Finding 45222 (2022-001)

2022 ? 001 Federal Agency: Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425E, 84.425F Award Period: July 01, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for the Higher Education Emergency Relief Fund (HEERF): 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: During our testing of HEERF reporting requirements on the System, we noted: 1) Noncompliant Student Reporting: University of New Hampshire ? Two of the two quarterly reports tested did not have supporting documentation that agreed to the number of emergency grant eligible students and number of emergency grant recipients. ? One of the two quarterly reports tested included total emergency grant amounts for a six month period instead of only the quarter period being reported. Keene State College ? One of the one quarterly reports tested did not have evidence to support the date of upload to the College?s website. 2) Noncompliant Institutional Reporting: University of New Hampshire ? One of the one quarterly reports tested had HEERF Institutional Portion award totals that did not match the award amounts from the Grant Award Notifications. Keene State College ? One of the two quarterly reports tested was published to the College?s website outside of the 10-day timeframe requirement. Plymouth State University ? One of the one quarterly reports tested was published to the University?s website outside of the 10-day timeframe requirement. Granite State College ? One of the one quarterly reports tested had HEERF Institutional Portion award totals that did not match the award amounts from the Grant Award Notifications. 3) Noncompliant Annual Reporting: University of New Hampshire ? One of the one annual reports tested did not have supporting documentation that could corroborate all student count and student emergency grant totals. Keene State College ? One of the one annual reports tested did not have supporting documentation that agreed to the number of student emergency grant recipients. Granite State College ? One of the one annual reports tested had incorrect totals reported in the Student Portion provided directly to students reporting area. 4) Lack of Documentation of Review: University of New Hampshire Keene State College Plymouth State University Granite State College Context: The Colleges and Universities did not have a centralized process to successfully track the reporting requirements. In addition, there was a general lack of guidance from the Department of Education on reporting requirements. This led to the various issues noted above within the reports tested. Cause: The policies and procedures of the Universities and Colleges did not ensure that grant reporting compliance requirements were timely and accurately met or corroborated by supporting documentation. Questioned Costs: None Possible Asserted Effect: The documentation doesn?t support the numbers reported on the website and therefore the amounts reported on the website could be inaccurate. Repeat Finding: Yes, 2021-001 Auditor?s Recommendation: We recommend the Universities and Colleges maintain the documentation used during the reporting process to support the numbers included in the public reporting on their website as well as maintain the formal documentation of the review and approval process that the reports go through during preparation. Views of Responsible Officials: There is no disagreement with the audit finding.