Finding 537969 (2024-001)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-03-27
Audit: 348998
Organization: Western Michigan University (MI)

AI Summary

  • Core Issue: The University failed to accurately update enrollment information for 6 out of 40 students, leading to material weaknesses in compliance with federal reporting requirements.
  • Impacted Requirements: The University must report enrollment status changes to the NSLDS within 60 days, ensuring accurate data for all students, including those who withdrew or changed addresses.
  • Recommended Follow-Up: Update policies to align with federal definitions, implement controls for accurate data reporting, and conduct regular internal audits to verify compliance.

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 and material noncompliance with laws and regulations Repeat Finding No Criteria The University has 60 days from the date the University determines an enrollment status change to report to National Student Loan Data System (NSLDS). The enrollment reporting must be updated for changes in the data elements for the campus record and program record and submitted electronically through the batch method, spreadsheet submittal, or the NSLDS website (34 CFR 685.309). Condition Of the 40 students selected for enrollment reporting testing, the University did not properly update the student enrollment information for 6 students accurately. Questioned Costs None Identification of How Questioned Costs Were Computed N/A Context Out of a sample of 40 students, our testing identified 5 students that were reported as withdrawn from the University with the improper enrollment effective date and 1 student that changed their address at the University and it was not reported to NSLDS. Cause and Effect The University did not have formal procedures and controls in place to determine the appropriate effective date of unofficial withdrawals or properly identify students that changed their address within the University's student information system and ensure these students were properly reported in the monthly enrollment roster. Recommendation The University should update their policy to align the definition of the enrollment effective date with the regulations and implement controls to ensure the appropriate data elements are complete, accurate, and timely prior to submission. Views of Responsible Officials and Corrective Action Plan To ensure accurate and timely reporting of student withdrawals, the Registrar’s Office and the Office of Student Financial Aid have implemented a new process in compliance with 34 CFR 685.309(b) and 34 CFR 668.22: • The Office of Student Financial Aid will generate a list of students who received all failing grades and whose last date of attendance was reported as prior to the end of the term. The report will be shared with the Registrar’s Office. • The Registrar’s Office will then update the student enrollment status to "Withdrawn" in the National Student Clearinghouse database, using the reported last date of attendance as the effective date. • All updates will be submitted within 30 days of determination or included in the next NSLDS reporting cycle, per federal requirements. Staff have received additional training to ensure accurate enrollment status reporting. Additionally, an internal audit process will be implemented to verify that enrollment records are accurately updated each semester.

Corrective Action Plan

Condition: Of the 40 students selected for enrollment reporting testing, the University did not properly update the student enrollment information for 6 students accurately. Planned Corrective Action: To ensure accurate and timely reporting of student withdrawals, the Registrar’s Office and the Office of Student Financial Aid have implemented a new process in compliance with 34 CFR 685.309(b) and 34 CFR 668.22:  The Office of Student Financial Aid will generate a list of students who received all failing grades and whose last date of attendance was reported as prior to the end of the term. The report will be shared with the Registrar’s Office.  The Registrar’s Office will then update the student enrollment status to "Withdrawn" in the National Student Clearinghouse database, using the reported last date of attendance as the effective date.  All updates will be submitted within 30 days of determination or included in the next NSLDS reporting cycle, per federal requirements. Staff have received additional training to ensure accurate enrollment status reporting. Additionally, an internal audit process will be implemented to verify that enrollment records are accurately updated each semester. Contact person responsible for corrective action: Carrie Cumming, Registrar Anticipated Completion Date: July 2025

