313, P379T231391, and P379T241391
Questioned Costs: $50
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate and 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 3 out of 40 (7.5%) students return of Title IV funds were not processed within the 45 day window, ranging from 4-25 days late. Additionally, we noted 1 student out of 40 (2.5%) had an incorrect calculation performed, resulting in $50 in excess Pell funds being returned to the Department of Education. The sample was not a statistically valid sample.
Criteria: A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns accurately within 45 days after the determined date of withdrawal (34 CFR 668.173(b)), and accurately calculate the amount of unearned title IV assistance to be returned to the Department of Education (34 CFR 668.22(g)). 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.
Cause and Effect: University management indicated staffing shortages as well as regulatory and systemic changes during the 2023-2024 aid year caused this to occur. There were questioned costs of $50 due to the calculation error, resulting in a $50 overpayment to the
Department of Education. Without sufficient controls in place to return Title IV funds there is a greater risk that the school does not return funds timely or accurately or that students may not receive post-withdrawal disbursements timely or accurately. (Finding Code No. 2024-002, 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 and additional controls to ensure proper review of the return of Title IV calculations. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame and accurately.
University Response: The University agrees with the finding. The University is committed to developing a comprehensive plan to ensure compliance with return of Title IV funds policies and procedures.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268, 84.007, 84.379
Program Expenditures: $39,166,408
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, P268K231391, P268K241391,
P007A241313, P379T231391, and P379T241391
Questioned Costs: $50
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate and 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 3 out of 40 (7.5%) students return of Title IV funds were not processed within the 45 day window, ranging from 4-25 days late. Additionally, we noted 1 student out of 40 (2.5%) had an incorrect calculation performed, resulting in $50 in excess Pell funds being returned to the Department of Education. The sample was not a statistically valid sample.
Criteria: A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns accurately within 45 days after the determined date of withdrawal (34 CFR 668.173(b)), and accurately calculate the amount of unearned title IV assistance to be returned to the Department of Education (34 CFR 668.22(g)). 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.
Cause and Effect: University management indicated staffing shortages as well as regulatory and systemic changes during the 2023-2024 aid year caused this to occur. There were questioned costs of $50 due to the calculation error, resulting in a $50 overpayment to the
Department of Education. Without sufficient controls in place to return Title IV funds there is a greater risk that the school does not return funds timely or accurately or that students may not receive post-withdrawal disbursements timely or accurately. (Finding Code No. 2024-002, 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 and additional controls to ensure proper review of the return of Title IV calculations. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame and accurately.
University Response: The University agrees with the finding. The University is committed to developing a comprehensive plan to ensure compliance with return of Title IV funds policies and procedures.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268, 84.007, 84.379
Program Expenditures: $39,166,408
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, P268K231391, P268K241391,
P007A241313, P379T231391, and P379T241391
Questioned Costs: $50
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate and 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 3 out of 40 (7.5%) students return of Title IV funds were not processed within the 45 day window, ranging from 4-25 days late. Additionally, we noted 1 student out of 40 (2.5%) had an incorrect calculation performed, resulting in $50 in excess Pell funds being returned to the Department of Education. The sample was not a statistically valid sample.
Criteria: A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns accurately within 45 days after the determined date of withdrawal (34 CFR 668.173(b)), and accurately calculate the amount of unearned title IV assistance to be returned to the Department of Education (34 CFR 668.22(g)). 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.
Cause and Effect: University management indicated staffing shortages as well as regulatory and systemic changes during the 2023-2024 aid year caused this to occur. There were questioned costs of $50 due to the calculation error, resulting in a $50 overpayment to the
Department of Education. Without sufficient controls in place to return Title IV funds there is a greater risk that the school does not return funds timely or accurately or that students may not receive post-withdrawal disbursements timely or accurately. (Finding Code No. 2024-002, 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 and additional controls to ensure proper review of the return of Title IV calculations. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame and accurately.
University Response: The University agrees with the finding. The University is committed to developing a comprehensive plan to ensure compliance with return of Title IV funds policies and procedures.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268, 84.007, 84.379
Program Expenditures: $39,166,408
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, P268K231391, P268K241391,
P007A241313, P379T231391, and P379T241391
Questioned Costs: $50
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate and 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 3 out of 40 (7.5%) students return of Title IV funds were not processed within the 45 day window, ranging from 4-25 days late. Additionally, we noted 1 student out of 40 (2.5%) had an incorrect calculation performed, resulting in $50 in excess Pell funds being returned to the Department of Education. The sample was not a statistically valid sample.
Criteria: A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns accurately within 45 days after the determined date of withdrawal (34 CFR 668.173(b)), and accurately calculate the amount of unearned title IV assistance to be returned to the Department of Education (34 CFR 668.22(g)). 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.
Cause and Effect: University management indicated staffing shortages as well as regulatory and systemic changes during the 2023-2024 aid year caused this to occur. There were questioned costs of $50 due to the calculation error, resulting in a $50 overpayment to the
Department of Education. Without sufficient controls in place to return Title IV funds there is a greater risk that the school does not return funds timely or accurately or that students may not receive post-withdrawal disbursements timely or accurately. (Finding Code No. 2024-002, 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 and additional controls to ensure proper review of the return of Title IV calculations. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame and accurately.
