Information on the federal program: Student Financial Assistance Cluster; United States Department of Education; Award Year 2021-22; Internal Control Deficiency; Type of Finding: Significant Deficiency in Internal Control over Compliance. Criteria: Institutions should maintain student financial aid files containing all required eligibility documentation and other supporting information. Condition: For many of the student financial aid awards we tested, several items requested were not in the student?s financial aid folders, such as most current award letters, updated student budgets, master promissory notes, loan histories, and entrance/exit counseling. The University was able to provide the requested documentation by other means, in some cases after multiple requests. Cause: The University began initial steps to implement a comprehensive system software change during the current year. The additional time required for this effort, coupled with financial aid office staffing shortages, led to the lack of appropriate review of student aid files to ensure they contained all required documentation. Effect: This issue could have led to students being over-awarded federal financial aid. Questioned Costs: n/a for this finding. Context: Our testing included 64 students. Items not available for review in student aid files, that had to be requested, included: 43 initial or updated award letters, 5 financial aid summaries, 19 entrance/exit counselings, 17 updated student budgets, 17 promissory notes, and 8 loan histories. Recommendations: Management should take steps to ensure that student files contain adequate documentation to support the federal aid amounts awarded. Responsible Official?s Response and Corrective Action Planned: see corrective action plan.
Information on the federal program: Student Financial Assistance Cluster; United States Department of Education; Award Year 2021-22; Internal Control Deficiency; Type of Finding: Significant Deficiency in Internal Control over Compliance. Criteria: Institutions should maintain student financial aid files containing all required eligibility documentation and other supporting information. Condition: For many of the student financial aid awards we tested, several items requested were not in the student?s financial aid folders, such as most current award letters, updated student budgets, master promissory notes, loan histories, and entrance/exit counseling. The University was able to provide the requested documentation by other means, in some cases after multiple requests. Cause: The University began initial steps to implement a comprehensive system software change during the current year. The additional time required for this effort, coupled with financial aid office staffing shortages, led to the lack of appropriate review of student aid files to ensure they contained all required documentation. Effect: This issue could have led to students being over-awarded federal financial aid. Questioned Costs: n/a for this finding. Context: Our testing included 64 students. Items not available for review in student aid files, that had to be requested, included: 43 initial or updated award letters, 5 financial aid summaries, 19 entrance/exit counselings, 17 updated student budgets, 17 promissory notes, and 8 loan histories. Recommendations: Management should take steps to ensure that student files contain adequate documentation to support the federal aid amounts awarded. Responsible Official?s Response and Corrective Action Planned: see corrective action plan.
Information on the federal program: Student Financial Assistance Cluster; United States Department of Education; Award Year 2021-22; Internal Control Deficiency; Type of Finding: Significant Deficiency in Internal Control over Compliance. Criteria: Institutions should maintain student financial aid files containing all required eligibility documentation and other supporting information. Condition: For many of the student financial aid awards we tested, several items requested were not in the student?s financial aid folders, such as most current award letters, updated student budgets, master promissory notes, loan histories, and entrance/exit counseling. The University was able to provide the requested documentation by other means, in some cases after multiple requests. Cause: The University began initial steps to implement a comprehensive system software change during the current year. The additional time required for this effort, coupled with financial aid office staffing shortages, led to the lack of appropriate review of student aid files to ensure they contained all required documentation. Effect: This issue could have led to students being over-awarded federal financial aid. Questioned Costs: n/a for this finding. Context: Our testing included 64 students. Items not available for review in student aid files, that had to be requested, included: 43 initial or updated award letters, 5 financial aid summaries, 19 entrance/exit counselings, 17 updated student budgets, 17 promissory notes, and 8 loan histories. Recommendations: Management should take steps to ensure that student files contain adequate documentation to support the federal aid amounts awarded. Responsible Official?s Response and Corrective Action Planned: see corrective action plan.
