Audit 348932

Federal Agency: US Department of Education (ED) Program Name: Student Financial Assistance Cluster: Federal Direct Student Loans ALN: 84.268 Award Numbers: N/A; Federal Awards Year 2023 - 2024 Questioned Costs: None Repeat Finding: No 2024-003. Finding: Errors in Reporting for NSLDS Northern Illinois University (the University) did not properly report enrollment changes for certain students who received federal student aid to the National Student Loan Data System (NSLDS) and the internal controls in place did not identify the errors. Condition: Out of 40 students tested, we noted 1 (2.5%) student in which the University did not report the correct enrollment effective date to the NSLDS at the Program Level. Out of 40 students tested, we noted 1 (2.5%) student in which the University did not report the correct enrollment effective date to the NSLDS at the Campus Level. Out of 40 students tested, we noted 1 (2.5%) student in which the University did not timely report the correct enrollment effective date to the NSLDS at the Campus Level. The sample was not intended to be, and was not, a statistically valid sample. Criteria: The Code of Federal Regulations (34 CFR 685.309) requires enrollment status changes for students to be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status to include an accurate effective date. According to the NSLDS Enrollment Reporting Guide, a student’s Program-Level enrollment status should be reported with the same enrollment status as that student’s campus-level enrollment status for all programs the student is enrolled in at that location, even if the student is not currently taking coursework that applies to a particular program. If the student has withdrawn or graduated from an academic program, a “terminal enrollment status” of ‘W’ or ‘G,’ as appropriate, should be reported for that program, even if the student is still taking coursework applicable to other programs in which the student is enrolled. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to 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 completed properly.  Cause: University officials stated the two Campus Level exceptions were the result of a change to system configuration to reflect an academic policy change in the graduate school regarding the assignment of grades for course and program withdrawals. A new withdrawal grade code was implemented for 45 graduate students for the 2023-2024 academic year which caused the student information system enrollment reporting logic not to accurately calculate a withdrawal status for some students. University officials also stated the Program Level exception was the result of a misinterpretation of NSLDS reporting requirements regarding the appropriate effective date to provide in the event that a student’s withdrawal is processed on a later date than the withdrawal’s effective date. Effect: If the NSLDS system is not properly updated with the student information, overawards could occur should the student transfer to another institution and the student may not properly enter the repayment period. (Finding Code No. 2024-003) Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. University Response: Accepted. The University will take steps to address the recommendation in this finding. The University will correct the software issue which caused some students with the new withdrawal grade code to not have a withdrawal status calculated correctly at the campus level. The University will provide additional training and guidance to address the misinterpretation of withdrawal status effective date reporting which caused an error at the program level.

Federal Agency: US Department of Education (ED) Program Name: Fund for the Improvement of Postsecondary Education ALN: 84.116 Award Number: P116Z230260; Federal Awards Year 2023 - 2024 Questioned Costs: None Repeat Finding: No 2024-004. Finding: Internal Controls Over Procurement Northern Illinois University (the University) included incorrect documentation within purchase requisition forms for small purchases and simplified acquisition procurement transactions at the time of approval of the purchase which did not allow a reviewer to determine the appropriateness of the procurement method in the Fund for the Improvement of Postsecondary Education program. Condition: The University’s internal controls over purchases include review and approval of purchase requisitions in PeopleSoft that document the procurement method selected. Out of four small purchase procurement transactions tested, four transactions (100%) were approved based on a form that summarized the incorrect procurement method. The University incorrectly indicated on a small purchase waiver form that the transactions were exempt from procurement under Illinois Procurement Code (30 ILCS 500 / 1-13(b)(8)). Out of four transactions tested meeting the simplified acquisition threshold, four transactions (100%) were approved based on a form that summarized the incorrect procurement method. The University incorrectly indicated on a small purchase waiver form that the transactions were exempt from procurement under Illinois Procurement Code (30 ILCS 500 / 1-13(b)(8)). Based on additional information provided to us during our testing, the University did have other documentation to support the history of procurement, including rationale for the method of procurement and there were no indications that procurement methods ultimately used were inappropriate. The sample was not intended to be, and was not, a statistically valid sample. Criteria: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal 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 procurement procedures are properly followed and support is properly maintained as required by 2 CFR 200.318. Cause: University officials stated that staff turnover and lack of training on policies and procedures governing procurements subject to 2 CFR 200 lead to the incorrect documentation on the purchase requisitions. Effect: If the purchase requisition forms contain an incorrect rationale for the procurement method selected, the University could approve payments of federal funds to vendors that do not meet federal regulations. (Finding Code No. 2024-004) Recommendation: We recommend the University review current processes for small purchases and simplified acquisition transactions to ensure purchase requisition forms are completed correctly. University Response: Accepted. The University has already initiated a review of current processes and is taking steps to address the recommendation.

