Finding 1181361 (2025-001)

Material Weakness Repeat Finding
Requirement
A
Questioned Costs
-
Year
2025
Accepted
2026-03-18
Audit: 392593
Organization: Millikin University (IL)
Auditor: SIKICH CPA LLC

AI Summary

  • Core Issue: Four federal work study recipients were found working during scheduled class hours, violating compliance requirements.
  • Impacted Requirements: Noncompliance with 34 CFR 675.20 regarding work study positions and class schedules.
  • Recommended Follow-Up: Review and adjust policies to prevent compensation for hours worked during class times.

Finding Text

2025-001 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program - Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is - (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be - … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.” Volume 6, Chapter 2 of the 2024-2025 Federal Student Aid Handbook page 7 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented.” Volume 6, Chapter 2 of the 2024-2025 Federal Student Aid Handbook page 11 notes, “You must maintain adequate timesheets or records of hours worked for FWS students. These timesheets must show, separately for each day worked, the hours a student worked, and the total hours worked during the job’s payment cycle (i.e., twice a month, every week, every two weeks, etc., but not less than once a month). These amounts and hours recorded must match the hours for which the student is paid. Condition: During our testing of forty individuals receiving federal work study, we noted four individuals (10%) working during scheduled class hours. We consider this condition to be an instance of noncompliance relating to Activities Allowed or Unallowed compliance requirement and is not a repeat finding. Statistical sampling was not used in making sample selections. Questioned Costs: $45 Cause & Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations. Recommendation: We recommend the University evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

Corrective Action Plan

2025-001 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program - Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Condition: During our testing of forty individuals receiving federal work study, we noted four individuals (10%) working during scheduled class hours. We consider this condition to be an instance of noncompliance relating to Activities Allowed or Unallowed compliance requirement and is not a repeat finding. Statistical sampling was not used in making sample selections. Management Response: We accept this finding. Corrective Action Plan: Additional planning is ongoing to correct timecards to not allow students to clock work hours during their scheduled classes. Additional training will also be provided to timecard approval staff for departments with student workers receiving Federal Work Study. Responsible Person: Student Employment/Financial Aid Implementation Date: January 2026

Categories

Student Financial Aid

Other Findings in this Audit

  • 1181362 2025-002
    Material Weakness Repeat
  • 1181363 2025-003
    Material Weakness Repeat
  • 1181364 2025-002
    Material Weakness Repeat
  • 1181365 2025-003
    Material Weakness Repeat
  • 1181366 2025-003
    Material Weakness Repeat
  • 1181367 2025-003
    Material Weakness Repeat
  • 1181368 2025-003
    Material Weakness Repeat
  • 1181369 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $9.95M
84.063 FEDERAL PELL GRANT PROGRAM $3.86M
84.038 FEDERAL PERKINS LOAN - FEDERAL CAPITAL CONTRIBUTIONS $517,003
84.031 HIGHER EDUCATION_INSTITUTIONAL AID $352,088
84.033 FEDERAL WORK-STUDY PROGRAM $276,890
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $154,076
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $3,772