Information on the federal program: Student Financial Assistance Cluster; United States Department of Education; Award Year 2021-22; Internal Control Deficiency; Type of Finding: Significant Deficiency in Internal Control over Compliance. Criteria: Institutions should maintain student financial aid files containing all required eligibility documentation and other supporting information. Condition: For many of the student financial aid awards we tested, several items requested were not in the student?s financial aid folders, such as most current award letters, updated student budgets, master promissory notes, loan histories, and entrance/exit counseling. The University was able to provide the requested documentation by other means, in some cases after multiple requests. Cause: The University began initial steps to implement a comprehensive system software change during the current year. The additional time required for this effort, coupled with financial aid office staffing shortages, led to the lack of appropriate review of student aid files to ensure they contained all required documentation. Effect: This issue could have led to students being over-awarded federal financial aid. Questioned Costs: n/a for this finding. Context: Our testing included 64 students. Items not available for review in student aid files, that had to be requested, included: 43 initial or updated award letters, 5 financial aid summaries, 19 entrance/exit counselings, 17 updated student budgets, 17 promissory notes, and 8 loan histories. Recommendations: Management should take steps to ensure that student files contain adequate documentation to support the federal aid amounts awarded. Responsible Official?s Response and Corrective Action Planned: see corrective action plan.
Information on the federal program: Student Financial Assistance Cluster; Direct Loans (Assistance Listing Number 84.268); United States Department of Education; Award Year 2021-22: Compliance Requirement ? Eligibility; Type of Finding: Questioned Costs. Criteria: 34 CFR 685.301 requires that total aid not be awarded in excess of the student?s financial aid or cost of attendance. 34 CFR 685.203(d) and (e) require aggregate loan limits not to exceed $31,000 for dependent undergraduate students. Condition: For three Direct Loans tested, students were over-awarded funds: two had negative unmet financial need and one exceeded the aggregate loan limit. Cause: Due to the internal control issues outlined in finding 2022-003 below, the awarding of Direct Loans was not reviewed as thoroughly as it should be. Effect: The three students affected received more in aid than allowed. Questioned Costs: Known questioned costs total $4,591: See Schedule of Findings and Questioned Costs for chart/table Projected out to the total population, likely questioned costs total $42,379. Context: Total Direct Loans in our 64-student federal student aid file testing: 53. Recommendations: Refund the overpayments to the Department of Education. Follow the recommendations in finding 2022-003 below to prevent further occurrences. Responsible Official?s Response and Corrective Action Planned: see corrective action plan.
Information on the federal program: COVID-19 Education Stabilization Fund (Assistance Listing Number 84.425) HEERF: Institutional Portion (84.425F), Minority Serving Institutions (MSIs) (84.425L), and Student Aid Portion (84.425E); United States Department of Education; Award Year 2021-22; Compliance Requirement ? Reporting; Type of Finding ? Material Noncompliance. Criteria: Uniform Guidance Compliance Supplement 2022 Section 4-84.425 (ESF Section 2) ? III.L.3.b. and c. (Special Reporting) require quarterly public reporting for (a)(1) Institutional Portion, (a)(2), and (a)(3) funds and for (a)(1) Student Aid Portion. The quarterly student reporting includes a requirement to disclose the method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive. Higher Education Emergency Relief Fund III Frequently Asked Questions #51 requires public quarterly reports to remain online for a period of at least three years after the submission of the last quarterly or annual performance report. Condition: The noncompliance for Reporting was as follows: 1) We found no evidence that the following items had been posted to the University?s website: a. The fall 2021 criteria for determining eligible award amounts for students. b. The student portion quarterly reports for 3rd and 4th quarters 2021 and 1st quarter 2022. 2) As of September 19, 2022 and November 22, 2022, when we reviewed the University?s website, we were unable to access any student or institutional quarterly reports, including the reports we cited in our 2020-21 audit report as finding 2021-001. 3) The institutional quarterly reports had errors: a. September 30, 2021 report showed incorrect quarterly amounts. b. December 31, 2021 report showed the amounts for the quarter ended September 30, 2021 instead of December 31, 2021. c. The final quarterly report included cumulative expenditures for the ARP funding instead of the quarterly expenditure amounts. This report was also dated January 6, 2022 instead of March 31, 2022. Cause: University management did not have controls in place to (1) ensure that quarterly reporting would take place, (2) review quarterly reporting for accuracy, or (3) ensure that the reporting would remain available online for three years from the submission of the final report. Effect: The student award eligibility information and accurate quarterly reporting was not made publicly available, and was not maintained online for three years, as required by the grant. Questioned Costs: n/a for this compliance requirement. Context: Total required quarterly institutional and student reports for the year: 6 (program ended prior to March 31, 2022). Student eligibility was calculated differently for each of the two main semesters; only the criteria for spring 2022 was available online. Recommendations: Management should review the Compliance Supplement and other HEERF guidance, post the required reporting online as soon as possible, and take steps to ensure that it will be kept publicly available online for three years. Training should be provided regarding federal grants in the future to ensure that all grant reporting requirements are met. Responsible Official?s Response and Corrective Action Planned: see corrective action plan.
