2022-001: Cash Management Identification of the federal program: U.S. Department of Education ALN 84.425 COVID-19 Education Stabilization Fund Criteria or specific requirement: Department of Education requirements for COVID-19 Education Stabilization Fund (ESF) Programs for the cash management requirement, as summarized in the 2022 OMB Compliance Supplement stipulates that the institutional aid portion of ESF Funds (ALN 84.425F) should be disbursed within 3 calendar days of the drawdown from the G5 system. For lost revenue recovery, the "obligation" occurs on the date the institution completes its estimate of is amount of lost revenue after the estimation period. Condition: The University did not complete its final estimate of lost revenue within the required three calendar days after receiving the funds. Cause: The University had various options in order to utilize its institutional funds under HEERF III but ultimately decided on the path to use 2022 lost revenues but the draws from the G5 system predated this final decision. Effect or potential effect: The ultimate decision to use 2022 lost revenues came at the consequence of not being in full compliance with the timing rules for drawing funds. Questioned costs: None Context: The University did not complete its final estimate of lost revenue within the required three calendar days after receiving the funds, as required by the granting agency. This was a one-time event, as the University received one disbursement during FY 2022. No questioned costs were identified, as the finding relates to timing, as opposed to improper use of funds. Repeat finding: No Recommendation: We recommend management implement a process related to new government funding to understand all the various applicable compliance requirements in order to ensure grant requirements are properly met in a linear fashion and avoid situations where changes in how to meet one requirement does not inadvertently cause issues in other administrative requirements. Views of responsible officials: The University agrees with the finding. Refer to the University?s corrective action plan.
2022-002: Improper Preparation of Schedule of Expenditures of Federal Awards Identification of the federal program: U.S. Department of Education ALN 84.425 COVID-19 Education Stabilization Fund (ESF) Criteria or specific requirement: Per 2 CFR 200.510(b), the University must prepare a complete and accurate Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee?s financial statements which must include the total Federal awards expended in accordance with requirements in 2 CFR 200.502. Condition: The SEFA initially drafted and provided by the University was not complete as it did not include all ESF Institutional funds that should have been reportable for the year ended June 30, 2022. Cause: Management initially believed lost revenues were not reportable on the SEFA as they are not technically ?expenditures? in nature. Effect or potential effect: The University?s Schedule of Expenditures of Federal Awards excluded certain federal funding that were required to be reported as they did meet the Department of Education?s guidelines for reportable award expenditures. Questioned costs: None Context: The concept of lost revenues as introduced under various pandemic funding is not how federal awards are typically expended and this lead to internal confusion as to the need to report or not on the SEFA. Repeat finding: No Recommendation: We recommend management review applicable FAQ documents as to how Uniform Guidance relates to the funding received and how such funds should be reported on the SEFA, or not reported, as applicable. Views of responsible officials: The University agrees with the finding. Refer to the University?s corrective action plan.
2022-003: Earmarking Identification of the federal program: U.S. Department of Education ALN 84.425 COVID-19 Education Stabilization Fund (ESF) Criteria or specific requirement: Department of Education requirements for COVID-19 Education Stabilization Fund (ESF) Programs for the ?Matching, Level of Effort, and Earmarking? requirement, as summarized in the 2022 OMB Compliance Supplement states that the American Rescue Plan (ARP) created two specific requirements for the use of the institutional aid portion of ESF Funds (ALN 84.425F). A portion of such funds must be used (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 HEA. As noted in Question 35 of the ARP HEERF III ARP FAQs, institutions must document how the amount of the HEERF grant spent on these two required activities was reasonable and necessary given the unique needs and circumstances of the institution. Condition: The University performed activities qualifying under both (a) and (b) above; however, they did not allocate the related expenses to the ESF grant as required by the regulations. Cause: The University had previously allocated non-grant funds to the related projects, and determined that any amount allocated to the grant would not materially impact the financial statements. Effect or potential effect: There were no grant funds allocated to meet the earmarking requirement. However, since no required dollar amount or proportion to be spent on these activities was identified in the ARP guidance, it is likely the noncompliance is not material to the grant. Any expenses identified/allocated for the earmarked uses would only reduce other expenses and/or lost revenues already charged to the award. Questioned costs: None Context: Management understood the responsibilities of the University to communicate funding opportunities under the HEERF program and to reduce the spread of the virus but did not fully appreciate the guidance that such costs should be reportable to the grant before using other sources to meet the funding obligations. Repeat finding: No Recommendation: We recommend management review their process around grant requirements to ensure all requirements are met. Views of responsible officials: The University agrees with the finding. Refer to the University?s corrective action plan.
