Eastern Illinois University

Eastern Illinois University (University) did not comply with a reporting requirement applicable to Higher Education Emergency Relief Fund (HEERF) grantees. During our review of the University?s compliance with HEERF program reporting requirements, we noted the University failed to post certain information on its website within the required timeframe for one of four (25%) required quarterly reports. Specifically, the University posted the required information for the report quarter ending December 31, 2020, 26 days late. We consider this condition to be an instance of noncompliance relating to the Reporting compliance requirement. On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was enacted into Public Law 116-136. Section 18004(a)(1) of the CARES Act established the HEERF program which authorizes the Secretary of Education to allocate funding to eligible institutions of higher education to prevent, prepare for, and respond to COVID-19. A University receiving Institutional funds under Section 18004 of the CARES Act must publicly post seven required reporting items on its website no later than thirty days after award, and update that information every forty-five days thereafter. On August 31, 2020, the Department of Education revised the frequency of reporting after the initial thirty-day period from every forty-five days thereafter to ten days after the end of every calendar quarter. University management stated they believed the extension of the annual report also applied to the quarterly report. Failure to comply with grant reporting requirements of the HEERF program results in noncompliance with the CARES Act. (Finding Code No. 2021-002) RECOMMENDATION: We recommend the University comply with all reporting requirements applicable to Higher Education Emergency Relief Fund (HEERF) grantees. UNIVERSITY RESPONSE: The University agrees with the recommendation. The University misunderstood the difference between the extended annual reporting requirement and the quarterly reporting requirement. Both the annual reporting requirement for calendar 2020 and the quarterly reporting requirement for December, 2020, were met on February 8, 2021, the extended due date of the annual report. All other reporting requirements were met on a timely basis.

Eastern Illinois University (University) did not review federal work study (FWS) hours worked against class hours scheduled and timesheets to ensure students were not working during a scheduled class and that they were paid for the correct number of hours. During testing, auditors noted two of 37 (5%) individuals tested worked during scheduled class hours. We consider this condition to be an instance of noncompliance relating to the Activities Allowed or Unallowed compliance requirement. Our sample selection was not, and was not intended to be, statistically valid. The Code of Federal Regulations (34 CFR 675.19 (b)(2)) requires the institution to establish and maintain program and fiscal records that include a certification by the student?s supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day and include a payroll voucher containing sufficient information to support all payroll disbursements. The Code of Federal Regulations (Code) (34 CFR 675.20 (d)(1)) states a student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is enrolled in an internship; enrolled in practicum; or employed in a research, teaching, or other assistantship. Further, the Code (34 CFR 675.20 (d)(2)) states a student employed in a FWS job and receiving academic credit for that job may not be paid for receiving instruction in a classroom, laboratory, or other academic setting. The 2019-2020 Federal Student Aid Handbook, Volume 6, Chapter 2, page 6-46 states in general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented. University officials indicated the exceptions noted were due to lack of documentation by supervisors and reviewers. Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations. (Finding Code No. 2020-002, 2019-002) RECOMMENDATION We recommend the University properly review federal work study hours to ensure none are worked during scheduled class hours. UNIVERSITY RESPONSE The University agrees with the auditor?s recommendation. We have new reports in place to verify hours worked against student class schedules. Student hours worked during regularly scheduled classes will be noted and explanations provided timely by the student or supervisor. Hours worked during regularly scheduled class times without proper explanation will be paid with non-Federal funds.

Eastern Illinois University?s (University) Fiscal Operations Report and Application to Participate (FISAP) records maintained did not agree to the actual amounts reported. During testing, we noted two instances for which the FISAP did not reflect the correct amount per the University?s records. The amount reported on the FISAP was $213,153 greater than the amount in the University?s records. We consider this condition to be an instance of noncompliance relating to the Reporting compliance requirement. The Code of Federal Regulations (Code) (34 CFR 668.24 (e)(1)(i)) requires institutions to keep records relating to its administration of the Federal Perkins Loan, Federal Work Study (FWS), Federal Supplemental Educational Opportunity Grant (FSEOG), Federal Pell Grant, Academic Competitiveness Grant (ACG), National SMART Grant, or Teacher Assistance for College and Higher Education (TEACH) Grant programs for three years after the end of the award year for which the aid was awarded and disbursed under those programs. The Code also requires institution to keep its Fiscal Operations Report and Application to Participate in the Federal Perkins Loan, FSEOG, and FWS Programs (FISAP), and any records necessary to support the data contained in the FISAP, including ?income grid information? for three years after the end of the award year in which the FISAP is submitted. University officials indicated the issues noted were due to human error. Reporting errors on the FISAP could affect the amount of future campus based aid awarded to the University. (Finding Code No. 2020-003) RECOMMENDATION We recommend the University improve controls to ensure the information reported on the FISAP is accurate. UNIVERSITY RESPONSE The University agrees with the auditor?s recommendation. The University will ensure that the FISAP data entry is independently reviewed prior to submission. This error was corrected with the FISAP filed with the U.S. Department of Education.

