Finding Text
2022-002 HEERF Activities Allowed or Unallowed U.S. Department of Education Program Education Stabilization Fund (ESF) Subprograms Section COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Aid portion (ALN 84.425E) COVID-19 Higher Education Emergency Relief Fund (HEERF) Institutional Aid portion (ALN 84.425F) Federal Award Year: 2021?2022 Condition: While testing activities allowed or unallowed in the audit of the 2020-2021 award year, we noted that there was a lack of a written plan to provide objective criteria for the distribution of funds until April 2022. Criteria: Per 2 CFR part 200 appendix XI, the School was required to have a documented plan to distribute funds to students. Per 2 CFR part 200.334, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report...as reported to the Federal awarding agency." Cause: Individuals involved in preparing the student award distribution plan were unaware of the requirement that the plan be documented and that the plan be retained by the School. Effect: Effective internal control over activities allowed or unallowed was not established and maintained. There is the potential that future grant funding could be lost due to noncompliance with the award requirements. Prevalence: Applies to the entire HEERF program. Questioned costs: None. Repeat finding?: Yes Recommendation: Management should establish and maintain controls over activities allowed or unallowed. View of responsible officials of the auditee: Management agrees with this finding.