Federal Agency: Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Numbers: 84.425F – Higher Education Emergency Relief Fund (HEERF) Institutional Portion
Federal Award Identification Number and Year: P425F201713 and P425F201723
Award Period: July 1, 2022, to June 30, 2023
Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Significant
Deficiency in Internal Controls over Compliance.
Criteria or Specific Requirement: In addition to the basic cash management principles, for
Coronavirus Relief and Response Supplemental Appropriation (CRRSAA), HEERF II and the American
Rescue Plan Act (ARP), HEERF III, the Certification, agreements and/or supplemental agreements
require that the student aid portion (ALN 84.425E) should be disbursed within 15 calendar days of the
drawdown from Education Department’s (ED) G5 grants system and Institutional Aid Portion, (a)(2),
and (a)(3) funds (all other ALNs) should be disbursed within 3 calendar days of the drawdown from G5.
For lost revenue, the “obligation” occurs on the date the institution completes its estimate of its amount
of lost revenue after the estimation period.
Condition: During fiscal year ended June 30, 2023, approximately $5,840,000 of the ARP institutional
portion was disbursed more than 3 days after the G5 cash draw receipt.
Questioned Costs: None noted.
Context: During our testing, we noted that the University was not in compliance with the ARP Cash
Management requirements.
Cause: The University had drawn down their remaining HEERF allotment near the end of FY22, as it
was expected that each campus had spent their allotment. The Aiken and Salkehatchie campuses did
not identify allowable costs before year end. The funding was held at USC until April 2023 when it was
expended, which results in non-compliance with cash management regulations.
Effect: The University pulled down funds from G5 and did not disburse them within the required days of
disbursement and therefore did not comply with the requirements.
Repeat Finding: No.
Recommendation: We recommend that the University continuously enhance its monitoring control
over administration and disbursement of HEERF money, in order to ascertain complete and accurate
compliance with cash management principles and requirements. We also recommend that the
University determines if any interest earned on these funds before expenditure should be returned to
ED.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Numbers: 84.425F – Higher Education Emergency Relief Fund (HEERF) Institutional Portion
Federal Award Identification Number and Year: P425F201713 and P425F201723
Award Period: July 1, 2022, to June 30, 2023
Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Significant
Deficiency in Internal Controls over Compliance.
Criteria or Specific Requirement: In addition to the basic cash management principles, for
Coronavirus Relief and Response Supplemental Appropriation (CRRSAA), HEERF II and the American
Rescue Plan Act (ARP), HEERF III, the Certification, agreements and/or supplemental agreements
require that the student aid portion (ALN 84.425E) should be disbursed within 15 calendar days of the
drawdown from Education Department’s (ED) G5 grants system and Institutional Aid Portion, (a)(2),
and (a)(3) funds (all other ALNs) should be disbursed within 3 calendar days of the drawdown from G5.
For lost revenue, the “obligation” occurs on the date the institution completes its estimate of its amount
of lost revenue after the estimation period.
Condition: During fiscal year ended June 30, 2023, approximately $5,840,000 of the ARP institutional
portion was disbursed more than 3 days after the G5 cash draw receipt.
Questioned Costs: None noted.
Context: During our testing, we noted that the University was not in compliance with the ARP Cash
Management requirements.
Cause: The University had drawn down their remaining HEERF allotment near the end of FY22, as it
was expected that each campus had spent their allotment. The Aiken and Salkehatchie campuses did
not identify allowable costs before year end. The funding was held at USC until April 2023 when it was
expended, which results in non-compliance with cash management regulations.
Effect: The University pulled down funds from G5 and did not disburse them within the required days of
disbursement and therefore did not comply with the requirements.
Repeat Finding: No.
Recommendation: We recommend that the University continuously enhance its monitoring control
over administration and disbursement of HEERF money, in order to ascertain complete and accurate
compliance with cash management principles and requirements. We also recommend that the
University determines if any interest earned on these funds before expenditure should be returned to
ED.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Numbers: 84.425F – Higher Education Emergency Relief Fund (HEERF)
Institutional Portion
Federal Award Identification Number and Year: P425F201713, P425F201715, P425F201717,
P425F201719, P425F201723, P425F201726, P425F201732, and P425F201737
Award Period: July 1, 2022, to June 30, 2023
Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Significant
Deficiency in Internal Controls over Compliance.
Criteria or Specific Requirement: Under section 2003(5) of the American Rescue Plan Act of 2021
(ARP) (Pub. L. 117-2) (supplemental award or grant) by the U.S. Department of Education, Recipient
must use a portion of their institutional funds received under this supplemental award to (a) to
implement evidence-based practices to monitor and suppress coronavirus in accordance with public
health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to
receive a financial aid adjustment due to the recent unemployment of a family member or independent
student, or other circumstances, described in section 479A of the Higher Education Act of 1965, as
amended (HEA) (20 USC § 1087tt).
