Finding Text
Federal Agency: U.S. Department of Education
Assistance Listing Number: 84.063, 84.268, 84.007, 84.379
Program Expenditures: $39,082,749
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, P268K221391, P268K231391,
P007A231313, P379T221391, and P379T231391
Questioned Costs: None
Western Illinois University (University) did not have adequate procedures in place to complete 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 6 out of 25 (24%) students
return of title IV funds were not processed within the 45 day window, ranging from 2-12 days late. The
sample was not a statistically valid sample.
A school participating in Title IV aid programs must establish and maintain proper administrative and fiscal
procedures and initiate returns within 45 days after the determined date of withdrawal (34 CFR 668.173(b)).
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.
University management indicated staffing shortages during the 2022-2023 aid year caused this to occur.
Without sufficient controls in place to return title IV funds there is a greater risk that the school does not
return funds timely or that students may not receive post-withdrawal disbursements timely. (Finding Code
No. 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. We also recommend these controls be
monitored to ensure that all necessary refunds are completed within the required time frame.
UNIVERSITY RESPONSE
The University agrees with the finding. Additional procedures have been put in place and additional staffing
efforts will be allocated to ensure timing requirements are met as it relates to Title IV funds.