The Institution does not dispute this finding. The Institution learned that it was not unique in misinterpreting the usage guidelines defined by the federal program. Upon learning that the interpretation was incorrect, the Institution immediately communicated with ED. These communications led to an accommodation from ED regarding the completeness of the Institution’s subsequent procedures. ED also permitted the Institution to retain the drawn down funds while it proceeded with disbursements to students between April and August 2022. In August 2022, the Institution returned the excess funds drawn down. Subsequent to August 2022, HEERF funds drawn down were in accordance with the federal program guidelines.