Eastern Illinois University (University) did not properly conduct exit counseling. During our testing of students who have had federal direct loans, we determined one (3%) of 40 students tested did not complete the required exit counseling. We consider this condition to be an instance of noncompliance relating to the Special Tests and Provisions compliance requirement. Our sample selection was not, and was not intended to be, statistically valid. The Code of Federal Regulations (34 CFR 685.304 (b)) requires a school to ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. University officials stated the required exit counseling did not occur due to oversight. Not conducting exit counseling properly could result in students being uninformed about the responsibilities and consequences of borrowing federal funds. (Finding Code No. 2020- 004) RECOMMENDATION We recommend the University improve internal controls to ensure all students complete the required exit counseling within 30 days. UNIVERSITY RESPONSE The University agrees with the auditor?s recommendation. The University currently notifies the student of the need for exit counseling through the student?s campus email account. We have added a second step to our exit counseling notification by mailing or emailing a student when counseling is not completed within thirty days. The notification will be sent to the students off campus address.

Eastern Illinois University (University) did not disburse a direct loan properly. During testing, we noted Title IV funds were not properly awarded and disbursed for one (3%) of 40 students tested. One student was under awarded an unsubsidized direct loan in the amount of $2,000. We consider this condition to be an instance of noncompliance with the eligibility compliance requirements. Statistical sampling was not used in making sample selections. The Code of Federal Regulations (34 CFR 685.201 (a) (2)) requires, if the student is eligible for a Direct Subsidized Loan or a Direct Unsubsidized Loan, the school in which the student is enrolled must perform the following functions: 1) create a loan origination record and transmit the record to the Secretary, 2) ensure that the loan is supported by a completed Master Promissory Note (MPN) and, if applicable, transmit the MPN to the Secretary, 3) draw down funds or receive funds from the Secretary, and 4) disburse the funds to the student. University officials indicated the issue noted was due to ongoing changes in and reviews of student data. Improper distribution of loans results in students receiving incorrect subsidized and unsubsidized amounts. (Finding Code No. 2020-005) RECOMMENDATION We recommend the University improve internal controls to ensure the loans are being disbursed accurately. UNIVERSITY RESPONSE The University agrees with the auditor?s recommendation. We went through a number of recalculations regarding this student due to incorrect information within the system. Once the data was determined to be accurate, we attempted to communicate with the student to inform them of their ability to receive an unsubsidized loan. However, the student never replied to our communication and ended up getting a private loan to cover their balance due without further discussion with us. The University will establish a process to ensure that Federal loans are fully processed before adding private loans.

Eastern Illinois University (University) did not timely and accurately submit enrollment status information. During testing, auditors noted three of 20 (15%) graduate student enrollment status changes for students tested were not reported to the National Student Loan Data System (NSLDS). Our sample selection was not, and was not intended to be, statistically valid. The Code of Federal Regulations (34 CFR 690.83(b)(2)) requires the University to submit, in accordance with deadline dates established by the Secretary, other reports and information the Secretary requires and comply with the procedures the Secretary finds necessary to ensure that the reports are correct. The Code of Federal Regulations (34 CFR 685.309(b)) requires enrollment status changes for students to be reported to the NSLDS within 30 days, or within 60 days, if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. In addition, the financial aid handbook states if a student?s enrollment status falls under part time or the student withdraws, the school must notify the NSLDS within 30 days of the enrollment change. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to 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 enrollment reporting is timely completed. University officials stated the University did not follow up on error reports generated by the National Student Clearinghouse, which feeds information to the NSLDS. The University has not timely and accurately submitted enrollment status information, which has the potential to delay the start of the repayment period for students who have received loans. (Finding Code No. 2019-001) RECOMMENDATION We recommend the University review exception reports prepared by the NSLDS and correct student information as necessary. UNIVERSITY RESPONSE The University agrees with the auditor?s recommendation. When the University realized the error reports from the National Student Clearinghouse were not being reviewed and the corrections made in a timely manner, the University began doing so.

Eastern Illinois University (University) did not review federal work study (FWS) hours worked against class hours scheduled and timesheets to ensure students were not working during a scheduled class and that they were paid for the correct number of hours. During testing, auditors noted the following: ? Four of 37 (11%) individuals tested participating in the federal work study program did not reflect the correct number of hours worked or had incomplete documentation of the hours worked in their timesheets, resulting in both overpayments and underpayments to the individuals. Documentation showed differences between the hours paid and hours worked ranged from an underpayment totaling one hour to 20 hours overpaid. ? Three of 37 (8%) individuals tested worked during scheduled class hours. Our sample selection was not, and was not intended to be, statistically valid. The Code of Federal Regulations (34 CFR 675.19 (b)(2)) requires the institution to establish and maintain program and fiscal records that include a certification by the student?s supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day and include a payroll voucher containing sufficient information to support all payroll disbursements. The Code of Federal Regulations (Code) (34 CFR 675.20 (d)(1)) states a student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is enrolled in an internship; enrolled in practicum; or employed in a research, teaching, or other assistantship. Further, the Code (34 CFR 675.20 (d)(2)) states a student employed in a FWS job and receiving academic credit for that job may not be paid for receiving instruction in a classroom, laboratory, or other academic setting. The 2018-2019 Federal Student Aid Handbook, Volume 6, Chapter 2, page 6-43 states in general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented. University officials stated the issues noted above were due to oversight. Without proper review of hours worked against class hours scheduled and timesheets, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations. (Finding Code No. 2019-002) RECOMMENDATION We recommend the University properly review federal work study hours to ensure none are worked during scheduled class hours and actual hours reported on timesheets are accurate. UNIVERSITY RESPONSE The University agrees with the auditor?s recommendation. The University has implemented a procedure requiring all departments verify student class schedules before authorizing time worked each pay period. All authorized time sheets will be sent to the federal work study administrator for verification and file maintenance. The University corrected student overpayments by reimbursing FWS monies from University funds. Student underpayments were corrected with University funds and the students were made whole.

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