REPORT DIGEST

WESTERN ILLINOIS UNIVERSITY

COMPLIANCE EXAMINATION AND SINGLE AUDIT
FOR THE YEAR ENDED JUNE 30, 2020

Release Date:  June 29, 2021

FINDINGS THIS AUDIT:  11

CATEGORY:  NEW -- REPEAT -- TOTAL
Category 1:  1 -- 0 -- 1
Category 2:  4 -- 6 -- 10
Category 3:  0 -- 0 -- 0
TOTAL:  5 -- 6 -- 11

FINDINGS LAST AUDIT: 8

Category 1: Findings that are material
weaknesses in internal control and/or a
qualification on compliance with State
laws and regulations (material
noncompliance).
Category 2: Findings that are significant
deficiencies in internal control and
noncompliance with State laws and
regulations.
Category 3: Findings that have no
internal control issues but are in
noncompliance with State laws and
regulations.

State of Illinois, Office of the Auditor
General
FRANK J. MAUTINO, AUDITOR GENERAL

To obtain a copy of the Report contact:
Office of the Auditor General, Iles Park
Plaza, 740 E. Ash Street, Springfield, IL
62703
(217) 782-6046 or TTY (888) 261-2887

This Report Digest and Full Report are
also available on the worldwide web at
www.auditor.illinois.gov

SYNOPSIS
INTRODUCTION

This digest covers our single audit and
compliance examination of Western
Illinois University (University) for the
year ended June 30, 2020. A separate
financial audit as of and for the year
ending June 30, 2020 was previously
released on June 16, 2021. In total, this
report contains 11 findings, one of which
was reported in the financial audit.

SYNOPSIS

• (20-02) The University did not document
the Gramm-Leach-Bliley Act (GLBA)
required risk assessments related to
student information security.
• (20-03) The University disbursed the
Higher Education Emergency Relief Fund to
non-eligible students and inconsistently
applied the University’s approved methods
of determining and distribution of funds
to students.

FINDINGS, CONCLUSIONS, AND
RECOMMENDATIONS

INFORMATION TECHNOLOGY RISK ASSESSMENT
NOT PERFORMED

Western Illinois University (University)
did not document the Gramm-Leach-Bliley
Act (GLBA) required risk assessments
related to student information security.

As a requirement under the University’s
Program Participation Agreement with the
Department of Education, the University
must protect student financial aid
information. During our testing, we noted
they had not conducted a risk assessment
identifying internal and external risks
to the security, confidentiality, and
integrity of the students’ information.
(Finding 2, pages 25-27)

We recommended the University perform and
document a comprehensive risk assessment
that specifically addresses the
requirements of GLBA related to the
security, confidentiality, and integrity
of student information.

The University agreed with the finding
and stated they will perform and document
a comprehensive risk assessment that
specifically addresses the requirements
of GLBA related to the security,
confidentiality, and integrity of student
information.

INACCURATE CALCULATION AND DISBURSEMENT
OF HIGHER EDUCATION EMERGENCY RELIEF FUND
(HEERF)

Western Illinois University (University)
disbursed the HEERF to non-eligible
students and inconsistently applied the
University’s approved methods of
determining and distribution of funds to
students.

During our testing of HEERF Student Aid
Portion of the emergency aid grant
disbursement for 60 students, a
statistically valid sample, we noted the
following:

• Two of 60 (3%) students enrolled in an
online program received $2,875.

The question cost was determined by
obtaining the summary of students
enrolled in online programs for the
fiscal year 2020 spring and summer
semesters. The list was matched to
students awarded with HEERF grants for
the same period. We noted 88 students
enrolled in online program were awarded
HEERF grants. The University charged
$56,409 to the grant and recognized
revenue for the same amount. If the
amount is not recovered from the
students, the University will have
incurred unnecessary expenses for the
same amount resulting in a total
financial loss to the University of
$112,818.

• One of 60 (2%) students with a total
score of more than 1 was awarded $500
instead of the computed $2,500 based on
the distribution plan.

To determine the underpayment, we
obtained the summary per the distribution
plan for the fiscal year 2020 spring and
summer semesters. This summary is the
manual calculation of HEERF grants to be
awarded to eligible students. We matched
the calculated amount against HEERF
grants disbursed to students by billing
and receivable for the same period. We
noted 63 students were underpaid by
$56,566. (Finding 3, pages 28-30)

We recommended the University implement
controls to ensure proper determination
of eligibility and accuracy in the
distribution of HEERF student aid.

The University agrees with the finding
and stated the Financial Aid office will
review and modify its controls related to
HEERF to ensure accuracy in awarding
HEERF student aid.

OTHER FINDINGS

The remaining findings pertain to
noncompliance with statutory
requirements, subsidies between
accounting entities, internal audit,
computer inventory controls, controls
over external service providers and
segregation of duties over programmer
access to production.  We will review the
University’s progress towards the
implementation of our recommendations in
our next Single Audit and compliance
examination.

AUDITOR’S OPINIONS

The financial audit report was previously
released. The auditors stated the
financial statements of the University as
of and for the year ended June 30, 2020,
are fairly stated in all material
respects.

The auditors also conducted a Single
Audit of the University as required by
the Uniform Guidance.  The auditors
stated the University complied, in all
material respects, with the types of
compliance requirements that could have a
direct and material effect on the
University’s major federal programs for
the year ended June 30, 2020.

ACCOUNTANT’S OPINION

The accountants conducted a compliance
examination of the University for the
year ended June 30, 2020, as required by
the Illinois State Auditing Act.  The
accountants stated the University
complied, in all material respects, with
the requirements described in the report.

This Single Audit and compliance
examination was conducted by Adelfia LLC.

JANE CLARK
Division Director

This report is transmitted in accordance
with Section 3-14 of the Illinois State
Auditing Act.

FRANK J. MAUTINO
Auditor General

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