2022-001: Cash Management Identification of the federal program: U.S. Department of Education ALN 84.425 COVID-19 Education Stabilization Fund Criteria or specific requirement: Department of Education requirements for COVID-19 Education Stabilization Fund (ESF) Programs for the cash management requirement, as summarized in the 2022 OMB Compliance Supplement stipulates that the institutional aid portion of ESF Funds (ALN 84.425F) should be disbursed within 3 calendar days of the drawdown from the G5 system. For lost revenue recovery, the "obligation" occurs on the date the institution completes its estimate of is amount of lost revenue after the estimation period. Condition: The University did not complete its final estimate of lost revenue within the required three calendar days after receiving the funds. Cause: The University had various options in order to utilize its institutional funds under HEERF III but ultimately decided on the path to use 2022 lost revenues but the draws from the G5 system predated this final decision. Effect or potential effect: The ultimate decision to use 2022 lost revenues came at the consequence of not being in full compliance with the timing rules for drawing funds. Questioned costs: None Context: The University did not complete its final estimate of lost revenue within the required three calendar days after receiving the funds, as required by the granting agency. This was a one-time event, as the University received one disbursement during FY 2022. No questioned costs were identified, as the finding relates to timing, as opposed to improper use of funds. Repeat finding: No Recommendation: We recommend management implement a process related to new government funding to understand all the various applicable compliance requirements in order to ensure grant requirements are properly met in a linear fashion and avoid situations where changes in how to meet one requirement does not inadvertently cause issues in other administrative requirements. Views of responsible officials: The University agrees with the finding. Refer to the University?s corrective action plan.
2022-002: Improper Preparation of Schedule of Expenditures of Federal Awards Identification of the federal program: U.S. Department of Education ALN 84.425 COVID-19 Education Stabilization Fund (ESF) Criteria or specific requirement: Per 2 CFR 200.510(b), the University must prepare a complete and accurate Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee?s financial statements which must include the total Federal awards expended in accordance with requirements in 2 CFR 200.502. Condition: The SEFA initially drafted and provided by the University was not complete as it did not include all ESF Institutional funds that should have been reportable for the year ended June 30, 2022. Cause: Management initially believed lost revenues were not reportable on the SEFA as they are not technically ?expenditures? in nature. Effect or potential effect: The University?s Schedule of Expenditures of Federal Awards excluded certain federal funding that were required to be reported as they did meet the Department of Education?s guidelines for reportable award expenditures. Questioned costs: None Context: The concept of lost revenues as introduced under various pandemic funding is not how federal awards are typically expended and this lead to internal confusion as to the need to report or not on the SEFA. Repeat finding: No Recommendation: We recommend management review applicable FAQ documents as to how Uniform Guidance relates to the funding received and how such funds should be reported on the SEFA, or not reported, as applicable. Views of responsible officials: The University agrees with the finding. Refer to the University?s corrective action plan.
2022-003: Earmarking Identification of the federal program: U.S. Department of Education ALN 84.425 COVID-19 Education Stabilization Fund (ESF) Criteria or specific requirement: Department of Education requirements for COVID-19 Education Stabilization Fund (ESF) Programs for the ?Matching, Level of Effort, and Earmarking? requirement, as summarized in the 2022 OMB Compliance Supplement states that the American Rescue Plan (ARP) created two specific requirements for the use of the institutional aid portion of ESF Funds (ALN 84.425F). A portion of such funds must be used (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 HEA. As noted in Question 35 of the ARP HEERF III ARP FAQs, institutions must document how the amount of the HEERF grant spent on these two required activities was reasonable and necessary given the unique needs and circumstances of the institution. Condition: The University performed activities qualifying under both (a) and (b) above; however, they did not allocate the related expenses to the ESF grant as required by the regulations. Cause: The University had previously allocated non-grant funds to the related projects, and determined that any amount allocated to the grant would not materially impact the financial statements. Effect or potential effect: There were no grant funds allocated to meet the earmarking requirement. However, since no required dollar amount or proportion to be spent on these activities was identified in the ARP guidance, it is likely the noncompliance is not material to the grant. Any expenses identified/allocated for the earmarked uses would only reduce other expenses and/or lost revenues already charged to the award. Questioned costs: None Context: Management understood the responsibilities of the University to communicate funding opportunities under the HEERF program and to reduce the spread of the virus but did not fully appreciate the guidance that such costs should be reportable to the grant before using other sources to meet the funding obligations. Repeat finding: No Recommendation: We recommend management review their process around grant requirements to ensure all requirements are met. Views of responsible officials: The University agrees with the finding. Refer to the University?s corrective action plan.
