FAC Explorer

Finding 625967 (2022-005)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-03-29
Audit: 47967
Organization: Western Michigan University (MI)
Auditor: Plante & Moran PLLC

AI Summary

  • Core Issue: The University incorrectly reported student withdrawals related to COVID-19 in the COD System, violating CARES Act requirements.
  • Impacted Requirements: Compliance with Section 3508 of the CARES Act, specifically regarding the accurate reporting of Title IV funds and student withdrawal statuses.
  • Recommended Follow-Up: Implement stronger controls to ensure accurate reporting of COVID-19-related withdrawals and discontinue automatic COVID indicator usage.

Finding Text

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - Section 3508 of the CARES Act waives Return of Title IV Funds (R2T4) requirements for students whose withdrawals were related to the novel coronavirus disease (COVID 19). The CARES Act requires institutions to report to the Department of Education (ED) information specific to each student for whom it was not required to return Title IV funds under the waiver exception (and for each student for which Title IV funds were previously returned and are now being redrawn). The law also requires institutions to report to ED the total amount of Title IV grant or loan assistance that was not returned as a result of the CARES Act provisions. To implement this CARES Act relief for each student who withdraws as a result of the COVID 19 national emergency, ED requires the institution to use the Coronavirus Indicator checkbox in the COD System to indicate that an aid recipient?s actual disbursement(s) qualifies for Direct Loan cancellation (and the exclusion from the Direct Loan annual limits and Subsidized Loan usage calculations), or the exclusion from Pell Grant Lifetime Eligibility Used calculations and TEACH Grant award limits. Condition - The University improperly reported the students that withdrew within the COD System as a result of the COVID 19 national emergency. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, there were 3 students who completed more than 60 percent of the Spring 2022 semester and were incorrectly reported as withdrawing due to the COVID 19 national emergency within the COD System. In addition, there was 1 student who did withdraw due to the COVID 19 national emergency but was not properly reported as such in the COD System. Cause and Effect - The University had established a policy to record all students withdrawing past the 60 percent completion date from the Spring 2022 semester as a COVID 19 withdrawal; however, certain students withdrawing beyond this date did not have proper documentation to support a COVID 19 withdrawal. The University did not have controls in place to ensure proper reporting in accordance with the compliance requirement. Recommendation - The University should implement controls to ensure proper reporting of withdraws due to the COVID 19 national emergency within the COD System. Views of Responsible Officials and Planned Corrective Actions - The Student Financial Aid (SFA) office agrees with the finding that certain withdrawn students were improperly reported in COD because of the COVID-19 national emergency. SFA evaluated its R2T4 procedures and strengthened its internal controls by discontinuing the practice of automatically adding the COVID indicator to students who withdrew.

