Finding 1027795 (2022-001)

Material Weakness
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2023-03-28
Audit: 313372
Organization: Creighton University (NE)
Auditor: Kpmg LLP

AI Summary

  • Core Issue: The University failed to report required quarterly information for HEERF III funding, despite awarding approximately $4.4M in student aid.
  • Impacted Requirements: Compliance with federal reporting requirements under the CARES Act, specifically for timely updates on Emergency Financial Aid Grants.
  • Recommended Follow-Up: Enhance internal controls to ensure timely completion of all required reports moving forward.

Finding Text

Finding 2022-001Federal Program Title ? COVID-19 Education Stabilization Fund ? Student PortionAssistance Listing No. ? 84.425EFederal Agency ? U.S. Department of Education (ED or the Department)Grant Award Period ? April 25, 2020 to May 15, 2022Compliance Requirement ? ReportingCriteriaThe University received funding under the federal Coronavirus Aid, Relief, and Economic Security(CARES) Act (HEERF I), Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA)(HEERF II) and the America Rescue Plan (ARP) (HEERF III).ED requires that institutions publicly post certain information on their website. The following informationmust appear in a format and location that is easily accessible to the public. This information must also beupdated no later than 10 days after the end of each calendar quarter (September 30, and December 31,March 31, June 30) thereafter:(1) An acknowledgement that the institution signed and returned to the Department the Certification andAgreement and the assurance that the institution has used the applicable amount of funds designatedunder the CRRSAA and ARP (a)(1) and (a)(4) programs to provide Emergency Financial Aid Grants toStudents.(2) The total amount of funds that the institution will receive or has received from the Department pursuantto the institution?s Certification and Agreement for Emergency Financial Aid Grants to Students under theCRRSAA and ARP (a)(1) and (a)(4) programs.(3) The total amount of Emergency Financial Aid Grants distributed to students under the CRRSAA andARP (a)(1) and (a)(4) programs as of the date of submission (i.e., as of the initial report and every calendarquarter thereafter).(4) The estimated total number of students at the institution that are eligible to receive Emergency FinancialAid Grants to Students under the CRRSAA and ARP (a)(1) and (a)(4) programs.(5) The total number of students who have received an Emergency Financial Aid Grant to students underthe CRRSAA and ARP (a)(1) and (a)(4) programs.(6) The method(s) used by the institution to determine which students receive Emergency Financial AidGrants and how much they would receive under the CRRSAA and ARP (a)(1) and (a)(4) programs.(7) Any instructions, directions, or guidance provided by the institution to students concerning theEmergency Financial Aid Grants.In addition, CFR 200.303 requires nonfederal entities to, among other things, establish and maintaineffective internal control over the Federal award that provides reasonable assurance that the non Federalentity is managing the Federal award in compliance with Federal statutes, regulations, and the terms andconditions of the Federal award.Conditions Found:During the audit, we noted the required information for funds received and disbursed for student aid underHEERF I and HEERF II were reported on the University?s website within required timeframes, with finalinformation for HEERF II reported as of March 15, 2022. Final information for HEERF I was previouslyreported within required timeframes. No quarterly information on the funding received for HEERF III wasincluded in the reporting during the fiscal year, although approximately $4.4M of HEERF III student aid wasawarded and disbursed during the fiscal year.On July 11, 2022, a student aid report was posted to the University?s website as a PDF related to thequarter ended March 31, 2022. Reporting for this quarter was due by April 10, 2022. This informationincluded student aid awarded of $7,781 and number of students awarded of 4 for the quarter endedMarch 31, 2022, and cumulative student aid paid for all HEERF awards as of March 31, 2022. Noinformation was presented for cumulative students receiving aid to date.No additional student aid information was reported until November 7, 2022. An update was posted to theUniversity?s website on November 7, 2022, indicating cumulative information of amounts received,disbursed, and number of students eligible and awarded for HEERF I, HEERF II, and HEERF III as ofAugust 30, 2022. No additional quarterly information was presented. Information surrounding the methodthe University used was also included for each award. As of August 30, 2022, all student aid had beenexpended.Questioned CostNo questioned costs were identified.Cause and EffectDue to competing job priorities, the University did not submit all required quarterly reports for student aidawarded and disbursed under HEERF III. The University did not have an effective system of internal controlin place, as prescribed by 2 CFR 200.303, to ensure the University completed quarterly reports timely.Repeat FindingA similar finding was not reported in the prior year audit.Statistical SamplingThe sample was not intended to be, and was not, a statistically valid sample.RecommendationsWe recommend the University enhance its internal control process to ensure the University has effectiveinternal controls in place in relation to completing its reporting on a timely manner.Views of Responsible OfficialThe University concurs with the findings. Appropriate reporting was completed for HEERF I and HEERF IIand annual reports completed timely. We have executed our corrective action plan to ensure quarterlyreports for HEERF III and other future reports are completed timely.

Categories

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 451353 2022-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $161.85M
84.GSA_MIGRATION Federal Perkins Loan $10.58M
93.342 Health Professions Student Loans, Including Primary Care Loand and Loans for Disadvantaged Students $8.36M
84.425E Education Stabilization Fund - Higher Education Emergency Relief Fund - Student Portion $4.39M
93.364 Nursing Student Loans $3.24M
84.GSA_MIGRATION Federal Pell Grant Program $2.43M
84.GSA_MIGRATION Upward Bound $1.17M
93.859 Biomedical Research and Research Training $1.04M
84.GSA_MIGRATION Federal Supplemental Educational Opportunity Grants $1.01M
12.420 Military Medical Research and Development $842,487
84.GSA_MIGRATION Federal Work-Study Program $753,933
12.300 Basic and Applied Scientific Research $648,192
93.498 Provider Relief Fund $608,974
93.822 Health Careers Opportunity Program (hcop) $438,601
84.GSA_MIGRATION Talent Search $435,452
93.393 Cancer Cause and Prevention Research $392,488
47.GSA_MIGRATION Integrative Activities $347,153
84.GSA_MIGRATION Student Support Services $308,908
93.866 Aging Research $266,640
84.GSA_MIGRATION Educational Opportunity Centers $249,335
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $236,381
93.242 Mental Health Research Grants $213,302
81.GSA_MIGRATION Office of Science Financial Assistance Program $202,501
47.GSA_MIGRATION Biological Sciences $161,369
84.425F Education Stabilization Fund - Higher Education Emergency Relief Fund - Institutional Portion $137,716
21.GSA_MIGRATION Coronavirus Relief Fund $135,876
47.GSA_MIGRATION Mathematical and Physical Sciences $94,765
93.121 Oral Diseases and Disorders Research $73,348
93.855 Allergy and Infectious Diseases Research $72,783
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $49,806
93.867 Vision Research $42,049
93.173 Research Related to Deafness and Communication Disorders $41,090
45.149 Promotion of the Humanities Division of Preservation and Access $31,102
47.050 Geosciences $28,699
43.GSA_MIGRATION Office of Stem Engagement (ostem) $19,545
93.879 Medical Library Assistance $17,015
93.GSA_MIGRATION Public Health Emergency Preparedness $12,220
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $12,205
93.113 Environmental Health $9,135
47.075 Social, Behavioral, and Economic Sciences $7,073
21.GSA_MIGRATION Emergency Rental Assistance Program $7,033
93.426 Improving the Health of Americans Through Prevention and Management of Diabetes and Heart Disease and Stroke $6,346
93.865 Child Health and Human Development Extramural Research $1,723
93.838 Lung Diseases Research $250