FAC Explorer

Finding 381120 (2023-003)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-19
Audit: 295860
Organization: Western Illinois University (IL)
Auditor: Plante & Moran PLLC

AI Summary

  • Core Issue: Western Illinois University failed to update verification statuses for 24% of students selected for verification in the COD database.
  • Impacted Requirements: The University did not comply with timely updating requirements as mandated by 34 CFR 668.53(a) and 2 CFR 200.303(a).
  • Recommended Follow-Up: Implement stronger controls to ensure accurate and timely updates of verification statuses in the COD.

Finding Text

Federal Agency: U.S. Department of Education Assistance Listing Number: 84.063 Program Expenditures: $12,171,226 Program Name: Federal Pell Grant Program Award Number(s): P063P211391, P063P221391, and P063P231391 Questioned Costs: None Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely updating of verification statuses in the Common Origination and Disbursement (COD) database for all students within the required time period. During our testing of borrowers that had been selected for verification at the University, we noted 6 out of 25 (24%) students whose verification status was not properly reflected in the COD records. The sample was not a statistically valid sample. The University is required to update the verification status for all borrowers in the COD timely for those selected for verification. During the year, there was a misunderstanding of the waived verification requirements allowable under Dear Colleague Letter “Changes to 2022-2023 Verification Requirements” (GEN-22-06), which caused 6 out of 25 students to not have their verification status updated in the COD. A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and verify an applicant’s FAFSA information and maintain up to date accurate information in COD (34 CFR 668.53(a)). 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 verification status for students is updated accurately and timely. University management indicated there was a misunderstanding of the waived verification requirements which caused this error. Failure to have sufficient controls around verification requirements, resulted in the University not accurately or timely updating the verification status in the COD to report that required verifications occurred for students selected by the Department of Education for verification. (Finding Code No. 2023-003) RECOMMENDATION We recommend the University implement controls to ensure that all students verification statuses are updated accurately and timely in the COD. UNIVERSITY RESPONSE The University agrees with the finding. The University's internal controls have been updated as the Department of Education has released the COVID suspension of the verification process.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment Internal Control / Segregation of Duties

Other Findings in this Audit

  • 381106 2023-001
    Material Weakness Repeat
  • 381107 2023-001
    Material Weakness Repeat
  • 381108 2023-001
    Material Weakness Repeat
  • 381109 2023-001
    Material Weakness Repeat
  • 381110 2023-001
    Material Weakness Repeat
  • 381111 2023-002
    Material Weakness
  • 381112 2023-002
    Material Weakness
  • 381113 2023-002
    Material Weakness
  • 381114 2023-002
    Material Weakness
  • 381115 2023-002
    Material Weakness
  • 381116 2023-002
    Material Weakness
  • 381117 2023-002
    Material Weakness
  • 381118 2023-002
    Material Weakness
  • 381119 2023-003
    Significant Deficiency
  • 381121 2023-003
    Significant Deficiency
  • 957548 2023-001
    Material Weakness Repeat
  • 957549 2023-001
    Material Weakness Repeat
  • 957550 2023-001
    Material Weakness Repeat
  • 957551 2023-001
    Material Weakness Repeat
  • 957552 2023-001
    Material Weakness Repeat
  • 957553 2023-002
    Material Weakness
  • 957554 2023-002
    Material Weakness
  • 957555 2023-002
    Material Weakness
  • 957556 2023-002
    Material Weakness
  • 957557 2023-002
    Material Weakness
  • 957558 2023-002
    Material Weakness
  • 957559 2023-002
    Material Weakness
  • 957560 2023-002
    Material Weakness
  • 957561 2023-003
    Significant Deficiency
  • 957562 2023-003
    Significant Deficiency
  • 957563 2023-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $26.61M
84.173 Special Education_preschool Grants $869,389
84.038 Federal Perkins Loan Program Federal Capital Contributions $826,384
12.431 Basic Scientific Research $716,681
84.425 Covid-19 - Education Stabilization Fund $637,602
20.509 Formula Grants for Rural Areas and Tribal Transit Program $436,368
84.033 Federal Work-Study Program $426,955
93.570 Community Services Block Grant_discretionary Awards $312,821
84.007 Federal Supplemental Educational Opportunity Grants $270,101
84.002 Adult Education - Basic Grants to States $184,818
81.049 Office of Science Financial Assistance Program $179,596
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $126,843
94.006 Americorps $122,852
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $108,140
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $66,644
10.771 Rural Cooperative Development Grants $64,529
84.016 Undergraduate International Studies and Foreign Language Programs $55,510
94.013 Volunteers in Service to America $48,248
10.871 Socially-Disadvantaged Groups Grant $42,018
10.175 Farmers Market and Local Food Promotion Program (b) $33,560
93.558 Temporary Assistance for Needy Families $33,272
21.019 Covid-19 Coronavirus Relief Fund $20,611
16.835 Body Worn Camera Policy and Implementation $19,900
59.059 Congressional Grants $16,320
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $15,522
47.049 Mathematical and Physical Sciences $13,183
47.076 Education and Human Resources $11,830
10.310 Agriculture and Food Research Initiative (afri) $11,054
84.063 Federal Pell Grant Program $10,398
93.434 Every Student Succeeds Act/preschool Development Grants $7,956
59.037 Small Business Development Centers $5,343
10.326 Capacity Building for Non-Land Grant Colleges of Agriculture (nlgca) $3,038
10.170 Specialty Crop Block Grant Program - Farm Bill $272
12.002 Procurement Technical Assistance for Business Firms $204
10.307 Organic Agriculture Research and Extension Initiative $140
97.067 Homeland Security Grant Program $13