Information on the federal program: COVID-19 Education Stabilization Fund (Assistance Listing Number 84.425) HEERF: Institutional Portion (84.425F), Minority Serving Institutions (MSIs) (84.425L), and Student Aid Portion (84.425E); United States Department of Education; Award Year 2021-22; Compliance Requirement ? Reporting; Type of Finding ? Material Noncompliance. Criteria: Uniform Guidance Compliance Supplement 2022 Section 4-84.425 (ESF Section 2) ? III.L.3.b. and c. (Special Reporting) require quarterly public reporting for (a)(1) Institutional Portion, (a)(2), and (a)(3) funds and for (a)(1) Student Aid Portion. The quarterly student reporting includes a requirement to disclose the method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive. Higher Education Emergency Relief Fund III Frequently Asked Questions #51 requires public quarterly reports to remain online for a period of at least three years after the submission of the last quarterly or annual performance report. Condition: The noncompliance for Reporting was as follows: 1) We found no evidence that the following items had been posted to the University?s website: a. The fall 2021 criteria for determining eligible award amounts for students. b. The student portion quarterly reports for 3rd and 4th quarters 2021 and 1st quarter 2022. 2) As of September 19, 2022 and November 22, 2022, when we reviewed the University?s website, we were unable to access any student or institutional quarterly reports, including the reports we cited in our 2020-21 audit report as finding 2021-001. 3) The institutional quarterly reports had errors: a. September 30, 2021 report showed incorrect quarterly amounts. b. December 31, 2021 report showed the amounts for the quarter ended September 30, 2021 instead of December 31, 2021. c. The final quarterly report included cumulative expenditures for the ARP funding instead of the quarterly expenditure amounts. This report was also dated January 6, 2022 instead of March 31, 2022. Cause: University management did not have controls in place to (1) ensure that quarterly reporting would take place, (2) review quarterly reporting for accuracy, or (3) ensure that the reporting would remain available online for three years from the submission of the final report. Effect: The student award eligibility information and accurate quarterly reporting was not made publicly available, and was not maintained online for three years, as required by the grant. Questioned Costs: n/a for this compliance requirement. Context: Total required quarterly institutional and student reports for the year: 6 (program ended prior to March 31, 2022). Student eligibility was calculated differently for each of the two main semesters; only the criteria for spring 2022 was available online. Recommendations: Management should review the Compliance Supplement and other HEERF guidance, post the required reporting online as soon as possible, and take steps to ensure that it will be kept publicly available online for three years. Training should be provided regarding federal grants in the future to ensure that all grant reporting requirements are met. Responsible Official?s Response and Corrective Action Planned: see corrective action plan.
