Finding 451352 (2022-001)

Finding No. 2022-001 ? ReportingAward InformationGrantor: Department of EducationAward Name: HEERF II Institutional GrantsAward Year: 4/19/2021 ? 4/18/2022Federal Assistance Listing Number: 84.425F, HEERF II Institutional GrantsPass Through Number: Not applicableCriteriaQuarterly Public Reporting for (a)(l) Institutional Portion, (a)(2), and (a)(3) funds (Assistance Listings84.425F, 84.425J, 84.425K, 84.425L, 84.425M, 84.425N, 84.425S, as applicable)The CARES, CRRSAA, and ARP institutional quarterly portion reporting requirements involve publiclyposting completed forms on the institution's website.The forms must be conspicuously posted on the institution's primary website on the same page thereports of the IHE's activities as to the emergency financial aid grants to students (Student Aid Portion)are posted.A new, separate form must be posted covering aggregate amounts spent for HEERF I, HEERF II, andHEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30),concluding after 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 daysafter the end of each calendar quarter (October 10, January 10, April 10, July 10) apart from the firstreport, which was due October 30, 2020, and the report covering the first quarter of 2021, which is dueJuly 10, 2021.ConditionYale expended both institutional and student funds received under the Higher Education EmergencyRelief Fund in the form of student grants. Yale reported its institutional expenditures in conjunction withits student expenditures. However, the regulations require a separate report for student and institutionalexpenditures. As a result of the combined reporting, Yale did not publicly post the institutional quarterlypublic report for the quarter ending June 30, 2021 that was due no later than July 10, 2021.Questioned CostsNo questioned costs as the finding is related to a reporting matter.CauseIt was an oversight on management?s behalf regarding the required institutional filing. Managementbelieved that the University complied with its reporting obligation by reporting all of the student grantexpenditures within the required student reports. The University should have publicly posted therequired institutional report and noted that all funds were given to students through grants. EffectThe University did not comply with the requirement to submit the institutional report within 10 days afterJune 30, 2021. Management has subsequently filed the required institutional report.RecommendationWe recommend the University continue to monitor the required reporting requirements related to COVIDrelated funding. As periodic updates are made to the reporting requirements, management shouldensure processes are enhanced to allow for complete and timely filing of all required reports.