Finding 2022-002: HEERF Student Aid Quarterly Public Reporting Federal Agency: Department of Education Program: Higher Education Emergency Relief Fund (?HEERF?), 84.425Q Criteria or Specific Requirement: Under 2 CFR Part 200, Appendix XI section 4.84.425-ESF, there are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Effective May 13, 2021, student aid public reporting under Coronavirus Response and Relief Supplemental Appropriations Act (?CRRSAA?) and American Rescue Plan (?ARP?) requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). The following are identified as critical information for the Quarterly Public Reporting for Student Aid Portion: Item #3: The total amount of Emergency Financial Aid Grants distributed to students under the Coronavirus Aid, Relief, and Economic Security Act (?CARES?) (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms as of the date of submission (i.e., as of the initial report and every calendar quarter thereafter). Item #4: The estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Item #5: The total number of students who have received an Emergency Financial Aid Grant to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Item #6: The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Condition/Context: During our audit testing over HEERF Student Aid Quarterly Public Reporting, we determined that the University did not provide the required level of detail to meet the reporting requirements for Item #6 above for the quarter ended December 31, 2021. On January 5, 2022, the University provided a quarterly student aid public update on its website to disclose the awarding of student grants under CRRSAA and ARP. While the University did state grants were awarded to enrolled students with priority given to those with exceptional need, the specific method used by the University to determine which students would receive the Emergency Financial Aid Grants and the amount each student would receive were not disclosed. Identification as a repeat finding, if applicable: This is not a repeat finding. Cause: The University?s interpretation of the level of detail required for Item #6 differed from what was required. Effect: The University was not in compliance with HEERF student aid quarterly public reporting requirements. Questioned Costs: None Recommendation: The University should revise its January 5, 2022, HEERF student aid quarterly public reporting for the quarter ending December 31, 2021, to provide the level of detail as required for Item #6. Views of Responsible Officials: The January 5, 2022 quarterly student aid public update posted by Bob Jones University provided general information regarding the Emergency Financial Aid Grants awarded under CRRSAA and ARP. It did not include detailed information regarding the method used to determine the awards or the amount awarded to each student. The University plans to update its website posting to meet the level of detail that is required for Item #6.
Finding 2022-002: HEERF Student Aid Quarterly Public Reporting Federal Agency: Department of Education Program: Higher Education Emergency Relief Fund (?HEERF?), 84.425Q Criteria or Specific Requirement: Under 2 CFR Part 200, Appendix XI section 4.84.425-ESF, there are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Effective May 13, 2021, student aid public reporting under Coronavirus Response and Relief Supplemental Appropriations Act (?CRRSAA?) and American Rescue Plan (?ARP?) requires that institutions publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30). The following are identified as critical information for the Quarterly Public Reporting for Student Aid Portion: Item #3: The total amount of Emergency Financial Aid Grants distributed to students under the Coronavirus Aid, Relief, and Economic Security Act (?CARES?) (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms as of the date of submission (i.e., as of the initial report and every calendar quarter thereafter). Item #4: The estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Item #5: The total number of students who have received an Emergency Financial Aid Grant to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Item #6: The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Condition/Context: During our audit testing over HEERF Student Aid Quarterly Public Reporting, we determined that the University did not provide the required level of detail to meet the reporting requirements for Item #6 above for the quarter ended December 31, 2021. On January 5, 2022, the University provided a quarterly student aid public update on its website to disclose the awarding of student grants under CRRSAA and ARP. While the University did state grants were awarded to enrolled students with priority given to those with exceptional need, the specific method used by the University to determine which students would receive the Emergency Financial Aid Grants and the amount each student would receive were not disclosed. Identification as a repeat finding, if applicable: This is not a repeat finding. Cause: The University?s interpretation of the level of detail required for Item #6 differed from what was required. Effect: The University was not in compliance with HEERF student aid quarterly public reporting requirements. Questioned Costs: None Recommendation: The University should revise its January 5, 2022, HEERF student aid quarterly public reporting for the quarter ending December 31, 2021, to provide the level of detail as required for Item #6. Views of Responsible Officials: The January 5, 2022 quarterly student aid public update posted by Bob Jones University provided general information regarding the Emergency Financial Aid Grants awarded under CRRSAA and ARP. It did not include detailed information regarding the method used to determine the awards or the amount awarded to each student. The University plans to update its website posting to meet the level of detail that is required for Item #6.