Information on the federal program: COVID-19 Education Stabilization Fund (Assistance Listing Number 84.425) HEERF: Institutional Portion (84.425F), Minority Serving Institutions (MSIs) (84.425L), and Student Aid Portion (84.425E); United States Department of Education; Award Year 2021-22; Compliance Requirement ? Reporting; Type of Finding ? Material Noncompliance. Criteria: Uniform Guidance Compliance Supplement 2022 Section 4-84.425 (ESF Section 2) ? III.L.3.b. and c. (Special Reporting) require quarterly public reporting for (a)(1) Institutional Portion, (a)(2), and (a)(3) funds and for (a)(1) Student Aid Portion. The quarterly student reporting includes a requirement to disclose the method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive. Higher Education Emergency Relief Fund III Frequently Asked Questions #51 requires public quarterly reports to remain online for a period of at least three years after the submission of the last quarterly or annual performance report. Condition: The noncompliance for Reporting was as follows: 1) We found no evidence that the following items had been posted to the University?s website: a. The fall 2021 criteria for determining eligible award amounts for students. b. The student portion quarterly reports for 3rd and 4th quarters 2021 and 1st quarter 2022. 2) As of September 19, 2022 and November 22, 2022, when we reviewed the University?s website, we were unable to access any student or institutional quarterly reports, including the reports we cited in our 2020-21 audit report as finding 2021-001. 3) The institutional quarterly reports had errors: a. September 30, 2021 report showed incorrect quarterly amounts. b. December 31, 2021 report showed the amounts for the quarter ended September 30, 2021 instead of December 31, 2021. c. The final quarterly report included cumulative expenditures for the ARP funding instead of the quarterly expenditure amounts. This report was also dated January 6, 2022 instead of March 31, 2022. Cause: University management did not have controls in place to (1) ensure that quarterly reporting would take place, (2) review quarterly reporting for accuracy, or (3) ensure that the reporting would remain available online for three years from the submission of the final report. Effect: The student award eligibility information and accurate quarterly reporting was not made publicly available, and was not maintained online for three years, as required by the grant. Questioned Costs: n/a for this compliance requirement. Context: Total required quarterly institutional and student reports for the year: 6 (program ended prior to March 31, 2022). Student eligibility was calculated differently for each of the two main semesters; only the criteria for spring 2022 was available online. Recommendations: Management should review the Compliance Supplement and other HEERF guidance, post the required reporting online as soon as possible, and take steps to ensure that it will be kept publicly available online for three years. Training should be provided regarding federal grants in the future to ensure that all grant reporting requirements are met. Responsible Official?s Response and Corrective Action Planned: see corrective action plan.
Information on the federal program: Student Financial Assistance Cluster; United States Department of Education; Award Year 2021-22; Internal Control Deficiency; Type of Finding: Significant Deficiency in Internal Control over Compliance. Criteria: Institutions should maintain student financial aid files containing all required eligibility documentation and other supporting information. Condition: For many of the student financial aid awards we tested, several items requested were not in the student?s financial aid folders, such as most current award letters, updated student budgets, master promissory notes, loan histories, and entrance/exit counseling. The University was able to provide the requested documentation by other means, in some cases after multiple requests. Cause: The University began initial steps to implement a comprehensive system software change during the current year. The additional time required for this effort, coupled with financial aid office staffing shortages, led to the lack of appropriate review of student aid files to ensure they contained all required documentation. Effect: This issue could have led to students being over-awarded federal financial aid. Questioned Costs: n/a for this finding. Context: Our testing included 64 students. Items not available for review in student aid files, that had to be requested, included: 43 initial or updated award letters, 5 financial aid summaries, 19 entrance/exit counselings, 17 updated student budgets, 17 promissory notes, and 8 loan histories. Recommendations: Management should take steps to ensure that student files contain adequate documentation to support the federal aid amounts awarded. Responsible Official?s Response and Corrective Action Planned: see corrective action plan.
Information on the federal program: Student Financial Assistance Cluster; United States Department of Education; Award Year 2021-22; Internal Control Deficiency; Type of Finding: Significant Deficiency in Internal Control over Compliance. Criteria: Institutions should maintain student financial aid files containing all required eligibility documentation and other supporting information. Condition: For many of the student financial aid awards we tested, several items requested were not in the student?s financial aid folders, such as most current award letters, updated student budgets, master promissory notes, loan histories, and entrance/exit counseling. The University was able to provide the requested documentation by other means, in some cases after multiple requests. Cause: The University began initial steps to implement a comprehensive system software change during the current year. The additional time required for this effort, coupled with financial aid office staffing shortages, led to the lack of appropriate review of student aid files to ensure they contained all required documentation. Effect: This issue could have led to students being over-awarded federal financial aid. Questioned Costs: n/a for this finding. Context: Our testing included 64 students. Items not available for review in student aid files, that had to be requested, included: 43 initial or updated award letters, 5 financial aid summaries, 19 entrance/exit counselings, 17 updated student budgets, 17 promissory notes, and 8 loan histories. Recommendations: Management should take steps to ensure that student files contain adequate documentation to support the federal aid amounts awarded. Responsible Official?s Response and Corrective Action Planned: see corrective action plan.
