Finding Text
Finding No.: 2023-012 Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund AL Sub-Program: 84.425E Higher Education Emergency Relief Fund (HEERF) - Student Aid Portion Federal Award No.: COVID-19 P425E204126 AL Sub-Program: 84.425F HEERF - Institutional Portion Federal Award No.: COVID-19 P425F202732 AL Sub-Program: 84.425L HEERF - Minority Serving Institution Federal Award No.: COVID-19 P425L200219 Area: Reporting Questioned Costs: $0 Criteria: The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. In accordance with applicable reporting requirements, the College is required to submit HEERF I, II, & III Annual Performance Report Form (PRA Number 1840-0850) with the following key line items: Question 5: Institutions were required to prioritize exceptional need in awarding emergency financial aid grants to students. Documentation must show methodology for distributing aid that prioritizes exceptional need. Question 9b, row 13: “Implementing evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines” and row 14: “Conducting direct outreach to financial aid applicants.” Spending under these categories indicates whether an institution has spent funds under a required use of funds established under the ARP. If an institution indicates zero-dollar amount spending for either or both categories, examine earlier annual reports to determine the institution had spending at some point on these two funding categories consistent with American Rescue Plan Act (ARP) FAQ Question 21. Additionally, the College is required to submit Quarterly Budget and Expenditure Reporting for all HEERF I, II, and III grant funds (PRA Number 1840-0849). The quarterly portion reporting requirements involve publicly posting completed forms conspicuously on the institution’s website. Furthermore, 2 CFR 200.303(a) states that the subrecipient must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the COSO. Conditions: 1. Total annual expenditures per the Annual Report Data Collection System differ from cumulative expenditures from 01/01/22 through 12/31/22 per underlying accounting records, as follows: 2. ALN 84.425F COVID-19 HEERF-Institutional Portion ALN 84.425L COVID-19 HEERF-Minority Serving Institution Quarterly Budget and Expenditure reports were publicly posted beyond the 10-day posting requirement after the end of each calendar quarter as follows: Cause: The College lacks adequate internal controls over the timely and accurate preparation and review of required reports as stipulated in the criteria above. Effect: The College is in noncompliance with applicable reporting requirements. No questioned costs are presented as the finding relates to the reporting compliance requirement. Identification as a Repeat Finding: 2022-023 Recommendation: College management should strengthen controls so that required reports are timely and accurately prepared and reviewed and submitted within the specified timeframes to evidence compliance with applicable reporting requirements. Views of Auditee and Planned Corrective Actions: The College agrees with the finding and provides details in its Corrective Action Plan.