Finding Text
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268, 84.007, 84.379
Program Expenditures: $39,166,408
Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental
Education Opportunity Grants, Teacher Education Assistance for College and Higher Education Grants
Award Number(s): P063P211391, P063P221391, P063P231391, P268K231391, P268K241391,
P007A241313, P379T231391, and P379T241391
Questioned Costs: $50
Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely return of Title IV funds for all students within the required time period. During our testing of borrowers that withdrew from the University, we noted 3 out of 40 (7.5%) students return of Title IV funds were not processed within the 45 day window, ranging from 4-25 days late. Additionally, we noted 1 student out of 40 (2.5%) had an incorrect calculation performed, resulting in $50 in excess Pell funds being returned to the Department of Education. The sample was not a statistically valid sample.
Criteria: A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal procedures and initiate returns accurately within 45 days after the determined date of withdrawal (34 CFR 668.173(b)), and accurately calculate the amount of unearned title IV assistance to be returned to the Department of Education (34 CFR 668.22(g)). 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 return of Title IV funds is accurate and timely.
Cause and Effect: University management indicated staffing shortages as well as regulatory and systemic changes during the 2023-2024 aid year caused this to occur. There were questioned costs of $50 due to the calculation error, resulting in a $50 overpayment to the
Department of Education. Without sufficient controls in place to return Title IV funds there is a greater risk that the school does not return funds timely or accurately or that students may not receive post-withdrawal disbursements timely or accurately. (Finding Code No. 2024-002, 2023-002)
Recommendation: We recommend the University implement controls to ensure that all refunds of Title IV funds are initiated within 45 days of the date of determination for the students withdrawal and additional controls to ensure proper review of the return of Title IV calculations. We also recommend these controls be monitored to ensure that all necessary refunds are completed within the required time frame and accurately.
University Response: The University agrees with the finding. The University is committed to developing a comprehensive plan to ensure compliance with return of Title IV funds policies and procedures.