Finding Text
FINDING 2022-001 - Reporting: Significant Deficiency over Internal Controls over Compliance: "See Schedule of Findings and Questioned Costs for chart/table". Criteria: According to an electronic announcement (EA) by U.S. Department of Higher Education (ED) on May 6, 2020, ED required institutions that received a Higher Education Emergency Relief Fund (HEERF) 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). On August 31, 2020, ED revised the EA with 85 FR 53802, which decreased the frequency of subsequent reporting from every 45 days to every calendar quarter. Additionally, 2 CFR 200.303 requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure the timely posting of special reports to their website. Condition/Context: The University did not publicly post a special report on a timely basis. The University is required to prepare and publicly post a special report (Section 18004(a)(1) Student Aid Portion Quarterly Public Reporting) with certain information describing the use of funds distributed from the HEERF on their website no later than 30 days after receiving the award. The University was required to publicly post the initial report to its website by January 10, 2022, however, the University first publicly posted the initial report to its website on January 14, 2022. Cause: In discussing these conditions with University management, the delay in publicly posting the special report to the University?s website was due to resource constraints as the University?s information systems personnel were implementing technology to effectively transition to distance learning and remote work in light of the COVID-19 pandemic and related shelter-in-place orders. Effect: Failure to publicly post special reports to the University?s website on a timely basis does not allow the public to access timely information on how the University used the funds received from the HEERF. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the University implement procedures to ensure special reports are posted to the University?s website in a timely manner. Views of responsible officials: We agree with the auditor?s comments. These were unprecedented times, and this type of failure is inconsistent with past practice. Reporting requirements are tracked internally via the BlueSky deliverable system. Publishing access to the reporting website has been granted to the Restricted Accounting Supervisor to avoid additional publishing delays.