Finding Text
Finding 2023-007 – COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Fund Annual Reporting
Repeat Finding: Partial
Federal Program Title – U.S. Department of Education
COVID-19 Education Stabilization Fund
Higher Education Emergency Relief Fund (HEERF)
COVID-19: HEERF Institutional Portion 84.425F
Federal Award Year 2022-2023
Condition
City Colleges did not accurately report certain information required in the calendar year 2022 annual report. The following instances of noncompliance were identified:
• HEERF Institutional Portion: City Colleges submitted the annual report for Olive Harvey for the period of January 1, 2022 – December 31, 2022 which did not reconcile to the underlying expense detail as of the date of the report. The difference was $234,118 which was a result of a figure being double counted in the total.
• HEERF Institutional Portion: City Colleges submitted the annual report for Malcolm X for the period of January 1, 2022 – December 31, 2022 which did not reconcile to the underlying expense detail as of the date of the report. The difference was $5,580,216 which was a result of a figure being double counted in the total.
Criteria
The Department of Education requires the submission of a “Higher Education Emergency Relief Fund (HEERF) I, II, & III Annual Performance Report” to be submitted on a calendar year basis. The third annual report covered the period of January 1, 2022 – December 31, 2022 and was due in March 2023.
2 CFR Section 200.303 requires entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure the timely and accurate posting of reports.
Questioned Costs
There were no questioned costs with respect to this finding.
Cause
City Colleges did not have effective internal controls in place to ensure reports were submitted accurately. Reports were reviewed prior to submission but those reviews were not precise enough.
Prevalence
Infrequent. 35 reports were required to be submitted in fiscal year 2023 relative to HEERF Student, Institutional, MSI and Annual reporting. 2 reports contained 1 field that was inaccurate.
Effect
The submission of inaccurate reports is noncompliance with the requirements of the grant award and could result in other penalties.
Recommendation
We recommend City Colleges implement internal controls to ensure reports are submitted accurately for the final annual report that is anticipated to be due in early 2024.
Views of responsible officials
We agree with this finding. See corrective action plan.