Information on the federal program: Student Financial Assistance Cluster; United States Department of Education; Award Year 2021-22; Internal Control Deficiency; Type of Finding: Significant Deficiency in Internal Control over Compliance. Criteria: Institutions should maintain student financial aid files containing all required eligibility documentation and other supporting information. Condition: For many of the student financial aid awards we tested, several items requested were not in the student?s financial aid folders, such as most current award letters, updated student budgets, master promissory notes, loan histories, and entrance/exit counseling. The University was able to provide the requested documentation by other means, in some cases after multiple requests. Cause: The University began initial steps to implement a comprehensive system software change during the current year. The additional time required for this effort, coupled with financial aid office staffing shortages, led to the lack of appropriate review of student aid files to ensure they contained all required documentation. Effect: This issue could have led to students being over-awarded federal financial aid. Questioned Costs: n/a for this finding. Context: Our testing included 64 students. Items not available for review in student aid files, that had to be requested, included: 43 initial or updated award letters, 5 financial aid summaries, 19 entrance/exit counselings, 17 updated student budgets, 17 promissory notes, and 8 loan histories. Recommendations: Management should take steps to ensure that student files contain adequate documentation to support the federal aid amounts awarded. Responsible Official?s Response and Corrective Action Planned: see corrective action plan.
Information on the federal program: Student Financial Assistance Cluster; United States Department of Education; Award Year 2021-22; Internal Control Deficiency; Type of Finding: Significant Deficiency in Internal Control over Compliance. Criteria: Institutions should maintain student financial aid files containing all required eligibility documentation and other supporting information. Condition: For many of the student financial aid awards we tested, several items requested were not in the student?s financial aid folders, such as most current award letters, updated student budgets, master promissory notes, loan histories, and entrance/exit counseling. The University was able to provide the requested documentation by other means, in some cases after multiple requests. Cause: The University began initial steps to implement a comprehensive system software change during the current year. The additional time required for this effort, coupled with financial aid office staffing shortages, led to the lack of appropriate review of student aid files to ensure they contained all required documentation. Effect: This issue could have led to students being over-awarded federal financial aid. Questioned Costs: n/a for this finding. Context: Our testing included 64 students. Items not available for review in student aid files, that had to be requested, included: 43 initial or updated award letters, 5 financial aid summaries, 19 entrance/exit counselings, 17 updated student budgets, 17 promissory notes, and 8 loan histories. Recommendations: Management should take steps to ensure that student files contain adequate documentation to support the federal aid amounts awarded. Responsible Official?s Response and Corrective Action Planned: see corrective action plan.
Information on the federal program: Student Financial Assistance Cluster; Direct Loans (Assistance Listing Number 84.268); United States Department of Education; Award Year 2021-22: Compliance Requirement ? Eligibility; Type of Finding: Questioned Costs. Criteria: 34 CFR 685.301 requires that total aid not be awarded in excess of the student?s financial aid or cost of attendance. 34 CFR 685.203(d) and (e) require aggregate loan limits not to exceed $31,000 for dependent undergraduate students. Condition: For three Direct Loans tested, students were over-awarded funds: two had negative unmet financial need and one exceeded the aggregate loan limit. Cause: Due to the internal control issues outlined in finding 2022-003 below, the awarding of Direct Loans was not reviewed as thoroughly as it should be. Effect: The three students affected received more in aid than allowed. Questioned Costs: Known questioned costs total $4,591: See Schedule of Findings and Questioned Costs for chart/table Projected out to the total population, likely questioned costs total $42,379. Context: Total Direct Loans in our 64-student federal student aid file testing: 53. Recommendations: Refund the overpayments to the Department of Education. Follow the recommendations in finding 2022-003 below to prevent further occurrences. Responsible Official?s Response and Corrective Action Planned: see corrective action plan.