Categories

Student Financial Aid Eligibility Reporting Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 49519 2022-002
    Material Weakness Repeat
  • 49520 2022-003
    Material Weakness Repeat
  • 49521 2022-005
    Significant Deficiency
  • 49522 2022-001
    Significant Deficiency
  • 49523 2022-002
    Material Weakness Repeat
  • 49524 2022-003
    Material Weakness Repeat
  • 49525 2022-005
    Significant Deficiency
  • 49526 2022-001
    Significant Deficiency
  • 49527 2022-002
    Material Weakness Repeat
  • 49528 2022-003
    Material Weakness Repeat
  • 49529 2022-005
    Significant Deficiency
  • 49530 2022-004
    Material Weakness
  • 49531 2022-004
    Material Weakness
  • 625961 2022-002
    Material Weakness Repeat
  • 625962 2022-003
    Material Weakness Repeat
  • 625963 2022-005
    Significant Deficiency
  • 625964 2022-001
    Significant Deficiency
  • 625965 2022-002
    Material Weakness Repeat
  • 625966 2022-003
    Material Weakness Repeat
  • 625968 2022-001
    Significant Deficiency
  • 625969 2022-002
    Material Weakness Repeat
  • 625970 2022-003
    Material Weakness Repeat
  • 625971 2022-005
    Significant Deficiency
  • 625972 2022-004
    Material Weakness
  • 625973 2022-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $95.95M
84.063 Federal Pell Grant Program $18.37M
84.038 Federal Perkins Loan Program $4.16M
59.075 Covid-19 - Shuttered Venue Operators Grant Program $2.86M
84.423 Supporting Effective Educator Development Program $1.55M
84.007 Federal Supplemental Educational Opportunity Grants $1.16M
84.365 English Language Acquisition State Grants $669,901
84.336 Teacher Quality Partnership Grants $639,880
84.033 Federal Work-Study Program $612,467
84.327 Special Education_educational Technology Media, and Materials for Individuals with Disabilities $558,371
84.425 Covid-19 - Education Stabilization Fund $415,350
93.732 Mental and Behavioral Health Education and Training Grants $352,647
84.042 Trio_student Support Services $339,205
84.149 Migrant Education_college Assistance Migrant Program $300,419
84.335 Child Care Access Means Parents in School $239,484
84.325 Special Education - Personnel Development to Improve Services and Results for Children with Disabilities $193,477
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $180,845
84.129 Rehabilitation Long-Term Training $161,088
43.001 Science $150,850
84.215 Fund for the Improvement of Education $146,617
93.865 Child Health and Human Development Extramural Research $142,938
59.037 Small Business Development Centers $137,262
93.859 Biomedical Research and Research Training $134,165
12.420 Military Medical Research and Development $133,131
93.867 Vision Research $128,281
12.800 Air Force Defense Research Sciences Program $106,788
81.087 Renewable Energy Research and Development $96,403
20.109 Air Transportation Centers of Excellence $91,299
93.173 Research Related to Deafness and Communication Disorders $83,991
81.086 Conservation Research and Development $83,142
43.012 Space Technology $76,473
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $72,106
93.136 Injury Prevention and Control Research and State and Community Based Programs $65,133
84.031 Higher Education_institutional Aid $63,449
93.855 Allergy, Immunology and Transplantation Research $62,387
45.163 Promotion of the Humanities_professional Development $61,886
47.070 Computer and Information Science and Engineering $60,454
81.089 Fossil Energy Research and Development $47,926
15.814 National Geological and Geophysical Data Preservation Program $34,627
81.049 Office of Science Financial Assistance Program $34,476
98.001 Usaid Foreign Assistance for Programs Overseas $34,203
12.750 Uniformed Services University Medical Research Projects $33,824
93.279 Drug Abuse and Addiction Research Programs $31,058
47.050 Geosciences $27,498
93.110 Maternal and Child Health Federal Consolidated Programs $26,015
47.049 Mathematical and Physical Sciences $24,982
11.417 Sea Grant Support $24,894
10.572 Wic Farmers' Market Nutrition Program (fmnp) $23,560
47.076 Education and Human Resources $19,773
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $19,596
12.910 Research and Technology Development $19,321
47.041 Engineering $14,568
93.107 Area Health Education Centers Point of Service Maintenance and Enhancement Awards $14,450
20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research $14,134
93.994 Maternal and Child Health Services Block Grant to the States $13,218
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $11,838
45.130 Promotion of the Humanities_challenge Grants $11,634
15.808 U.s. Geological Survey_ Research and Data Collection $10,515
84.047 Trio_upward Bound $10,161
93.926 Healthy Start Initiative $10,082
45.129 Promotion of the Humanities_federal/state Partnership $7,335
15.810 National Cooperative Geologic Mapping Program $7,127
84.305 Education Research, Development and Dissemination $6,228
47.074 Biological Sciences $5,742
81.GSA_MIGRATION U.s. Department of Energy $5,373
43.008 Education $4,954
15.657 Endangered Species Conservation ? Recovery Implementation Funds $4,944
16.585 Drug Court Discretionary Grant Program $1,368
47.075 Social, Behavioral, and Economic Sciences $189
84.016 Undergraduate International Studies and Foreign Language Programs $-20,447