Finding 2022-002: Significant Deficiency - COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds Reporting Program: COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds Assistance Listing Number: 84.425E and 84.425F Federal Agency: U.S. Department of Education Federal Award Identification Number: P425E201560 and P425F201058 Federal Award Year: June 30, 2022 Repeat Finding: 2021-002 Criteria: The U.S. Department of Education (the Department) has issued guidance for the Education Stabilization Funds (ESF) Higher Education Emergency Relief Funds (HEERF) for quarterly reporting for all sections (a)(1), (a)(2), (a)(3) and (a)(4) that requires that institutions to prepare a report for each quarter for funds t11at are drawn down and disbursed/spent. The reports are to be posted on the institution's website within 10 days of the calendar quarter end. Additionally, institutions are required to prepare an annual report and submit to the Department summarizing the uses of the HEERF funds for the calendar year. Condition/Context: Incorrect data was reported in two institutional portion quarterly reports and the annual report. Three student portion quarterly reports were not posted to the University's website. One student portion quarterly report and two institution quarterly reports were posted to the University's website after the 10 days after quarter end requirement. The annual report was also submitted late. The auditor selected a sample of one student portion quarterly report and two institutional portion quarterly reports in addition to the annual report. The sample was not a statistically valid sample. Questioned Costs: Not applicable. Cause: The University's internal control surrounding preparing, reviewing and posting the reports did not deter or prevent errors in the reporting or late or missing posting of the quarterly reports to the University's website. The University noted there was confusion and misunderstanding on the HEERF reporting requirements including deadlines and whether reports were to be cumulative or not. Effect: The University had HEERF quarterly reporting on its website and annual reporting to the Department that were missing and/or incorrect and/or late. Recommendation: The University should ensure it keeps up to date on the Department's HEERF guidance and ensure that reporting is done accurately and timely. Management's Response: The University concurs with the finding. The University experienced challenges during COVID limiting the availability of resources to review and adequately analyze the reporting guidance as it developed. As a result, there were some misunderstanding of the requirements as they changed over time. Tl1e University continued to experience challenges with staffing in 2022 that limited the availability of resources to address the past and current reporting issues. The University will assign more resources to address all reporting issues including updating the website, revising and resubmitting past reports, and submitting missing reports. In accordance with the corrective action plan, additional resources have been allocated to review all reporting requirements, revise existing reports as needed and submit missing reports. Anticipated completion date: December 31, 2023 Contact: Mary Woolfolk (Controller) at 949-214-3123