Finding Text
2022 ? 004: HEERF Reporting Federal Agency: U.S. Department of Education Federal Program Name: (COVID-19) Higher Education Emergency Relief Fund Assistance Listing Number: 84.425F, 84.425M Federal Award Identification Number and Year: P425E204430-2020, P425M201006-20A-2020 Award Period: 84.425F ? May 14, 2020 to June 30, 2023 / 84.425M ? August 5, 2020 to June 30, 2023 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 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 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. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: The University filed the annual report on May 12th, 2022, which was two (2) days later than the requirement to complete by May 10th, 2022. Questioned costs: There are no questioned costs. Context: In performing our audit, we noted that the University had not filed the annual report, with the appropriate supporting documentation, in accordance with the stated criteria. Cause: The University?s internal controls failed to detect that the annual report was not filed by the due date in the stated criteria. Effect: The University was not in compliance with the requirement to file the annual report by the due date in the stated criteria. Repeat Finding: No Recommendation: We recommend the University review its policies and procedures for the filing of the HEERF to ensure that there is sufficient time in the process to meet the due date in accordance with the stated criteria. The evidence of submission should include the original supporting documentation for the information published. Views of responsible officials: There is no disagreement with the audit finding.