Condition: During our testing of annual reporting for the University, we noted that there was no amount
allocated to the earmarking requirement noted above.
Questioned Costs: Unknown.
Context: During our testing, we noted that the University was not in compliance with the annual
reporting requirements.
Cause: The policies and procedures of the University did not ensure that annual reporting requirements
were accurately met.
Effect: Non-compliance with federal regulations could lead to funds being required to be returned or
refunded in order to meet the reporting requirement.
Repeat Finding: No.
Recommendation: We recommend that the University monitor the reporting requirements of all grants,
to ensure they stay in compliance.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Numbers: 84.425F – Higher Education Emergency Relief Fund (HEERF)
Institutional Portion
Federal Award Identification Number and Year: P425F201713, P425F201715, P425F201717,
P425F201719, P425F201723, P425F201726, P425F201732, and P425F201737
Award Period: July 1, 2022, to June 30, 2023
Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Significant
Deficiency in Internal Controls over Compliance.
Criteria or Specific Requirement: Under section 2003(5) of the American Rescue Plan Act of 2021
(ARP) (Pub. L. 117-2) (supplemental award or grant) by the U.S. Department of Education, Recipient
must use a portion of their institutional funds received under this supplemental award to (a) to
implement evidence-based practices to monitor and suppress coronavirus in accordance with public
health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to
receive a financial aid adjustment due to the recent unemployment of a family member or independent
student, or other circumstances, described in section 479A of the Higher Education Act of 1965, as
amended (HEA) (20 USC § 1087tt).
Condition: During our testing of annual reporting for the University, we noted that there was no amount
allocated to the earmarking requirement noted above.
Questioned Costs: Unknown.
Context: During our testing, we noted that the University was not in compliance with the annual
reporting requirements.
Cause: The policies and procedures of the University did not ensure that annual reporting requirements
were accurately met.
Effect: Non-compliance with federal regulations could lead to funds being required to be returned or
refunded in order to meet the reporting requirement.
Repeat Finding: No.
Recommendation: We recommend that the University monitor the reporting requirements of all grants,
to ensure they stay in compliance.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Numbers: 84.425F – Higher Education Emergency Relief Fund (HEERF) Institutional Portion
Federal Award Identification Number and Year: P425F201713 and P425F201723
Award Period: July 1, 2022, to June 30, 2023
Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Significant
Deficiency in Internal Controls over Compliance.
Criteria or Specific Requirement: In addition to the basic cash management principles, for
Coronavirus Relief and Response Supplemental Appropriation (CRRSAA), HEERF II and the American
Rescue Plan Act (ARP), HEERF III, the Certification, agreements and/or supplemental agreements
require that the student aid portion (ALN 84.425E) should be disbursed within 15 calendar days of the
drawdown from Education Department’s (ED) G5 grants system and Institutional Aid Portion, (a)(2),
and (a)(3) funds (all other ALNs) should be disbursed within 3 calendar days of the drawdown from G5.
For lost revenue, the “obligation” occurs on the date the institution completes its estimate of its amount
of lost revenue after the estimation period.
Condition: During fiscal year ended June 30, 2023, approximately $5,840,000 of the ARP institutional
portion was disbursed more than 3 days after the G5 cash draw receipt.
Questioned Costs: None noted.
Context: During our testing, we noted that the University was not in compliance with the ARP Cash
Management requirements.
Cause: The University had drawn down their remaining HEERF allotment near the end of FY22, as it
was expected that each campus had spent their allotment. The Aiken and Salkehatchie campuses did
not identify allowable costs before year end. The funding was held at USC until April 2023 when it was
expended, which results in non-compliance with cash management regulations.
Effect: The University pulled down funds from G5 and did not disburse them within the required days of
disbursement and therefore did not comply with the requirements.
Repeat Finding: No.
Recommendation: We recommend that the University continuously enhance its monitoring control
over administration and disbursement of HEERF money, in order to ascertain complete and accurate
compliance with cash management principles and requirements. We also recommend that the
University determines if any interest earned on these funds before expenditure should be returned to
ED.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Numbers: 84.425F – Higher Education Emergency Relief Fund (HEERF) Institutional Portion
Federal Award Identification Number and Year: P425F201713 and P425F201723
Award Period: July 1, 2022, to June 30, 2023
Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Significant
Deficiency in Internal Controls over Compliance.
