Finding Text
Reporting
Program Name: COVID-19: Higher Education Emergency Relief Funds, Institutional Portion Federal Financial Assistance Listing Numbers: 84.425F
Federal Agency: U.S. Department of Education (ED)
Direct funded by the U.S. Department of Education (ED)
Criteria or Specific Requirement
There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid; 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) 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, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329.
ED collected an annual report for HEERF grantees in March 2023 covering calendar year 2022 expenditures.
On June 17, 2022, ED announced an updated format for the HEERF Quarterly Report effective for Q2 2022, report to be posted July 10, 2022. The quarterly portion reporting requirements involve publicly posting completed forms conspicuously on the institution’s website.
Condition
Significant Deficiency in Internal Control over Compliance - The quarters ended September 30, 2022 and December 31, 2022 quarterly public report were selected for testing. 5 of the 6 reports selected for testing were not made publicly available on the District’s website.
Questioned Costs
There are no questioned costs associated with this finding.
Context
The District has 3 colleges that were required to post forms covering the aggregate amounts spent for HEERF I, II, and III quarterly, as well as one annual report per college.
Effect
The quarterly reports were not publicly posted on the District’s website. In addition, the supporting documentation was not available for review.
Cause
The District did not have internal controls in place to ensure quarterly reports were made publicly available and completed accurately with sufficient supporting documentation.
Recommendation
The District should implement internal controls to ensure that reporting requirements and deadlines are clearly communicated to all staff.