Finding Text
Finding Number: 2022-002 Federal Program: Higher Education Emergency Relief Fund Federal Award Identification Number and Year: N/A Assistance Listing Number (ALN): 84.425F & 84.425E Federal Agency: U.S. Department of Education Pass-through Entity: None Repeat Finding: No Material Weakness & Material Noncompliance ? Reporting Criteria: The U.S. Department of Education (ED) requires all Higher Education Emergency Relief Fund (HEERF) to annually report how HEERF funds were utilized. ED developed the HEERF Data Collection Form that institutions must have used to satisfy the annual reporting requirement for HEERF I. This form collects information about how the school used its CARES Act Section 18004(a)(1), (a)(2), and (a)(3) HEERF I funds. The form was required to be submitted to ED via the Annual Report Data Collection System between April 11, 2022 and May 6, 2022 and applied to the reporting period from January 1, 2021 through December 31, 2021. Additionally, the CARES, CRRSAA, and ARP institutional quarterly portion reporting requirements involve publicly posting completed forms on the District's website. The forms must be conspicuously posted on the District's primary website on the same page the reports of the Institution of Higher Education?s (IHEs) 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, and HEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after an institution has expended and liquidated all (a)(1) 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 days after the end of each calendar quarter (September 30, December 31, March 31, and June 30). Condition: The School District did not include $345,437 of institutional expenditures in the 2021 annual report submitted to ED. The original reporting for the quarterly report were posted timely; however, original reports were determined to be inaccurate and had to be revised after the required due dates and reposted to reflect the corrections. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: While reviewing the annual report for accurate information, noted the institutional expenditures did not agree to the School District?s expenditure ledgers. The original quarterly reports posted to the School District?s website were not accurate. Subsequent revisions were required after the due date for all four quarters and corrected reports were reposted.Cause and Effect: There was significant turnover in management within the financial aid department. This caused confusion regarding procedures and responsibilities within the department, including the specific timing and requirements for the annual and quarterly reporting. The School District did not have procedures in place to ensure that accurate information was included in the annual and quarterly reports. Failure to have procedures in place to complete annual and quarterly reporting requirements accurately may result in the School District being in non-compliance. Recommendation: The School should implement controls and processes to ensure that accurate information is reported on the quarterly and annual reports as required by the grant agreement. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.