Finding 1191784 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-30
Audit: 395596
Organization: Western Michigan University (MI)

AI Summary

  • Core Issue: The University failed to timely process Return to Title IV calculations for 3 out of 40 students who withdrew but never attended, violating federal regulations.
  • Impacted Requirements: Schools must return unearned federal funds within 30 days for students who never attended, as per Title IV regulations.
  • Recommended Follow-Up: The University should enhance its identification processes for non-attending students and implement standardized procedures to ensure timely returns of federal aid.

Finding Text

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.

Corrective Action Plan

Condition: Out of 40 students tested for Return to Title IV, we identified 3 students whose calculations were not performed timely. Planned Corrective Action: 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. Contact person responsible for corrective action: Shashanta S James, Director Lana Greaves, Sr. Associate Director Anticipated Completion Date: April 15, 2026

Categories

No categories assigned yet.

Other Findings in this Audit

  • 1191781 2025-001
    Material Weakness Repeat
  • 1191782 2025-002
    Material Weakness Repeat
  • 1191783 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $74.12M
84.063 FEDERAL PELL GRANT PROGRAM $25.16M
84.215 INNOVATIVE APPROACHES TO LITERACY; PROMISE NEIGHBORHOODS; FULL-SERVICE COMMUNITY SCHOOLS; AND CONGRESSIONALLY DIRECTED SPENDING FOR ELEMENTARY AND SECONDARY EDUCATION COMMUNITY PROJECTS $8.40M
84.423 SUPPORTING EFFECTIVE EDUCATOR DEVELOPMENT PROGRAM $3.26M
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $1.45M
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $908,206
84.336 TEACHER QUALITY PARTNERSHIP GRANTS $878,836
93.493 CONGRESSIONAL DIRECTIVES $820,607
84.033 FEDERAL WORK-STUDY PROGRAM $799,020
93.822 HEALTH CAREERS OPPORTUNITY PROGRAM (HCOP) $642,881
84.327 SPECIAL EDUCATION EDUCATIONAL TECHNOLOGY MEDIA, AND MATERIALS FOR INDIVIDUALS WITH DISABILITIES $615,706
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $463,730
93.243 TRAUMATIC BRAIN INJURY STATE DEMONSTRATION GRANT PROGRAM $454,867
84.335 CHILD CARE ACCESS MEANS PARENTS IN SCHOOL $351,446
84.047 TRIO UPWARD BOUND $333,482
84.042 TRIO STUDENT SUPPORT SERVICES $332,928
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $299,834
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $298,131
12.800 AIR FORCE DEFENSE RESEARCH SCIENCES PROGRAM $216,209
93.226 RESEARCH ON HEALTHCARE COSTS, QUALITY AND OUTCOMES $212,114
93.658 FOSTER CARE TITLE IV-E $211,760
47.074 BIOLOGICAL SCIENCES $199,889
15.810 NATIONAL COOPERATIVE GEOLOGIC MAPPING $180,832
93.333 CLINICAL RESEARCH $170,939
84.334 GAINING EARLY AWARENESS AND READINESS FOR UNDERGRADUATE PROGRAMS $165,659
81.086 CONSERVATION RESEARCH AND DEVELOPMENT $159,229
12.420 MILITARY MEDICAL RESEARCH AND DEVELOPMENT $151,182
43.012 SPACE TECHNOLOGY $148,165
84.129 REHABILITATION LONG-TERM TRAINING $144,743
47.084 NSF TECHNOLOGY, INNOVATION, AND PARTNERSHIPS $144,467
12.630 BASIC, APPLIED, AND ADVANCED RESEARCH IN SCIENCE AND ENGINEERING $136,606
93.867 VISION RESEARCH $124,934
93.865 CHILD HEALTH AND HUMAN DEVELOPMENT EXTRAMURAL RESEARCH $119,119
43.001 SCIENCE $114,558
12.750 UNIFORMED SERVICES UNIVERSITY MEDICAL RESEARCH PROJECTS $106,650
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $104,073
12.300 BASIC AND APPLIED SCIENTIFIC RESEARCH $101,169
21.027 COVID-19 - CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $91,414
81.008 CYBERSECURITY, ENERGY SECURITY & EMERGENCY RESPONSE (CESER) $70,339
15.015 GOOD NEIGHBOR AUTHORITY $68,301
15.073 EARTH MAPPING RESOURCES INITIATIVE $65,735
47.049 MATHEMATICAL AND PHYSICAL SCIENCES $59,924
45.162 PROMOTION OF THE HUMANITIES TEACHING AND LEARNING RESOURCES AND CURRICULUM DEVELOPMENT $55,431
15.814 NATIONAL GEOLOGICAL AND GEOPHYSICAL DATA PRESERVATION $52,959
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $50,495
81.049 OFFICE OF SCIENCE FINANCIAL ASSISTANCE PROGRAM $38,006
98.001 USAID FOREIGN ASSISTANCE FOR PROGRAMS OVERSEAS $35,314
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $34,467
84.325 SPECIAL EDUCATION - PERSONNEL DEVELOPMENT TO IMPROVE SERVICES AND RESULTS FOR CHILDREN WITH DISABILITIES $34,209
84.031 HIGHER EDUCATION INSTITUTIONAL AID $32,510
47.075 SOCIAL, BEHAVIORAL, AND ECONOMIC SCIENCES $30,355
15.662 GREAT LAKES RESTORATION $27,578
47.070 COMPUTER AND INFORMATION SCIENCE AND ENGINEERING $24,000
47.050 GEOSCIENCES $23,289
84.027 SPECIAL EDUCATION GRANTS TO STATES $22,502
47.041 ENGINEERING $20,157
10.215 SUSTAINABLE AGRICULTURE RESEARCH AND EDUCATION $16,654
93.279 DRUG USE AND ADDICTION RESEARCH PROGRAMS $16,380
45.313 LAURA BUSH 21ST CENTURY LIBRARIAN PROGRAM $14,323
16.585 TREATMENT COURT DISCRETIONARY GRANT PROGRAM $13,829
93.866 AGING RESEARCH $12,419
20.109 AIR TRANSPORTATION CENTERS OF EXCELLENCE $12,308
93.732 MENTAL AND BEHAVIORAL HEALTH EDUCATION AND TRAINING GRANTS $12,240
81.RD Other Programs: ALN Not Identified $10,932
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $9,567
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $6,664
66.509 SCIENCE TO ACHIEVE RESULTS (STAR) RESEARCH PROGRAM $5,852
45.025 PROMOTION OF THE ARTS PARTNERSHIP AGREEMENTS $4,800
15.657 ENDANGERED SPECIES RECOVERY IMPLEMENTATION $4,653
59.037 SMALL BUSINESS DEVELOPMENT CENTERS $4,096
15.808 U.S. GEOLOGICAL SURVEY RESEARCH AND DATA COLLECTION $4,012
43.008 OFFICE OF STEM ENGAGEMENT (OSTEM) $1,487
45.312 NATIONAL LEADERSHIP GRANTS $1,484
81.089 FOSSIL ENERGY RESEARCH AND DEVELOPMENT $1,209
20.505 METROPOLITAN TRANSPORTATION PLANNING AND STATE AND NON-METROPOLITAN PLANNING AND RESEARCH $876
81.087 RENEWABLE ENERGY RESEARCH AND DEVELOPMENT $-1