Finding 11881 (2023-002)

Criteria or specific requirement: Under section 2003(5) of the American Rescue Plan Act of 2021 (ARP) (Pub. L. 117-2) (supplemental award or grant) by the U.S. Department of Education, Recipient must use a portion of their institutional funds received under this supplemental award to (a) to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act of 1965, as amended (HEA) (20 USC § 1087tt). In addition, Uniform Grant Guidance (2 CFR 20.303) requires nonfederal entities receiving Federal awards establish and maintain controls designed to reasonable ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted there was no amount allocated to the earmarking requirement. Questioned costs: None Context: During our testing, we noted the College was not in compliance with the annual reporting requirements because the College did not report ARP funds expended to conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student or other circumstances, described in section 479A of the HEA. Cause: The policies and procedures of the College did not ensure that annual reporting requirements to report amounts spent for earmarking requirements were accurately met. Effect: The College inaccurately reported the amount spent under earmarking requirements. Non-compliance with federal regulations could lead to funds being required to be returned or refunded in order to meet the reporting requirement. Repeat Finding: No Recommendation: We recommend the College revise their report to properly show the amount spent under earmarking requirements. In addition, we recommend the College put procedures in place to review earmarking requirements and properly track them for reporting purposes. Views of responsible officials: There is no disagreement with the audit finding.