FINDING 2022-001: INSTITUTIONAL PORTION QUARTERLY REPORTING Condition For the quarterly Institutional Portion reports posted to the Institution?s website, we noted discrepancies between the amounts reported in the Funds Expended Categories and the supporting documentation provided by the Institution. Criteria Section 18004(e) of the Cares Act directs schools receiving funds under Section 18004 of the Act to submit a report to ED describing the use of funds distributed from HEERF. The U.S. Department of Education (ED) has developed the Quarterly Budget and Expenditure Reporting form (OMB Control Number 1840-0849) that institutions must use to satisfy the quarterly Institutional Portion reporting. The quarterly reports must be supported by accurate applicable accounting records and accurately presented in accordance with governing requirements. This is the Section 18004(a)(1) Institutional Portion Quarterly Public Reporting (ALN 84.425F) requirement. (a)(1) Institutional Aid Portion Certification and Agreement (Section 15011(b)(2) of Division B of the CARES Act) Quarterly Budget and Expenditure Reporting form (OMB Control Number 1840-0849) (updated 5/11/2011, 9/21/2021 and 7/7/2022) Cause The quarterly reports originally posted to the Institution?s website were deemed to be incorrect based on the accounting records and supporting documentation provided by the Institution. The 9/30/2021 and 12/31/2021 quarterly institution reports did not reflect the expenditures in the proper categories. Pittsburgh Institute of Aeronautics SECTION III ? FEDERAL AWARD FINDINGS FOR THE YEAR ENDED JUNE 30, 2022 34 FINDING 22-1: INSTITUTIONAL PORTION QUARTERLY REPORTING (CONTINUED) Effect and Questioned Costs The quarterly reports posted by the Institution were incorrect. There are no questioned costs associated with this finding as the amounts claimed by the Institution were for allowable costs. Prior to the issuance of this audit report, the Institution posted the amended quarterly reports in accordance with the federal requirements. Category Reported Correct Reported Correct Reported Correct Reported Correct Providing additional emergency financial aid grants to students $ 2,259 $ - $ 63,000 $ 65,259 $ 25,250 $ 25,250 $ - $ - Covering the cost of providing additional technology hardware to students, such as laptops or tablets, or covering the added cost of technology fees. - 71,135 - - - - - - Costs related to operating additional class sections to enable social distancing, such as those for hiring more instructors and increasing campus hours of operations - 4,267 - - - - - 15,930 Campus safety and operations - 140,816 - 228,797 - 9,871 - 12,080 Purchasing, leasing, or renting additional equipment or software to enable distance learning, or upgrading campus wi-fi access or extending open networks to parking lots or public spaces, etc - 36,047 - 4,978 - - - - Replacing lost revenue from academic sources - - 652,495 652,495 - - - - Other Uses of (a)(1) Institutional Portion funds 253,658 3,545 260,557 14,651 - - 28,010 - Other Uses of (a)(2) or (a)(3) funds, if applicable 41,054 41,054 - - - - - - $ 296,971 $ 296,864 $ 976,052 $ 966,180 $ 25,250 $ 35,121 $ 2 8,010 $ 2 8,010 September 30, 2021 December 31, 2021 March 31, 2022 June 30, 2022 Recommendation The Institution should continue to follow established procedures to ensure that, in the future, the quarterly Institution Portion Report is accurately prepared. Views of Responsible Officials The Institution has reviewed the finding and concurs with the recommendation. As outlined in the Corrective Action Plan, the Institution has procedures in place to ensure compliance with the requirements.
FINDING 22-2: PROCUREMENT POLICIES AND PROCEDURES Condition The Institution?s procurement policies and procedures did not include certain aspects of the applicable federal regulations and other procurement requirements specific to the HEERF program, including the various thresholds for vendor selection and purchases (micro - purchase, small purchase, sealed bid, and simplified acquisition methods) and conflict of interest policies related to procurement. Criteria Institutions must follow the procurement standards set out at 2 C.F.R. ?? 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 C.F.R. part 200. 2 C.F.R. ? 200.318 through 200.326 Cause The Institution used its current policy for procurement that required various levels of internal management approval for purchases and didn?t have specific policies under 2 CFR 200. The institution did not verify that vendors were not disbarred prior to purchasing or making drawdowns. Effect There were no questioned costs associated with this finding as the Institution?s purchases claimed using HEERF were for allowable costs. Over $280,000 of the expenditures claimed would have been applicable for the small purchase method while all other purchases would have been applicable for the micro-purchase method. In certain instances, the Institution received approval from ED approving expenditures to be claimed using HEERF. In some cases, the Institution did receive bids from multiple vendors and researched what vendors were able to supply their needs. The individual responsible for overseeing the purchases determined that the price was fair and reasonable. Recommendation The Institution should update its procurement policies and procedures to ensure that all applicable aspects of the federal guidelines are documented and in accordance with the federal regulations. Views of Responsible Officials The Institution has reviewed the finding and concurs with the recommendation. As outlined in the Corrective Action Plan, the Institution has procedures in place to ensure compliance with the requirements.
