FINDINGS AND QUESTIONED COSTS - FEDERAL AWARDS PROGRAM 2022-001 Higher Education Emergency Relief Fund (HEERF) Institutional Portion Assistance Listing Number: 84.425F Criteria According to the Department of Education Higher Education Emergency Relief Fund III Frequently Asked Questions (FAQs) question 26, institutions may discharge student debt or unpaid balances by discharging the complete balance of the debt as lost revenue and reimbursing themselves through their HEERF institutional grants or by providing additional emergency financial grants to students (with their permission). This is available for the institutions for students who were enrolled in an institution at any point on or after March 13, 2020. Condition There was a lack of review procedures that led to not adhering to the HEERF requirements. Context A portion of HEERF institutional grant funds was improperly used to discharge student debt and/or unpaid balances, including debt and/or unpaid balances of students that were enrolled prior to March 13, 2020. Cause Insufficient monitoring of grant rules and regulations. Effect Lost revenue was calculated using an alternative method that fit within the regulations. Questioned Cost There were no questioned costs related to this finding. Recommendation We recommend that the University closely monitor all grant requirements and ensure that there are proper review processes in place to catch any potential noncompliance. Planned Corrective Action The Fiscal Staff will review and recommend to reduce / inactivate the number of accounting classifications that are no longer used, and therefore the chart of accounts will be more streamlined. The new chart of accounts will then be deployed without the same unnecessary legacy monthly closing protocols. Existing fiscal staff will now have more bandwidth to help with monthly analysis and accounting close protocols. Implementation Date Effective date: 7/1/23 for fiscal year 2024. Responsible Personnel Arlene Cash Interim Vice President for Enrollment Management awcash@ndnu.edu