Finding Text
Criteria 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) require 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. Annual Reporting (all HEERF Grantees) ED required an annual report from HEERF grantees in April 2022 that included reporting uses of HEERF I CARES Act funds, HEERF II CRRSAA funds, and HEERF III ARP funds for the 2021 calendar year. Quarterly Public Reporting for (a)(1) Institutional Portion, (a)(2), and (a)(3) Funds The CARES, CRRSAA, and ARP institutional quarterly portion reporting requirements involve publicly posting completed forms on the institution?s website. The forms must be conspicuously posted on the institution?s primary website on the same page the reports of the IHE?s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. IHEs must post this quarterly report form no later than 10 days after the end of each calendar quarter. Quarterly Public Reporting for (a)(1) Student Aid Portion ED requires institutions that received Student Aid Portion awards under CARES Act, CRRSAA and ARP to publicly post certain information on their website. Under the requirements to post student aid public reporting for CRRSAA and ARP, there is a requirement to include certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated not later than 10 days after the end of each calendar quarter. Further, in accordance with 2 CFR 200.303(a), non-federal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testwork over institutional reporting, it was noted that for one of two quarterly required instances of reporting selected for testing was submitted untimely. This quarterly update was provided 23 days after the date it was required to be updated. Additionally, the required reporting included the University?s final disbursements was not appropriately marked as the final report. Additionally, internal controls were not effective as evidence of review of the reporting prior to posting on the University?s website was not retained by management. As such we could not see evidence the management review control was operating effectively. Cause The University?s HEERF reporting process did not include a requirement to maintain the review documentation and did not operate at a level of precision sufficient to ensure timely and accurate reporting. Effect If appropriate controls are not designed and operating effectively over the HEERF reporting process, HEERF expenditures reported on the University?s website and to U.S. Department of Education may be incomplete, inaccurate, or not posted within the timeframe required resulting in non-compliance. Questioned Costs None noted. Recommendation We recommend that the University implement a implement a requirement to maintain the review documentation and incorporate a detailed review of the various fields of the form to ensure accuracy as well as to ensure the HEERF reporting is completed timely.