Finding Text
Finding 2022-007: Significant Deficiency - Reporting Program: COVID-19 - Education Stabilization Fund CFDA Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E200145, P425F202178, P425M201123 Federal Award Year: June 30, 2022 Repeat of Prior Year Finding 2021-005 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. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education (ED) exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For the annual report covering January 1, 2021 through December 31, 2021, the University reported the Strengthening Institutions Program funding spent in calendar year 2022 within its 2021 annual report. In addition, for the third quarter 2021 (quarter ending September 30, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(2) Strengthening Institutions Program funding awarded to the University on the section (a)(3) line, when the amount should have been included on the section (a)(2) line. For the third quarter 2021 institutional portion report, the University also reported the lost revenue claimed under the institutional portion of section (a)(1) in the section (a)(2) column, when the amount should have been included in the section (a)(1) column. Also, for the quarterly student portion reports, the University reported the student grants awarded, the number of students eligible to receive a student grant, and the number of students who received a student grant for each individual quarter and not cumulatively from the start of the programs. Questioned Costs: Not applicable. Context: Errors were noted in the one annual report, two quarterly institutional portion reports, and two quarterly student portion reports that were tested. The University was required to file one annual report, four quarterly institutional portion reports, and four quarterly student portion reports during the fiscal year. The sample was not considered statistically valid. Effect: The information included on the publicly-available reports and reports submitted to federal agencies was not accurate. Cause: The exceptions noted on the reports resulted from various factors, including misunderstanding of how reports were intended to be completed and turnover during the year in key personnel associated with preparing and reviewing the reports. Recommendation: It is recommended that the guidance surrounding the preparation of the annual and quarterly reports be reviewed. In addition, the review of reports by someone who is not the original preparer of the reports should include a detailed tie out of numbers included on the reports to the University's supporting documentation. Management's Response: The University agrees with the finding. While the University did not provide the public with data in accordance with the above noted columns and cumulative amounts in the top section related to the HEERF Institutional Aid Portion, the amounts listed and what they were expensed for was correct. Based on the information provided to the University by the Department of Education (ED) and attending other webinars regarding reporting requirements, the University believed it had filed the reports correctly. The University's initial report was reviewed and accepted by ED on June 5, 2020. Based on that acceptance, the University thought it was doing the reports correctly. Since the finding was identified during the audit, the University has submitted the revised reports stated above. The University has a committee to monitor reporting requirements of federal awards consisting of key members of the Executive Team, Business Office, IT and the respective project director. On February 4, 2022, the University received notification from ED that the updated reports had been received, reviewed and added to its file.