Finding Number: 2022-001 Federal Agency: United States Department of Education Pass-through Agency: Direct Program Name: Education Stabilization Fund (HEERF) ? Student Aid Portion Assistance Listing Number: 84.425E Federal Award Numbers: P425E200967-20A P425E200967-20B Federal Award Year: July 1, 2021 ? June 30, 2022 Criteria Beginning May 6, 2020, ED required institutions that received a HEERF 18004(a)(1) student aid portion award to publicly post certain information on their website no later than 30 days after award and update the information every 45 days thereafter (by posting a new report). On August 31, 2020, ED revised the announcement by decreasing the frequency of reporting after the initial 30-day reporting period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020 should instead post a report every calendar quarter, with the first quarter report due by October 10, 2020, and covering the period form their late 45-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under CRRSAA and ARP, which 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, and 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, December 31, March 31 June 30). Auditors should determine if an institution was both timely and accurate in publicly posting its Student Aid Portion Reports from May 6, 2020, onward and sample these public reports and reconcile the publicly reported amounts with underlying documentation to ensure accuracy. The critical information that was required to be posted on the institution?s website included: 1) Item #3: The total amount of Emergency Financial Aid Grants distributed to students under the 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).2) Item #4: The estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. 3) 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. 4) 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. Lastly, Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition Found During our testing of two quarterly reports submitted, we found the University reported an inaccurate number of students who received Emergency Financial Aid Grants to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. For the number of students reported, the University appears to have duplicated students that received grants under both the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. The University reported 3,559 and 2,588 students for the March 31, 2022 and September 30, 2021 quarterly reports, respectively. Documentation provided by the University indicates that there were 2,349 and 1,901 unique students that received grants under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms for the quarters ended March 31, 2022 and September 30, 2021, respectively. Cause The condition results from a combination of the fact that this relates to a federal program with evolving requirements during the period under audit and insufficient controls around the reporting of the number of students receiving grants. Possible Asserted Effect Failure to implement sufficient internal controls to ensure the accuracy of these quarterly reports in accordance with federal regulations resulted in the University?s program being noncompliant with federal statues, regulations and the terms and conditions of the federal awards. Questioned Costs None.Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend that the University enhance its process and controls to ensure reports are accurately prepared in accordance with the federal regulations. Views of Responsible Officials The University will correct the following quarterly reports: September 2021, December 2021, and March 2022 to reflect the number of students receiving HEERF student aid.
Finding Number: 2022-001 Federal Agency: United States Department of Education Pass-through Agency: Direct Program Name: Education Stabilization Fund (HEERF) ? Student Aid Portion Assistance Listing Number: 84.425E Federal Award Numbers: P425E200967-20A P425E200967-20B Federal Award Year: July 1, 2021 ? June 30, 2022 Criteria Beginning May 6, 2020, ED required institutions that received a HEERF 18004(a)(1) student aid portion award to publicly post certain information on their website no later than 30 days after award and update the information every 45 days thereafter (by posting a new report). On August 31, 2020, ED revised the announcement by decreasing the frequency of reporting after the initial 30-day reporting period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020 should instead post a report every calendar quarter, with the first quarter report due by October 10, 2020, and covering the period form their late 45-day report through the end of the calendar quarter on September 30, 2020. On May 13, 2021, ED published an additional notice for student aid public reporting under CRRSAA and ARP, which 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, and 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, December 31, March 31 June 30). Auditors should determine if an institution was both timely and accurate in publicly posting its Student Aid Portion Reports from May 6, 2020, onward and sample these public reports and reconcile the publicly reported amounts with underlying documentation to ensure accuracy. The critical information that was required to be posted on the institution?s website included: 1) Item #3: The total amount of Emergency Financial Aid Grants distributed to students under the 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).2) Item #4: The estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. 3) 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. 4) 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. Lastly, Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition Found During our testing of two quarterly reports submitted, we found the University reported an inaccurate number of students who received Emergency Financial Aid Grants to students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. For the number of students reported, the University appears to have duplicated students that received grants under both the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. The University reported 3,559 and 2,588 students for the March 31, 2022 and September 30, 2021 quarterly reports, respectively. Documentation provided by the University indicates that there were 2,349 and 1,901 unique students that received grants under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms for the quarters ended March 31, 2022 and September 30, 2021, respectively. Cause The condition results from a combination of the fact that this relates to a federal program with evolving requirements during the period under audit and insufficient controls around the reporting of the number of students receiving grants. Possible Asserted Effect Failure to implement sufficient internal controls to ensure the accuracy of these quarterly reports in accordance with federal regulations resulted in the University?s program being noncompliant with federal statues, regulations and the terms and conditions of the federal awards. Questioned Costs None.Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend that the University enhance its process and controls to ensure reports are accurately prepared in accordance with the federal regulations. Views of Responsible Officials The University will correct the following quarterly reports: September 2021, December 2021, and March 2022 to reflect the number of students receiving HEERF student aid.