Information on the federal program: COVID-19 Education Stabilization Fund (Assistance Listing Number 84.425) HEERF: Institutional Portion (84.425F), Minority Serving Institutions (MSIs) (84.425L), and Student Aid Portion (84.425E); United States Department of Education; Award Year 2021-22; Compliance Requirement ? Reporting; Type of Finding ? Material Noncompliance. Criteria: Uniform Guidance Compliance Supplement 2022 Section 4-84.425 (ESF Section 2) ? III.L.3.b. and c. (Special Reporting) require quarterly public reporting for (a)(1) Institutional Portion, (a)(2), and (a)(3) funds and for (a)(1) Student Aid Portion. The quarterly student reporting includes a requirement to disclose the method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive. Higher Education Emergency Relief Fund III Frequently Asked Questions #51 requires public quarterly reports to remain online for a period of at least three years after the submission of the last quarterly or annual performance report. Condition: The noncompliance for Reporting was as follows: 1) We found no evidence that the following items had been posted to the University?s website: a. The fall 2021 criteria for determining eligible award amounts for students. b. The student portion quarterly reports for 3rd and 4th quarters 2021 and 1st quarter 2022. 2) As of September 19, 2022 and November 22, 2022, when we reviewed the University?s website, we were unable to access any student or institutional quarterly reports, including the reports we cited in our 2020-21 audit report as finding 2021-001. 3) The institutional quarterly reports had errors: a. September 30, 2021 report showed incorrect quarterly amounts. b. December 31, 2021 report showed the amounts for the quarter ended September 30, 2021 instead of December 31, 2021. c. The final quarterly report included cumulative expenditures for the ARP funding instead of the quarterly expenditure amounts. This report was also dated January 6, 2022 instead of March 31, 2022. Cause: University management did not have controls in place to (1) ensure that quarterly reporting would take place, (2) review quarterly reporting for accuracy, or (3) ensure that the reporting would remain available online for three years from the submission of the final report. Effect: The student award eligibility information and accurate quarterly reporting was not made publicly available, and was not maintained online for three years, as required by the grant. Questioned Costs: n/a for this compliance requirement. Context: Total required quarterly institutional and student reports for the year: 6 (program ended prior to March 31, 2022). Student eligibility was calculated differently for each of the two main semesters; only the criteria for spring 2022 was available online. Recommendations: Management should review the Compliance Supplement and other HEERF guidance, post the required reporting online as soon as possible, and take steps to ensure that it will be kept publicly available online for three years. Training should be provided regarding federal grants in the future to ensure that all grant reporting requirements are met. Responsible Official?s Response and Corrective Action Planned: see corrective action plan.
