Finding Text
Criteria: 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 (Annual Report). The Coronavirus Aid, Relief,
and Economic Security (CARES) Act 18004(e) and the Coronavirus Response and Relief Supplemental
Appropriations Act (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
American Rescue Plan (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.
Condition: For one quarterly report, the supporting documentation maintained did not agree to the
information included in the report. Additionally, the Annual Report for 2022 was not prepared.
Context: For quarterly reporting, we selected a non-statistical sample of two Quarterly Reporting Forms
for testing, noting that for one report, discrepancies between the supporting documentation and the
information in the report existed in 3 out of 6 lines of data. For annual reporting, management indicated
that they did not believe they were required to prepare the Annual Report for 2022 as all program funds
were expended prior to December 31, 2022.
Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as
possible, it was necessary to gather information from various sources within the University. However, the
turnover of staff resulted in a lack of retention of this information in a manner conducive to easy retrieval,
compilation and reconciliation with reported amounts. Effect: The Quarterly Reporting Forms that were completed may contain inaccurate or incomplete data. In
addition, the University was not compliant with the requirement to submit the Annual Report for 2022.
Questioned Costs: None
Identification of a repeat finding: This is a repeat finding of 2022-002.
Recommendations: As the HEERF Program has ended for the University, we recommend that if similar
programs become available in the future, management should develop well-documented policies and
procedures. These should be detailed enough to ensure that essential knowledge and information for report
preparation, including information sources, can withstand significant staff turnover.
Views of responsible officials: The HPU Office of Sponsored Projects (OSP) and the Office of Financial
Aid endeavor to follow all applicable reporting regulations and guidance mandated for federally funded
grant and contract programs. The HEERF awards were fully expended as of June 30, 2022 for the Student
Portion and as of September 30, 2022 for the Institutional Portion. Should similar programs become
available in the future, management will develop, in advance of expending funds, documented policies and
procedures to administer the program and will maintain documentation demonstrating compliance with
program requirements and related institutional policy and procedure.