Criteria or Specific Requirement: In addition to the basic cash management principles, for
Coronavirus Relief and Response Supplemental Appropriation (CRRSAA), HEERF II and the American
Rescue Plan Act (ARP), HEERF III, the Certification, agreements and/or supplemental agreements
require that the student aid portion (ALN 84.425E) should be disbursed within 15 calendar days of the
drawdown from Education Department’s (ED) G5 grants system and Institutional Aid Portion, (a)(2),
and (a)(3) funds (all other ALNs) should be disbursed within 3 calendar days of the drawdown from G5.
For lost revenue, the “obligation” occurs on the date the institution completes its estimate of its amount
of lost revenue after the estimation period.
Condition: During fiscal year ended June 30, 2023, approximately $5,840,000 of the ARP institutional
portion was disbursed more than 3 days after the G5 cash draw receipt.
Questioned Costs: None noted.
Context: During our testing, we noted that the University was not in compliance with the ARP Cash
Management requirements.
Cause: The University had drawn down their remaining HEERF allotment near the end of FY22, as it
was expected that each campus had spent their allotment. The Aiken and Salkehatchie campuses did
not identify allowable costs before year end. The funding was held at USC until April 2023 when it was
expended, which results in non-compliance with cash management regulations.
Effect: The University pulled down funds from G5 and did not disburse them within the required days of
disbursement and therefore did not comply with the requirements.
Repeat Finding: No.
Recommendation: We recommend that the University continuously enhance its monitoring control
over administration and disbursement of HEERF money, in order to ascertain complete and accurate
compliance with cash management principles and requirements. We also recommend that the
University determines if any interest earned on these funds before expenditure should be returned to
ED.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Numbers: 84.425F – Higher Education Emergency Relief Fund (HEERF)
Institutional Portion
Federal Award Identification Number and Year: P425F201713, P425F201715, P425F201717,
P425F201719, P425F201723, P425F201726, P425F201732, and P425F201737
Award Period: July 1, 2022, to June 30, 2023
Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Significant
Deficiency in Internal Controls over Compliance.
Criteria or Specific Requirement: Under section 2003(5) of the American Rescue Plan Act of 2021
(ARP) (Pub. L. 117-2) (supplemental award or grant) by the U.S. Department of Education, Recipient
must use a portion of their institutional funds received under this supplemental award to (a) to
implement evidence-based practices to monitor and suppress coronavirus in accordance with public
health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to
receive a financial aid adjustment due to the recent unemployment of a family member or independent
student, or other circumstances, described in section 479A of the Higher Education Act of 1965, as
amended (HEA) (20 USC § 1087tt).
Condition: During our testing of annual reporting for the University, we noted that there was no amount
allocated to the earmarking requirement noted above.
Questioned Costs: Unknown.
Context: During our testing, we noted that the University was not in compliance with the annual
reporting requirements.
Cause: The policies and procedures of the University did not ensure that annual reporting requirements
were accurately met.
Effect: Non-compliance with federal regulations could lead to funds being required to be returned or
refunded in order to meet the reporting requirement.
Repeat Finding: No.
Recommendation: We recommend that the University monitor the reporting requirements of all grants,
to ensure they stay in compliance.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education
Federal Program Title: Education Stabilization Fund
Assistance Listing Numbers: 84.425F – Higher Education Emergency Relief Fund (HEERF)
Institutional Portion
Federal Award Identification Number and Year: P425F201713, P425F201715, P425F201717,
P425F201719, P425F201723, P425F201726, P425F201732, and P425F201737
Award Period: July 1, 2022, to June 30, 2023
Type of Finding: Other Matters Finding related to Compliance within Uniform Guidance and Significant
Deficiency in Internal Controls over Compliance.
Criteria or Specific Requirement: Under section 2003(5) of the American Rescue Plan Act of 2021
(ARP) (Pub. L. 117-2) (supplemental award or grant) by the U.S. Department of Education, Recipient
must use a portion of their institutional funds received under this supplemental award to (a) to
implement evidence-based practices to monitor and suppress coronavirus in accordance with public
health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to
receive a financial aid adjustment due to the recent unemployment of a family member or independent
student, or other circumstances, described in section 479A of the Higher Education Act of 1965, as
amended (HEA) (20 USC § 1087tt).
Condition: During our testing of annual reporting for the University, we noted that there was no amount
allocated to the earmarking requirement noted above.
Questioned Costs: Unknown.
Context: During our testing, we noted that the University was not in compliance with the annual
reporting requirements.
Cause: The policies and procedures of the University did not ensure that annual reporting requirements
were accurately met.
Effect: Non-compliance with federal regulations could lead to funds being required to be returned or
refunded in order to meet the reporting requirement.
Repeat Finding: No.
Recommendation: We recommend that the University monitor the reporting requirements of all grants,
to ensure they stay in compliance.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the
audit finding. Management has addressed their corrective action plan in a separately issued letter.