Finding Text
Reference Number 2023-002
Finding: Reporting
Federal Assistance Listing Number 84.425E & 84.425F - Higher Education Emergency Relief Fund (HEERF) Student Aid Portion & HEERF Institutional Portion
Department of Education
Award Number – P425E201050, P425F202411, P425L200337
Award Year 2023
Criteria: The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law on March 27, 2020 and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to Alliance University and Subsidiary (the University) under the Higher Education Emergency Relief Fund (HEERF) Program. The Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA), was signed into law on December 27, 2020, and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. Under the requirements of the HEERF program there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report.
Condition: The reporting frequency of the University’s required Student Aid and Institutional quarterly portion reporting requirements were not consistent with the existing federal requirements. Additionally, one out of the four quarterly Student Aid and Institutional Portion reports were made publicly available on the University’s website.
Context: Four out of the eight required quarterly Student Aid and Institutional reports for fiscal year 2023 were tested to determine whether the reports were posted on the University’s website by the federal due dates and complied with federal regulations.
Effect: The University and federal oversight agencies, including the Department of Education, depend on accurate reports posted to the institution's website to measure program results and compliance with federal requirements and to provide transparency. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the grant award notification.
Cause: Though the University had established internal controls in place to ensure it complied with the HEERF grant reporting requirements, due to turnover in key management, the procedures and controls in place for the required quarterly reports to be prepared, reviewed for accuracy, and be publicly posted within federally required timeframes, was not performed. Additionally, the University did not have adequate cross-training in place to ensure that reporting requirements were met after turnover occurred during the fiscal year.
Identification as a Repeat Finding: Not applicable.
Recommendation: We recommend that the University strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund reporting requirements and to develop policies and procedures for staying abreast of the specific reporting requirements.
Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.