Finding Text
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268
Program Expenditures: $38,687,691
Program Name: Federal Pell Grant Program, Federal Direct Student Loans
Award Number(s): P063P211391, P063P221391, P063P231391, P268K221391, and P268K231391
Questioned Costs: None
Western Illinois University (University) did not have adequate procedures in place to complete accurate
and timely enrollment reporting for all students within the required time period.
During our testing of Pell or Direct Loan borrowers, we noted 21 out of 40 (53%) students campus-level
record and program-level record were not updated within the required time frame, ranging from 11-52 days
late. For 19 out of the 21 students noted above, we also noted the enrollment effective date was incorrect
(19 out of 40 students tested, 48%). The sample was not a statistically valid sample.
The University is required to report enrollment reporting changes no less than every 60 days. 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 not being reported
timely for 21 students tested or accurately for 19 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 at least every 30 days, there was a flaw in the University’s process that caused enrollment status
changes and degree confirmations submitted to the NSC to not ultimately be submitted to National Student
Loan Data System (NSLDS), resulting in enrollment reporting changes to be reported greater than 60 days
after program enrollment effective date (for 21 students tested) and in some cases, with incorrect enrollment
effective date (for 19 out of the 21 students noted above).
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 within 30 days of the change or included in a Student Status Confirmation Report
(SSCR) sent to the NSLDS within 60 days of the status change.
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 and timely.
University officials indicated the University did not have adequate procedures in place to ensure all required
campus-level data and program-level data was being reported to NSLDS via NSC due to a flaw in their
process causing degree confirmations to be overridden with other enrollment information prior to
submission. The University did not have an appropriate enrollment reporting timeline to ensure student
status changes were reported in the required time frame.
Without sufficient controls around enrollment reporting there is a greater risk that student enrollment data
will not be reported accurately or timely. Inaccurate or untimely reporting of student enrollment data can
result in inconsistencies between the University’s records and the National Students Loan Data System as
well as potential delays in the repayment of federal loans. (Finding Code No. 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 at least every 60 days.
We also recommend these controls be monitored to ensure that all necessary information is reported within the
required time frame.
UNIVERSITY RESPONSE
The University agrees with the finding. Procedural changes have been identified and internal controls will be
implemented moving forward to ensure that enrollment status changes and degree confirmations are being
appropriately submitted and reported, and that they are done so in a timely manner.