Finding Number: 2022-003 - Allowable Costs Institutional Response: It is Lander University?s position the measures taken to utilize previously leased space to socially distance nursing students, in a simulation lab setting, falls within the guidance provided. While HEERF funding was not to be used for construction or capital outlays, an exception was provided in the FAQ regarding, and helping to further define, ?minor remodeling.? The FAQ provides limited, and not all-inclusive, examples of ?minor remodeling.? The most specific examples given were under question #24. ?What are some examples of permissible ?minor remodeling? that HEERF grant funds may support under the definition in 34 CFR ? 77.1?? An excerpt of the answer is provided: ?Some examples of permissible minor remodeling may include, but not limited to: ? The installation or renovation of an HVAC system, to help with air filtration to prevent the spread of COVID-19. ? The purchase or cost of the installation of ?room dividers? within a previously completed building to increase social distancing.? The building in question was preexisting, occupiable, and did not receive structural improvements or additions to the building. The HVAC systems was renovated to meet the CDC and ASHRAE recommendations to improved air quality through a significant increase of bringing in outside make up air. The institution expended $162,535 in direct HVAC costs according to the final pay app - schedule of values with additional associated expenses in both plumbing and electrical, totaling more than $281,000. The institution did partition a large, open space into two separate areas to further divide students for social distancing measures. Taking these measures allowed the institution to keep preparing nurses for the workforce at a critical time during the pandemic. Lander University did not have to reduce class sizes, or resort to limited online learning for lab experience because it had the ability to spread out between two locations: the main nursing building and this extension location for simulation. The simulation space worked to mimic clinical experience with essential equipment for training nursing students. Corrective Action: The University maintains its position the expenses incurred fall within provided guidance; however, should the U.S. Department of Education disagree as part of their auditing procedures, Lander University will work to reach a remedy with the agencies in authority over the HEERF program. Responsible department for corrective action: Office of Accounting and Controls and the Office of Finance and Administration