University Response: The University agrees with the finding. The University is committed to developing a comprehensive plan to ensure compliance with return of Title IV funds policies and procedures.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268, 84.007, 84.379
Program Expenditures: $39,166,408
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, P268K231391, P268K241391,
P007A241313, P379T231391, and P379T241391
Questioned Costs: $50
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate and 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 3 out of 40 (7.5%) students return of Title IV funds were not processed within the 45 day window, ranging from 4-25 days late. Additionally, we noted 1 student out of 40 (2.5%) had an incorrect calculation performed, resulting in $50 in excess Pell funds being returned to the Department of Education. The sample was not a statistically valid sample.
Criteria: A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns accurately within 45 days after the determined date of withdrawal (34 CFR 668.173(b)), and accurately calculate the amount of unearned title IV assistance to be returned to the Department of Education (34 CFR 668.22(g)). 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.
Cause and Effect: University management indicated staffing shortages as well as regulatory and systemic changes during the 2023-2024 aid year caused this to occur. There were questioned costs of $50 due to the calculation error, resulting in a $50 overpayment to the
Department of Education. Without sufficient controls in place to return Title IV funds there is a greater risk that the school does not return funds timely or accurately or that students may not receive post-withdrawal disbursements timely or accurately. (Finding Code No. 2024-002, 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 and additional controls to ensure proper review of the return of Title IV calculations. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame and accurately.
University Response: The University agrees with the finding. The University is committed to developing a comprehensive plan to ensure compliance with return of Title IV funds policies and procedures.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268, 84.007, 84.379
Program Expenditures: $39,166,408
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, P268K231391, P268K241391,
P007A241313, P379T231391, and P379T241391
Questioned Costs: $50
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate and 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 3 out of 40 (7.5%) students return of Title IV funds were not processed within the 45 day window, ranging from 4-25 days late. Additionally, we noted 1 student out of 40 (2.5%) had an incorrect calculation performed, resulting in $50 in excess Pell funds being returned to the Department of Education. The sample was not a statistically valid sample.
Criteria: A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns accurately within 45 days after the determined date of withdrawal (34 CFR 668.173(b)), and accurately calculate the amount of unearned title IV assistance to be returned to the Department of Education (34 CFR 668.22(g)). 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.
Cause and Effect: University management indicated staffing shortages as well as regulatory and systemic changes during the 2023-2024 aid year caused this to occur. There were questioned costs of $50 due to the calculation error, resulting in a $50 overpayment to the
Department of Education. Without sufficient controls in place to return Title IV funds there is a greater risk that the school does not return funds timely or accurately or that students may not receive post-withdrawal disbursements timely or accurately. (Finding Code No. 2024-002, 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 and additional controls to ensure proper review of the return of Title IV calculations. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame and accurately.
University Response: The University agrees with the finding. The University is committed to developing a comprehensive plan to ensure compliance with return of Title IV funds policies and procedures.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268, 84.007, 84.379
Program Expenditures: $39,166,408
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, P268K231391, P268K241391,
P007A241313, P379T231391, and P379T241391
Questioned Costs: $50
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate and 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 3 out of 40 (7.5%) students return of Title IV funds were not processed within the 45 day window, ranging from 4-25 days late. Additionally, we noted 1 student out of 40 (2.5%) had an incorrect calculation performed, resulting in $50 in excess Pell funds being returned to the Department of Education. The sample was not a statistically valid sample.
Criteria: A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns accurately within 45 days after the determined date of withdrawal (34 CFR 668.173(b)), and accurately calculate the amount of unearned title IV assistance to be returned to the Department of Education (34 CFR 668.22(g)). 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.
Cause and Effect: University management indicated staffing shortages as well as regulatory and systemic changes during the 2023-2024 aid year caused this to occur. There were questioned costs of $50 due to the calculation error, resulting in a $50 overpayment to the
Department of Education. Without sufficient controls in place to return Title IV funds there is a greater risk that the school does not return funds timely or accurately or that students may not receive post-withdrawal disbursements timely or accurately. (Finding Code No. 2024-002, 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 and additional controls to ensure proper review of the return of Title IV calculations. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame and accurately.
University Response: The University agrees with the finding. The University is committed to developing a comprehensive plan to ensure compliance with return of Title IV funds policies and procedures.
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268, 84.007, 84.379
Program Expenditures: $39,166,408
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, P268K231391, P268K241391,
P007A241313, P379T231391, and P379T241391
Questioned Costs: $50
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate and 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 3 out of 40 (7.5%) students return of Title IV funds were not processed within the 45 day window, ranging from 4-25 days late. Additionally, we noted 1 student out of 40 (2.5%) had an incorrect calculation performed, resulting in $50 in excess Pell funds being returned to the Department of Education. The sample was not a statistically valid sample.
Criteria: A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns accurately within 45 days after the determined date of withdrawal (34 CFR 668.173(b)), and accurately calculate the amount of unearned title IV assistance to be returned to the Department of Education (34 CFR 668.22(g)). 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.
Cause and Effect: University management indicated staffing shortages as well as regulatory and systemic changes during the 2023-2024 aid year caused this to occur. There were questioned costs of $50 due to the calculation error, resulting in a $50 overpayment to the
Department of Education. Without sufficient controls in place to return Title IV funds there is a greater risk that the school does not return funds timely or accurately or that students may not receive post-withdrawal disbursements timely or accurately. (Finding Code No. 2024-002, 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 and additional controls to ensure proper review of the return of Title IV calculations. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame and accurately.
University Response: The University agrees with the finding. The University is committed to developing a comprehensive plan to ensure compliance with return of Title IV funds policies and procedures.