FINDING 2022-001: INSTITUTIONAL PORTION QUARTERLY REPORTING Condition For the quarterly Institutional Portion reports posted to the Institution?s website, we noted discrepancies between the amounts reported in the Funds Expended Categories and the supporting documentation provided by the Institution. Criteria Section 18004(e) of the Cares Act directs schools receiving funds under Section 18004 of the Act to submit a report to ED describing the use of funds distributed from HEERF. The U.S. Department of Education (ED) has developed the Quarterly Budget and Expenditure Reporting form (OMB Control Number 1840-0849) that institutions must use to satisfy the quarterly Institutional Portion reporting. The quarterly reports must be supported by accurate applicable accounting records and accurately presented in accordance with governing requirements. This is the Section 18004(a)(1) Institutional Portion Quarterly Public Reporting (ALN 84.425F) requirement. (a)(1) Institutional Aid Portion Certification and Agreement (Section 15011(b)(2) of Division B of the CARES Act) Quarterly Budget and Expenditure Reporting form (OMB Control Number 1840-0849) (updated 5/11/2011, 9/21/2021 and 7/7/2022) Cause The quarterly reports originally posted to the Institution?s website were deemed to be incorrect based on the accounting records and supporting documentation provided by the Institution. The 9/30/2021 and 12/31/2021 quarterly institution reports did not reflect the expenditures in the proper categories. Pittsburgh Institute of Aeronautics SECTION III ? FEDERAL AWARD FINDINGS FOR THE YEAR ENDED JUNE 30, 2022 34 FINDING 22-1: INSTITUTIONAL PORTION QUARTERLY REPORTING (CONTINUED) Effect and Questioned Costs The quarterly reports posted by the Institution were incorrect. There are no questioned costs associated with this finding as the amounts claimed by the Institution were for allowable costs. Prior to the issuance of this audit report, the Institution posted the amended quarterly reports in accordance with the federal requirements. Category Reported Correct Reported Correct Reported Correct Reported Correct Providing additional emergency financial aid grants to students $ 2,259 $ - $ 63,000 $ 65,259 $ 25,250 $ 25,250 $ - $ - Covering the cost of providing additional technology hardware to students, such as laptops or tablets, or covering the added cost of technology fees. - 71,135 - - - - - - Costs related to operating additional class sections to enable social distancing, such as those for hiring more instructors and increasing campus hours of operations - 4,267 - - - - - 15,930 Campus safety and operations - 140,816 - 228,797 - 9,871 - 12,080 Purchasing, leasing, or renting additional equipment or software to enable distance learning, or upgrading campus wi-fi access or extending open networks to parking lots or public spaces, etc - 36,047 - 4,978 - - - - Replacing lost revenue from academic sources - - 652,495 652,495 - - - - Other Uses of (a)(1) Institutional Portion funds 253,658 3,545 260,557 14,651 - - 28,010 - Other Uses of (a)(2) or (a)(3) funds, if applicable 41,054 41,054 - - - - - - $ 296,971 $ 296,864 $ 976,052 $ 966,180 $ 25,250 $ 35,121 $ 2 8,010 $ 2 8,010 September 30, 2021 December 31, 2021 March 31, 2022 June 30, 2022 Recommendation The Institution should continue to follow established procedures to ensure that, in the future, the quarterly Institution Portion Report is accurately prepared. Views of Responsible Officials The Institution has reviewed the finding and concurs with the recommendation. As outlined in the Corrective Action Plan, the Institution has procedures in place to ensure compliance with the requirements.
FINDING 22-2: PROCUREMENT POLICIES AND PROCEDURES Condition The Institution?s procurement policies and procedures did not include certain aspects of the applicable federal regulations and other procurement requirements specific to the HEERF program, including the various thresholds for vendor selection and purchases (micro - purchase, small purchase, sealed bid, and simplified acquisition methods) and conflict of interest policies related to procurement. Criteria Institutions must follow the procurement standards set out at 2 C.F.R. ?? 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 C.F.R. part 200. 2 C.F.R. ? 200.318 through 200.326 Cause The Institution used its current policy for procurement that required various levels of internal management approval for purchases and didn?t have specific policies under 2 CFR 200. The institution did not verify that vendors were not disbarred prior to purchasing or making drawdowns. Effect There were no questioned costs associated with this finding as the Institution?s purchases claimed using HEERF were for allowable costs. Over $280,000 of the expenditures claimed would have been applicable for the small purchase method while all other purchases would have been applicable for the micro-purchase method. In certain instances, the Institution received approval from ED approving expenditures to be claimed using HEERF. In some cases, the Institution did receive bids from multiple vendors and researched what vendors were able to supply their needs. The individual responsible for overseeing the purchases determined that the price was fair and reasonable. Recommendation The Institution should update its procurement policies and procedures to ensure that all applicable aspects of the federal guidelines are documented and in accordance with the federal regulations. Views of Responsible Officials The Institution has reviewed the finding and concurs with the recommendation. As outlined in the Corrective Action Plan, the Institution has procedures in place to ensure compliance with the requirements.