Finding Text
Finding No.: 2021-017
Federal Agency: U.S. Department of Education
AL Program: 84.425 Education Stabilization Fund
AL Sub-Program: 84.425E Higher Education Emergency Relief Fund (HEERF) - Student Aid Portion
Federal Award No.: COVID-19 P425E204126
AL Sub-Program: 84.425F HEERF - Institutional Portion
Federal Award No.: COVID-19 P425F202732
AL Sub-Program: 84.425L HEERF - Minority Serving Institution
Federal Award No.: COVID-19 P425L200219
Area: Reporting
Questioned Costs: $0
Criteria: Annual Reporting - Per OMB Compliance Supplement Addendum July 2021, the HEERF Data Collection Form (OMB Control Number 1840-0850) must be submitted to ED via the Annual Report Data Collection System on February 8, 2021 (for reporting period from March 13, 2020 through December 31, 2020). Furthermore, amounts and data reported in the report should be accurate.
Quarterly Public Reporting for (a)(1) Student Aid Portion - Per OMB Compliance Supplement Addendum July 2021, institutions that received a HEERF 18004(a)(1) Student Aid Portion award are required to publicly post certain information on their website no later than 30 days after award and update that information every 45 days thereafter. On August 31, 2020, the frequency of reporting after the initial 30-day period was decreased from every 45 days thereafter to every calendar quarter. On May 13, 2021, ED published an additional notice for student aid public reporting under CRRSAA and ARP, which requires that institution publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than 30 days after the publication of the notice or 30 days after the date ED first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later. The report must be updated no later than 10 days after the end of each calendar quarter.
Quarterly Public Reporting for (a)(1) Institutional Portion and (a)(2), and (a)(3) funds - Per OMB Compliance Supplement Addendum July 2021, Quarterly Budget and Expenditure form must be conspicuously posted on the institution’s primary website on the same page the reports of the IHE’s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. The form must be posted covering each quarterly reporting period no later than 10 days after the end of each calendar quarter.
Condition:
1. Total annual expenditures per the Annual Report Data Collection System differ from cumulative expenditures from the date of award through 12/31/20 per underlying accounting records, as follows:
2. ALN 84.425E COVID-19 HEERF-Student Aid Portion
A. For both quarterly reports tested, the required quarterly updates were done on an annual basis.
B. Total amount of Emergency Financial Aid Grants distributed to students for the year ended 12/31/2020 per the publicly posted Student Emergency Financial Aid Reporting differ from the annual student aid portion expenditures per underlying accounting records, as follows:
C. Total amount of Emergency Financial Aid Grants distributed to students for the year ended 12/31/2021 per the publicly posted Student Emergency Financial Aid Reporting differ from the annual student aid portion expenditures per underlying accounting records, as follows:
3. 84.425F COVID-19 HEERF-Institutional Portion
84.425L COVID-19 HEERF-Minority Serving Institution
A. Quarterly Budget and Expenditure reports were publicly posted beyond the 10-day posting requirement after the end of each calendar quarters as follow:
B. Total quarterly expenditures for the quarter ended 06/30/2021 per the publicly posted Quarterly Budget and Expenditure Reporting differ from the quarterly expenditures per underlying accounting records, as follows:
Cause: The College lacks adequate internal controls over the timely and accurate preparation and review of required reports as stipulated in the Compliance Supplement.
Effect: The College is in noncompliance with applicable reporting requirements. No questioned costs are presented as the identified reporting differences do not represent overpayments, and we are unable to quantify the impact of late reporting on the program.
Identified as a Repeat Finding: 2020-008
Recommendation: College management should strengthen controls so that required reports are timely and accurately prepared and reviewed and submitted within the specified timeframes to evidence compliance with applicable reporting requirements.
Views of Auditee and Corrective Action Plan: The College agrees with the finding and provides details in its Corrective Action Plan.