Finding Text
2023-003 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Significant Deficiency in Internal Controls over Compliance
Department of Education
Federal Assistance Listing Number: 84.425E, 84.425L
Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion, Higher Education Emergency Relief Funds (HEERF) Minority Serving Institutions (MSIs)
Federal Award Number: P425E200777, P425L200234
Award Year: 2022-23, 2021-22, 2020-21
Criteria – In accordance with the Funding Certification and Agreement for the Emergency Financial Aid Grants to Students institutions must have a documented plan to distribute funds to students.
Condition/context – A sample of 10 disbursements to students out of a population of 136 disbursements to students was selected. A documented plan for distribution of funds to students was requested, however the University did not have a documented plan.
Our sample was not, and was not intended to be, statistically valid.
Questioned costs – None.
Cause/effect – The University did not have the controls in place to formerly approve a plan for distributions of funds that was documented and circulated to the University. The lack of a documented plan for distribution of funds to students increases the risk that funds were inappropriately disbursed to students at the wrong amounts. In addition, it increases the risk that the disbursements were not equitable across the student population.
Repeat finding – Yes, 2022-004
Recommendation – We recommend the University adopt a policy that is formally approved and retained indicating how HEERF student aid portion funds are to be distributed to students.
Views of responsible officials and planned corrective actions – The University shall establish and maintain a documented policy outlining the allocation of HEERF student aid portion monies to students.