Finding Text
Department of Education
Education Stabilization Fund: Higher Education Emergency Relief Find (HEERF)
Federal Financial Assistance Listing 84.425F Institutional Portion
Award Number P425F202657, Award Years 2020 and 2021
Period of Performance
Material Weakness in Internal Controls over Compliance and Material Non-Compliance
Criteria: In the CRRSSA and ARP Certification and Agreement, all institutions were given one calendar year from
the date of the Grant Award Notification to complete period of performance which was subsequently extended
to June 30, 2023. Department of Education provided guidance in Frequently Asked Questions #51 specific to
period of performance noting, “institutions now have 120 calendar days to liquidate all financial obligations
incurred under the award after the period of performance.” The 2024 compliance supplement also notes
specific to lost revenue, “For lost revenue, the obligation occurs on the date the institution completes its
estimate of its amount of lost revenue after the estimation period.”
Condition: Two errors were noted related to period of performance: 1) the lost revenue calculation was
completed in October 2023, which was after the June 30, 2023, period of performance date; and 2) the School
District also spent money on expenses for the program in November 2023 and January 2024, which was after
the 120-day liquidation period.
Cause: The School did not apply for a no cost extension to be able to obligate the funding after June 30, 2023.
For error #1, the School District was waiting to claim lost revenue until all expenses under the program were
incurred to be able to use any remaining funding available. For error #2, the School District believed that the
purchase orders that were outstanding after the 120-day liquidation period would be allowed to be paid when
items purchased were received.
Effect: The School received grant funding on allowable costs which were paid for or obligated after the period of
performance and liquidation period ended.
Questioned Costs: $539,358 specific to lost revenue and $179,409 for expenses paid for in November 2023 and
January 2024.
Context/Sampling: All lost revenue calculation reports were tested. We tested 40 out of 410 total expenses from
the program for other expenses. Total questioned costs for expenses was obtained from general ledger detail
for expenses paid after October 26, 2023.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend a tracking schedule monitored by multiple people be maintained with all
required spending deadlines to ensure that funding is spent in the required timeframe. We also recommend
review of the grant agreements and grant funding information to ensure that knowledge of the requirements is
known by multiple people to ensure requirements are met.
Views of Responsible Officials: Management agrees with the finding.