Federal Agency: US Department of Education (ED) Program Name: Student Financial Assistance Cluster: Federal Direct Student Loans ALN: 84.268 Award Numbers: N/A; Federal Awards Year 2023 - 2024 Questioned Costs: None Repeat Finding: No 2024-003. Finding: Errors in Reporting for NSLDS Northern Illinois University (the University) did not properly report enrollment changes for certain students who received federal student aid to the National Student Loan Data System (NSLDS) and the internal controls in place did not identify the errors. Condition: Out of 40 students tested, we noted 1 (2.5%) student in which the University did not report the correct enrollment effective date to the NSLDS at the Program Level. Out of 40 students tested, we noted 1 (2.5%) student in which the University did not report the correct enrollment effective date to the NSLDS at the Campus Level. Out of 40 students tested, we noted 1 (2.5%) student in which the University did not timely report the correct enrollment effective date to the NSLDS at the Campus Level. The sample was not intended to be, and was not, a statistically valid sample. Criteria: The Code of Federal Regulations (34 CFR 685.309) requires enrollment status changes for students to be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status to include an accurate effective date. According to the NSLDS Enrollment Reporting Guide, a student’s Program-Level enrollment status should be reported with the same enrollment status as that student’s campus-level enrollment status for all programs the student is enrolled in at that location, even if the student is not currently taking coursework that applies to a particular program. If the student has withdrawn or graduated from an academic program, a “terminal enrollment status” of ‘W’ or ‘G,’ as appropriate, should be reported for that program, even if the student is still taking coursework applicable to other programs in which the student is enrolled. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to 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 completed properly.  Cause: University officials stated the two Campus Level exceptions were the result of a change to system configuration to reflect an academic policy change in the graduate school regarding the assignment of grades for course and program withdrawals. A new withdrawal grade code was implemented for 45 graduate students for the 2023-2024 academic year which caused the student information system enrollment reporting logic not to accurately calculate a withdrawal status for some students. University officials also stated the Program Level exception was the result of a misinterpretation of NSLDS reporting requirements regarding the appropriate effective date to provide in the event that a student’s withdrawal is processed on a later date than the withdrawal’s effective date. Effect: If the NSLDS system is not properly updated with the student information, overawards could occur should the student transfer to another institution and the student may not properly enter the repayment period. (Finding Code No. 2024-003) Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. University Response: Accepted. The University will take steps to address the recommendation in this finding. The University will correct the software issue which caused some students with the new withdrawal grade code to not have a withdrawal status calculated correctly at the campus level. The University will provide additional training and guidance to address the misinterpretation of withdrawal status effective date reporting which caused an error at the program level.

Federal Agency: US Department of Education (ED) Program Name: Fund for the Improvement of Postsecondary Education ALN: 84.116 Award Number: P116Z230260; Federal Awards Year 2023 - 2024 Questioned Costs: None Repeat Finding: No 2024-004. Finding: Internal Controls Over Procurement Northern Illinois University (the University) included incorrect documentation within purchase requisition forms for small purchases and simplified acquisition procurement transactions at the time of approval of the purchase which did not allow a reviewer to determine the appropriateness of the procurement method in the Fund for the Improvement of Postsecondary Education program. Condition: The University’s internal controls over purchases include review and approval of purchase requisitions in PeopleSoft that document the procurement method selected. Out of four small purchase procurement transactions tested, four transactions (100%) were approved based on a form that summarized the incorrect procurement method. The University incorrectly indicated on a small purchase waiver form that the transactions were exempt from procurement under Illinois Procurement Code (30 ILCS 500 / 1-13(b)(8)). Out of four transactions tested meeting the simplified acquisition threshold, four transactions (100%) were approved based on a form that summarized the incorrect procurement method. The University incorrectly indicated on a small purchase waiver form that the transactions were exempt from procurement under Illinois Procurement Code (30 ILCS 500 / 1-13(b)(8)). Based on additional information provided to us during our testing, the University did have other documentation to support the history of procurement, including rationale for the method of procurement and there were no indications that procurement methods ultimately used were inappropriate. The sample was not intended to be, and was not, a statistically valid sample. Criteria: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal 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 procurement procedures are properly followed and support is properly maintained as required by 2 CFR 200.318. Cause: University officials stated that staff turnover and lack of training on policies and procedures governing procurements subject to 2 CFR 200 lead to the incorrect documentation on the purchase requisitions. Effect: If the purchase requisition forms contain an incorrect rationale for the procurement method selected, the University could approve payments of federal funds to vendors that do not meet federal regulations. (Finding Code No. 2024-004) Recommendation: We recommend the University review current processes for small purchases and simplified acquisition transactions to ensure purchase requisition forms are completed correctly. University Response: Accepted. The University has already initiated a review of current processes and is taking steps to address the recommendation.