2022-001: Cash Management Identification of the federal program: U.S. Department of Education ALN 84.425 COVID-19 Education Stabilization Fund Criteria or specific requirement: Department of Education requirements for COVID-19 Education Stabilization Fund (ESF) Programs for the cash management requirement, as summarized in the 2022 OMB Compliance Supplement stipulates that the institutional aid portion of ESF Funds (ALN 84.425F) should be disbursed within 3 calendar days of the drawdown from the G5 system. For lost revenue recovery, the "obligation" occurs on the date the institution completes its estimate of is amount of lost revenue after the estimation period. Condition: The University did not complete its final estimate of lost revenue within the required three calendar days after receiving the funds. Cause: The University had various options in order to utilize its institutional funds under HEERF III but ultimately decided on the path to use 2022 lost revenues but the draws from the G5 system predated this final decision. Effect or potential effect: The ultimate decision to use 2022 lost revenues came at the consequence of not being in full compliance with the timing rules for drawing funds. Questioned costs: None Context: The University did not complete its final estimate of lost revenue within the required three calendar days after receiving the funds, as required by the granting agency. This was a one-time event, as the University received one disbursement during FY 2022. No questioned costs were identified, as the finding relates to timing, as opposed to improper use of funds. Repeat finding: No Recommendation: We recommend management implement a process related to new government funding to understand all the various applicable compliance requirements in order to ensure grant requirements are properly met in a linear fashion and avoid situations where changes in how to meet one requirement does not inadvertently cause issues in other administrative requirements. Views of responsible officials: The University agrees with the finding. Refer to the University?s corrective action plan.
2022-002: Improper Preparation of Schedule of Expenditures of Federal Awards Identification of the federal program: U.S. Department of Education ALN 84.425 COVID-19 Education Stabilization Fund (ESF) Criteria or specific requirement: Per 2 CFR 200.510(b), the University must prepare a complete and accurate Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee?s financial statements which must include the total Federal awards expended in accordance with requirements in 2 CFR 200.502. Condition: The SEFA initially drafted and provided by the University was not complete as it did not include all ESF Institutional funds that should have been reportable for the year ended June 30, 2022. Cause: Management initially believed lost revenues were not reportable on the SEFA as they are not technically ?expenditures? in nature. Effect or potential effect: The University?s Schedule of Expenditures of Federal Awards excluded certain federal funding that were required to be reported as they did meet the Department of Education?s guidelines for reportable award expenditures. Questioned costs: None Context: The concept of lost revenues as introduced under various pandemic funding is not how federal awards are typically expended and this lead to internal confusion as to the need to report or not on the SEFA. Repeat finding: No Recommendation: We recommend management review applicable FAQ documents as to how Uniform Guidance relates to the funding received and how such funds should be reported on the SEFA, or not reported, as applicable. Views of responsible officials: The University agrees with the finding. Refer to the University?s corrective action plan.
2022-003: Earmarking Identification of the federal program: U.S. Department of Education ALN 84.425 COVID-19 Education Stabilization Fund (ESF) Criteria or specific requirement: Department of Education requirements for COVID-19 Education Stabilization Fund (ESF) Programs for the ?Matching, Level of Effort, and Earmarking? requirement, as summarized in the 2022 OMB Compliance Supplement states that the American Rescue Plan (ARP) created two specific requirements for the use of the institutional aid portion of ESF Funds (ALN 84.425F). A portion of such funds must be used (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 HEA. As noted in Question 35 of the ARP HEERF III ARP FAQs, institutions must document how the amount of the HEERF grant spent on these two required activities was reasonable and necessary given the unique needs and circumstances of the institution. Condition: The University performed activities qualifying under both (a) and (b) above; however, they did not allocate the related expenses to the ESF grant as required by the regulations. Cause: The University had previously allocated non-grant funds to the related projects, and determined that any amount allocated to the grant would not materially impact the financial statements. Effect or potential effect: There were no grant funds allocated to meet the earmarking requirement. However, since no required dollar amount or proportion to be spent on these activities was identified in the ARP guidance, it is likely the noncompliance is not material to the grant. Any expenses identified/allocated for the earmarked uses would only reduce other expenses and/or lost revenues already charged to the award. Questioned costs: None Context: Management understood the responsibilities of the University to communicate funding opportunities under the HEERF program and to reduce the spread of the virus but did not fully appreciate the guidance that such costs should be reportable to the grant before using other sources to meet the funding obligations. Repeat finding: No Recommendation: We recommend management review their process around grant requirements to ensure all requirements are met. Views of responsible officials: The University agrees with the finding. Refer to the University?s corrective action plan.