Information on the federal program: COVID-19 Education Stabilization Fund (Assistance Listing Number 84.425) HEERF: Institutional Portion (84.425F), Minority Serving Institutions (MSIs) (84.425L), and Student Aid Portion (84.425E); United States Department of Education; Award Year 2021-22; Compliance Requirement ? Reporting; Type of Finding ? Material Noncompliance. Criteria: Uniform Guidance Compliance Supplement 2022 Section 4-84.425 (ESF Section 2) ? III.L.3.b. and c. (Special Reporting) require quarterly public reporting for (a)(1) Institutional Portion, (a)(2), and (a)(3) funds and for (a)(1) Student Aid Portion. The quarterly student reporting includes a requirement to disclose the method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive. Higher Education Emergency Relief Fund III Frequently Asked Questions #51 requires public quarterly reports to remain online for a period of at least three years after the submission of the last quarterly or annual performance report. Condition: The noncompliance for Reporting was as follows: 1) We found no evidence that the following items had been posted to the University?s website: a. The fall 2021 criteria for determining eligible award amounts for students. b. The student portion quarterly reports for 3rd and 4th quarters 2021 and 1st quarter 2022. 2) As of September 19, 2022 and November 22, 2022, when we reviewed the University?s website, we were unable to access any student or institutional quarterly reports, including the reports we cited in our 2020-21 audit report as finding 2021-001. 3) The institutional quarterly reports had errors: a. September 30, 2021 report showed incorrect quarterly amounts. b. December 31, 2021 report showed the amounts for the quarter ended September 30, 2021 instead of December 31, 2021. c. The final quarterly report included cumulative expenditures for the ARP funding instead of the quarterly expenditure amounts. This report was also dated January 6, 2022 instead of March 31, 2022. Cause: University management did not have controls in place to (1) ensure that quarterly reporting would take place, (2) review quarterly reporting for accuracy, or (3) ensure that the reporting would remain available online for three years from the submission of the final report. Effect: The student award eligibility information and accurate quarterly reporting was not made publicly available, and was not maintained online for three years, as required by the grant. Questioned Costs: n/a for this compliance requirement. Context: Total required quarterly institutional and student reports for the year: 6 (program ended prior to March 31, 2022). Student eligibility was calculated differently for each of the two main semesters; only the criteria for spring 2022 was available online. Recommendations: Management should review the Compliance Supplement and other HEERF guidance, post the required reporting online as soon as possible, and take steps to ensure that it will be kept publicly available online for three years. Training should be provided regarding federal grants in the future to ensure that all grant reporting requirements are met. Responsible Official?s Response and Corrective Action Planned: see corrective action plan.
Information on the federal program: COVID-19 Education Stabilization Fund (Assistance Listing Number 84.425) HEERF: Institutional Portion (84.425F), Minority Serving Institutions (MSIs) (84.425L), and Student Aid Portion (84.425E); United States Department of Education; Award Year 2021-22; Compliance Requirement ? Reporting; Type of Finding ? Material Noncompliance. Criteria: Uniform Guidance Compliance Supplement 2022 Section 4-84.425 (ESF Section 2) ? III.L.3.b. and c. (Special Reporting) require quarterly public reporting for (a)(1) Institutional Portion, (a)(2), and (a)(3) funds and for (a)(1) Student Aid Portion. The quarterly student reporting includes a requirement to disclose the method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive. Higher Education Emergency Relief Fund III Frequently Asked Questions #51 requires public quarterly reports to remain online for a period of at least three years after the submission of the last quarterly or annual performance report. Condition: The noncompliance for Reporting was as follows: 1) We found no evidence that the following items had been posted to the University?s website: a. The fall 2021 criteria for determining eligible award amounts for students. b. The student portion quarterly reports for 3rd and 4th quarters 2021 and 1st quarter 2022. 2) As of September 19, 2022 and November 22, 2022, when we reviewed the University?s website, we were unable to access any student or institutional quarterly reports, including the reports we cited in our 2020-21 audit report as finding 2021-001. 3) The institutional quarterly reports had errors: a. September 30, 2021 report showed incorrect quarterly amounts. b. December 31, 2021 report showed the amounts for the quarter ended September 30, 2021 instead of December 31, 2021. c. The final quarterly report included cumulative expenditures for the ARP funding instead of the quarterly expenditure amounts. This report was also dated January 6, 2022 instead of March 31, 2022. Cause: University management did not have controls in place to (1) ensure that quarterly reporting would take place, (2) review quarterly reporting for accuracy, or (3) ensure that the reporting would remain available online for three years from the submission of the final report. Effect: The student award eligibility information and accurate quarterly reporting was not made publicly available, and was not maintained online for three years, as required by the grant. Questioned Costs: n/a for this compliance requirement. Context: Total required quarterly institutional and student reports for the year: 6 (program ended prior to March 31, 2022). Student eligibility was calculated differently for each of the two main semesters; only the criteria for spring 2022 was available online. Recommendations: Management should review the Compliance Supplement and other HEERF guidance, post the required reporting online as soon as possible, and take steps to ensure that it will be kept publicly available online for three years. Training should be provided regarding federal grants in the future to ensure that all grant reporting requirements are met. Responsible Official?s Response and Corrective Action Planned: see corrective action plan.