Finding 2022-002: Information on the Federal Program: 84.425F-Higher Education Emergency Relief Fund - institutional Portion Compliance Requirement: Reporting Type of Finding: Significant Deficiency Criteria: The objective of the Higher Education Emergency Relief Fund (HEERF) program is to use HEERF grant funds to "prevent, prepare for, and respond to coronavirus" through grants to eligible institutions. There are three components to reporting for HEERF: (1) public reporting on the (a)(l) Student Aid Portion; (2) public reporting on the (a)(!) Institutional Portion, (a)(2) and (a)(3) programs, as applicable; and (3) the annual report. Beginning on May 6, 2020, U.S .. Department of Education (ED) required institutions that received a HEERF I 8004(a)(l) Student Aid Portion award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter (by posting a new report). This was announced through an electronic announcement (EA). On August 31, 2020, ED revised the EA by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Grantees posting a 45-day report on or after August 31, 2020, should instead post a report every calendar qua1ter, with the first calendar quarter repo1t due by October 10, 2020, and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. 42 Sections I 8004(a)(l) Institutional Portion, (a)(2), and (a)(3) Quarterly Public Reporting must be conspicuously posted on the institution's primary website on the same page the reports of the Institution of Higher Education (IHE)'s activities as to the emergency financial aid grants to students made with funds from the IHE' s al location under Section 18004( a)( I) of the CARES Act (Student Aid Portion) are posted. A new, separate form must be posted covering each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after either (1) posting the quarterly report ending September 30, 2022, or (2) when an institution has expended and liquidated all (a)(l) Institutional Portion, (a)(2), and (a)(3) funds and checks the "final report" box. IHEs must post this quarterly report form no later than 10 days after the end of each calendar quarter (October I 0, January I 0, April l 0, July I 0) apa1t from the first report, which is due October 30, 2020. In addition, repo1ting requirements to ED state that the institutional portion of HEERF is reported by Quarter and should not be cumulative. Condition: Jacksonville College did not post the quarterly report for Quarter 1 ending on March 31, 2022 for the institutional portions that were expended. The institutional quarterly reports for the quarters ending June 30, 2022, September 30, 2022, and December 31, 2022 contained amounts that were inconsistent with the amount of funds expended. Context: Management's review control over its reporting requirements for HEERF was not operating at a level of precision to ensure accurate reporting. As such, certain data reported on HEERF was not accurate or timely. Questioned Costs: $0 Cause: The College did not properly review the reporting requirements or grant expenditures in a timely manner. Effect or Potential Effect: Jacksonville College did not report correct amounts to the Department of Education. Repeat Finding: Not a repeat finding. Recommendation: The College should develop written procedures for posting the quarterly reports to the College webpage in a timely manner. In addition, the College should implement procedures to periodically review expend itures for grant requirements and reconcile the grant expenditures to the quarterly reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This deficiency was due to the transition of key personnel during the period that COVID reporting was required. All reports have been corrected with the final report being checked appropriately and posted to the website. Many of these adjustments were due to extensive discounts that were awarded to students, keeping in line with our mission as a faith-based college. Future issues of non-compliance will be prevented by providing retention incentives for current employees while also requiring more careful documentation of the reporting requirements for special programs such as HEERF. This will create a list of written policies that will be maintained 43 on the prope1ty. Finally, cross-training will ensure that all personnel have someone trained in case of a vacancy.