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Material Weakness Reporting

Other Findings in this Audit

  • 537970 2024-001
    Material Weakness
  • 1114411 2024-001
    Material Weakness
  • 1114412 2024-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $85.36M
84.063 Federal Pell Grant Program $19.58M
84.215 Innovative Approaches to Literacy; Promise Neighborhoods; Full-Service Community Schools; and Congressionally Directed Spending for Elementary and Secondary Education Community Projects $6.58M
84.038 Federal Perkins Loan Program_federal Capital Contributions $1.86M
84.423 Supporting Effective Educator Development Program $1.18M
84.336 Teacher Quality Partnership Grants $1.05M
84.007 Federal Supplemental Educational Opportunity Grants $972,305
93.493 Congressional Directives $896,365
84.033 Federal Work-Study Program $741,039
84.327 Special Education Educational Technology Media, and Materials for Individuals with Disabilities $546,485
84.116 Fund for the Improvement of Postsecondary Education $514,774
93.822 Health Careers Opportunity Program (hcop) $462,124
84.042 Trio Student Support Services $453,737
84.365 English Language Acquisition State Grants $451,939
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $374,115
84.047 Trio Upward Bound $274,204
84.335 Child Care Access Means Parents in School $259,175
81.008 Cybersecurity, Energy Security & Emergency Response (ceser) $247,629
84.129 Rehabilitation Long-Term Training $183,209
43.012 Space Technology $178,393
81.087 Renewable Energy Research and Development $152,414
93.226 Research on Healthcare Costs, Quality and Outcomes $147,170
81.086 Conservation Research and Development $139,175
12.800 Air Force Defense Research Sciences Program $131,316
59.037 Small Business Development Centers $130,966
93.859 Biomedical Research and Research Training $119,039
93.865 Child Health and Human Development Extramural Research $100,538
45.313 Laura Bush 21st Century Librarian Program $92,195
12.420 Military Medical Research and Development $86,347
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $82,040
47.050 Geosciences $78,740
84.031 Higher Education Institutional Aid $70,158
93.333 Clinical Research $69,531
15.810 National Cooperative Geologic Mapping $57,580
20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research $57,447
98.001 Usaid Foreign Assistance for Programs Overseas $51,864
84.325 Special Education - Personnel Development to Improve Services and Results for Children with Disabilities $48,762
47.070 Computer and Information Science and Engineering $47,132
81.089 Fossil Energy Research and Development $45,359
81.RD Other Programs: Cfda Not Identified $44,537
93.658 Foster Care Title IV-E $39,394
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $38,518
43.001 Science $36,447
15.662 Great Lakes Restoration $33,057
15.073 Earth Mapping Resources Initiative $26,991
47.041 Engineering $25,812
93.867 Vision Research $24,411
12.750 Uniformed Services University Medical Research Projects $22,949
20.109 Air Transportation Centers of Excellence $21,801
47.049 Mathematical and Physical Sciences $20,099
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $18,669
93.732 Mental and Behavioral Health Education and Training Grants $18,662
45.162 Promotion of the Humanities Teaching and Learning Resources and Curriculum Development $13,919
47.084 Nsf Technology, Innovation, and Partnerships $12,302
93.866 Aging Research $12,001
47.076 Stem Education (formerly Education and Human Resources) $11,966
16.585 Treatment Court Discretionary Grant Program $11,568
15.657 Endangered Species Recovery Implementation $11,185
93.855 Allergy and Infectious Diseases Research $9,902
15.808 U.s. Geological Survey Research and Data Collection $9,860
15.814 National Geological and Geophysical Data Preservation $7,977
93.926 Healthy Start Initiative $7,974
21.027 Covid-19 - Coronavirus State and Local Fiscal Recovery Funds $7,362
47.075 Social, Behavioral, and Economic Sciences $5,122
43.008 Office of Stem Engagement (ostem) $4,990
93.279 Drug Use and Addiction Research Programs $4,763
93.991 Preventive Health and Health Services Block Grant $4,710
84.149 Migrant Education College Assistance Migrant Program $4,636
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $4,038
12.300 Basic and Applied Scientific Research $3,490
93.837 Cardiovascular Diseases Research $3,408
45.129 Promotion of the Humanities Federal/state Partnership $2,572
93.994 Maternal and Child Health Services Block Grant to the States $1,984
47.074 Biological Sciences $1,070
10.215 Sustainable Agriculture Research and Education $655
93.110 Maternal and Child Health Federal Consolidated Programs $311