Finding Text
Finding 2023-012 – A. Activities Allowed or Unallowed
Information on Federal Program(s) – COVID-19 Education Stabilization Fund (ALN 84.425F)
Criteria or Specific Requirement - The American Rescue Plan (“ARP”) established two new required uses of HEERF III institutional portion grant funds for public and private nonprofit institutions in which a portion of funds must be used to: (a) implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances.
Condition – The University did not use any portion of its HEERF III institutional funds to conduct direct outreach to financial aid applicants.
Cause - Administrative oversight and insufficient internal control.
Effect or Potential Effect – Noncompliance with required uses of grant funds.
Questioned Costs – None.
Context – As the University’s Institutional Portion grant was not used entirely for emergency financial aid grants to students, a portion of the funds must have been used to conduct direct outreach to financial aid applicants.
Indication of Repeat Finding - This is a repeat of prior year Finding 2022-009.
Recommendation – We recommend that the University enhance procedures and internal controls to ensure adherence with all federal grant terms and conditions.
Views of Responsible Officials – The University acknowledges that the COVID-19, American Rescue Plan Act funds were not spent in the correct manner. There was a lack of administrative oversight relating to the receipt and expenditure of the ARP HEERF III funds. All members of the business department have been made aware of the importance of tracking all funds especially those relating to government grants. The University has determined that any government grants over a certain threshold will be placed in a sperate bank account until it is time for them to be spent. This will eliminate the possible of the funds be misappropriated or comingled with general University funds. Any contracts related to government grants will be filed both electronically and via hard copy. The senior accountant will review any grant contracts to be aware of the purpose of the funds. Any expenditures from federal grants including HEERF will be documented and journaled on the general ledger in accordance with the department and object code expense deemed appropriate.