Finding Text
2023-001 Reporting
U.S. Department of Education:
COVID-19 Education Stabilization Fund – Higher Education Emergency Relief Fund (HEERF) Student
Aid Portion and Institutional Aid Portion (ALN 84.425E & 84.425F)
Federal Award Number and Year: P425F200214 (4/21/20 – 6/30/23)
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Prior Year Finding: 2022-002
Finding Type: Material Weakness and Material Noncompliance
Criteria
There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The Department of Education requires that institutions who received the Section 18004(a)(1) Student Aid Portion of higher education emergency relief funding (HEERF) to publicly post certain information on their website every calendar quarter. The report must be updated no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, and July 10). All institutions of higher education that received HEERF grant awards are required to submit a HEERF Annual Report. The next reporting cycle is the Year 3 report covering January 1, 2022, through December 31, 2022. The HEERF Annual Report portal will open on March 6, 2023, and will close on March 24, 2023. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program.
Condition and Context
Website reporting: During 2023, the University did not update their website each quarter. The University only updated its website for the quarter ending June 30, 2023. In addition, the University could not provide evidence that the information for the quarter ended June 30, 2023 was updated on the website timely or appropriately reviewed prior to posting. Annual reporting: The University could not provide evidence that the original report was submitted by the required deadline of March 2023. Additionally, the compliance supplement outlined two key line items. The first key line item was question 5 on the annual report. The University did not complete that section of the report. The second key line item related to the section “Conducting direct outreach to financial aid applicants.” According to the compliance supplement, this category of spending could not be zero for the life of the HEERF grant. The University has reported zero for this category of spending on the annual report filed for fiscal year 2023 and fiscal year 2022. Institutional quarterly reporting: For the June 30, 2023 quarterly reporting for the institutional portion of the HEERF funding, the University’s support did not match the amount that was submitted to the U.S. Department of Education. For the line item “HEERF (a)(1) Student Aid Portion Amount Disbursed” the amount reported was $20,647,007 however the correct amount was $20,674,007. The University did not properly design internal controls to ensure that information displayed on the website was reported timely, and was complete and accurate.
Cause
Website reporting: The University did not have policies and procedures in place to ensure that the website was appropriately updated on a quarterly basis. In addition, the University did not maintain documentation that the information was reported timely and was properly reviewed by someone other than the preparer with knowledge of the subject matter.
Annual reporting: The University did not have policies and procedures in place to ensure that the annual report was submitted timely and they also did not have policies and procedures in place to ensure the report contained all required elements before submission. Institutional quarterly reporting: The University did not have policies and procedures in place to ensure that the June 30, 2023 quarterly report was accurate.
Effect
Website reporting: The information displayed on the University’s website was not current throughout fiscal year 2023. Annual reporting: The report was submitted late and did not include all required information as outlined by the U.S. Department of Education. Institutional quarterly reporting: The information submitted by the University was not accurate.
Questioned Costs
Cannot be determined
Recommendation
We recommend that the University strengthen its policies and procedures over the website reporting, annual reporting and the institutional quarterly reporting in relation to the Education Stabilization Fund
program. We also recommend that the University ensure that internal controls in place surrounding the review of all of the reporting requirements are performed as designed and that documentation supporting the amounts reported is adequately maintained, along with evidence that the information was adequately reviewed by someone other than the preparer with knowledge of the subject matter.
Views of Responsible Official
The University agrees with the finding and acknowledges the finding was also reported in the previous fiscal year. Despite high staff turnover, the Director of the Financial Aid Office and in collaboration with the Controller’s Office, the issue is being addressed for any future reporting.