Audit 395596

Assistance Listing, Federal Agency, and Program Name Student Financial Assistance Cluster Federal Direct Student Loan Program, ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year Various Pass through Entity N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2024-001 Criteria - The University has 60 days from the date the University determines an enrollment status change to report to National Student Loan Data System (NSLDS). The enrollment reporting must be updated for changes in the data elements for the campus record and program record and submitted electronically through the batch method, spreadsheet submittal, or the NSLDS website (34 CFR 685.309). Condition - Of the 40 students selected for enrollment reporting testing, the University did not properly update the student enrollment information for 3 students accurately. Questioned Costs - None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - N/A Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, there were 3 students who withdrew whose status change was not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in an accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Western Michigan University has discontinued the use of manual enrollment status updates in the NSC Student Look Up tool for unofficial withdrawals. The Registrar’s Office now records last date of attendance and withdrawal status directly in the SIS for all students who earn all E and X grades and are determined to have unofficially withdrawn. All unofficial withdrawal records are included in the final enrollment submission for the term, ensuring that withdrawal status and effective dates are transmitted through certified batch files to NSC and NSLDS.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster Federal Direct Student Loan Program, ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance, but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.220)(1)). Condition - Out of 40 students tested for Return to Title IV, we identified 3 students whose calculations were not performed timely. Questioned Costs - None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - N/A Identification of How Questioned Costs Were Computed - N/A Context - The University did not timely identify students that had loan disbursements but never attended. Out of our sample of 40 students who withdrew from the University, 3 students that never attended the University however received their accepted aid did not have returns completed within 30 days. Cause and Effect - The University's process to identify the students that never attended was not operating effectively and as a result the students were reported outside of the required timeframe. Recommendation - We recommend the University review its processes and controls for identifying students that enrolled but never attended to ensure a timely return of federal aid. Views of Responsible Officials and Planned Corrective Actions - Financial Aid has reviewed our current practices and will implement centralized accountability processes, using the Banner system and associated reports, to monitor all types of student withdrawal and drop determinations, as well as the corresponding R2T4 deadlines. Standardized procedures and a comprehensive processing checklist will be developed to ensure accuracy and timely completion. Staff in both offices will be trained on the updated procedures. Financial Aid will also continue working with the Registrar’s Office to ensure the receipt of accurate and timely enrollment data necessary to meet all Title IV requirements and deadlines.