2022-001: Cash Management Identification of the federal program: U.S. Department of Education ALN 84.425 COVID-19 Education Stabilization Fund Criteria or specific requirement: Department of Education requirements for COVID-19 Education Stabilization Fund (ESF) Programs for the cash management requirement, as summarized in the 2022 OMB Compliance Supplement stipulates that the institutional aid portion of ESF Funds (ALN 84.425F) should be disbursed within 3 calendar days of the drawdown from the G5 system. For lost revenue recovery, the "obligation" occurs on the date the institution completes its estimate of is amount of lost revenue after the estimation period. Condition: The University did not complete its final estimate of lost revenue within the required three calendar days after receiving the funds. Cause: The University had various options in order to utilize its institutional funds under HEERF III but ultimately decided on the path to use 2022 lost revenues but the draws from the G5 system predated this final decision. Effect or potential effect: The ultimate decision to use 2022 lost revenues came at the consequence of not being in full compliance with the timing rules for drawing funds. Questioned costs: None Context: The University did not complete its final estimate of lost revenue within the required three calendar days after receiving the funds, as required by the granting agency. This was a one-time event, as the University received one disbursement during FY 2022. No questioned costs were identified, as the finding relates to timing, as opposed to improper use of funds. Repeat finding: No Recommendation: We recommend management implement a process related to new government funding to understand all the various applicable compliance requirements in order to ensure grant requirements are properly met in a linear fashion and avoid situations where changes in how to meet one requirement does not inadvertently cause issues in other administrative requirements. Views of responsible officials: The University agrees with the finding. Refer to the University?s corrective action plan.
2022-002: Improper Preparation of Schedule of Expenditures of Federal Awards Identification of the federal program: U.S. Department of Education ALN 84.425 COVID-19 Education Stabilization Fund (ESF) Criteria or specific requirement: Per 2 CFR 200.510(b), the University must prepare a complete and accurate Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee?s financial statements which must include the total Federal awards expended in accordance with requirements in 2 CFR 200.502. Condition: The SEFA initially drafted and provided by the University was not complete as it did not include all ESF Institutional funds that should have been reportable for the year ended June 30, 2022. Cause: Management initially believed lost revenues were not reportable on the SEFA as they are not technically ?expenditures? in nature. Effect or potential effect: The University?s Schedule of Expenditures of Federal Awards excluded certain federal funding that were required to be reported as they did meet the Department of Education?s guidelines for reportable award expenditures. Questioned costs: None Context: The concept of lost revenues as introduced under various pandemic funding is not how federal awards are typically expended and this lead to internal confusion as to the need to report or not on the SEFA. Repeat finding: No Recommendation: We recommend management review applicable FAQ documents as to how Uniform Guidance relates to the funding received and how such funds should be reported on the SEFA, or not reported, as applicable. Views of responsible officials: The University agrees with the finding. Refer to the University?s corrective action plan.
2022-003: Earmarking Identification of the federal program: U.S. Department of Education ALN 84.425 COVID-19 Education Stabilization Fund (ESF) Criteria or specific requirement: Department of Education requirements for COVID-19 Education Stabilization Fund (ESF) Programs for the ?Matching, Level of Effort, and Earmarking? requirement, as summarized in the 2022 OMB Compliance Supplement states that the American Rescue Plan (ARP) created two specific requirements for the use of the institutional aid portion of ESF Funds (ALN 84.425F). A portion of such funds must be used (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 HEA. As noted in Question 35 of the ARP HEERF III ARP FAQs, institutions must document how the amount of the HEERF grant spent on these two required activities was reasonable and necessary given the unique needs and circumstances of the institution. Condition: The University performed activities qualifying under both (a) and (b) above; however, they did not allocate the related expenses to the ESF grant as required by the regulations. Cause: The University had previously allocated non-grant funds to the related projects, and determined that any amount allocated to the grant would not materially impact the financial statements. Effect or potential effect: There were no grant funds allocated to meet the earmarking requirement. However, since no required dollar amount or proportion to be spent on these activities was identified in the ARP guidance, it is likely the noncompliance is not material to the grant. Any expenses identified/allocated for the earmarked uses would only reduce other expenses and/or lost revenues already charged to the award. Questioned costs: None Context: Management understood the responsibilities of the University to communicate funding opportunities under the HEERF program and to reduce the spread of the virus but did not fully appreciate the guidance that such costs should be reportable to the grant before using other sources to meet the funding obligations. Repeat finding: No Recommendation: We recommend management review their process around grant requirements to ensure all requirements are met. Views of responsible officials: The University agrees with the finding. Refer to the University?s corrective action plan.