Finding Number: 2022-002 - Internal Controls over Compliance with Education Stabilization Fund Requirements Institutional Response: The responsibility of ensuring expenditures incurred due to the COVID-19 pandemic met the requirements established under HEERF as eligible reimbursement rested with the former Office of Business and Administration. The vice president and the controller were the two lead finance officers for the institution and the controller was the grant ?Project Director? as defined by G5. Given the volume of purchases and the speed in which institutions had to act, larger committees to review expenditures were not feasible. The procurement department resided with this division, so the review of all anticipated HEERF eligible expenses by the leader of the division and the second most senior ranking in the division seemed adequate. The office also accounted for expenditures to HEERF funding by creating dedicated general ledger funds for only HEERF related expenses that they reviewed. The institution could not have foreseen both positions would be vacant before the closing of the grant period. The review process of each expenditure passing through the direct oversight of the vice president and the controller was still a sound practice that continued through the expenditures reported and claimed against HEERF funding. Corrective Action: While Lander University believes its expenditure review process under HEERF was adequate by establishing direct purchasing oversight with both the vice president and controller position, despite the fact both position were eventually vacated, the University acknowledges that a process or procedure established should continue to be honored. In the event a practice or procedure needs to be altered or updated, additional document supporting the change should also exist. The discontinuation of an internal form used to establish approvals specific to reviewing expenditures associated with HEERF did not impact the process as the upper-management review and sign-off still occurred and all procurements passed through the state procurement process. Lander University will ensure a more robust process of approvals is established for future federal funding should the institution experience turnover in key roles.