Finding Text
Improper Reporting of HEERF Funds
Information on the Federal Program: HEERF Student, Institutional, and HBCU Portion (AL Numbers
84.425E, 84.425F and 84.425J) – U.S. Department of Education
Criteria or specific requirement: Federal Register Vol. 85, No. 169 and Vol. 86, No. 91 state that
reporting information must appear in a format and location that is easily accessible to the public.
This information must be updated no later than 10 days after the end of each calendar quarter.
Additionally, HEERF FAQ guidance published by the Department of Education states an Institution
can discharge the complete balance of student debt and reimburse themselves through their HEERF
grants by reporting the discharge as lost revenue from academic sources in quarterly and annual
reporting.
Condition: The report for the quarter ended March 31, 2022, was revised in 2023, and the University
removed the original version from their website. All quarterly reports, excluding the Institutional
report for the quarter ended December 31, 2023, used cumulative totals of grant receipts instead of
quarterly totals.
Questioned Cost: $-0-
Cause: The University did not have the proper internal controls in place to ensure that all reporting
requirements were being adhered to.
Effect: The University is not in compliance with the reporting requirements for HEERF funds specified
by the Department of Education.
Recommendation: We recommend the University review all previously submitted reporting
documentation and update per the current guidance posted by the Department of Education. The
University should also implement and maintain an effective system of internal controls over the
administration of HEERF funds to ensure funds are reported accurately and timely, in accordance
with grant requirements.