Finding Text
2023-002 Activities Allowed or Unallowed and Allowable Costs/ Cost Principles
U.S. Department of Education:
Education Stabilization Fund – Higher Education Emergency Relief Fund (HEERF) Student Aid Portion
(ALN 84.425E)
Federal Award Numbers and Years: P425F200214 (4/21/20 – 6/30/23)
Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample.
Prior Year Finding: Not applicable
Finding Type: Material Weakness and Material Noncompliance
Criteria
As it relates to expenditures under the HEERF II and HEERF III (a)(1) Student Aid Portion or for additional
emergency financial aid grants made using other HEERF grant funds, ED required that (1) the institution
had a documented plan to distribute funds to students, (2) that institutions prioritized grants to students with exceptional need, (3) that the institution did not place any restrictions on the expenditure of those funds beyond what is in the statute, above, (4) the institution expended the entirety of the Student Aid Portion grant on Emergency financial aid grants to students, and (5) that the institution did not reimburse itself for any costs or expenses previously issued to students. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program.
Condition and Context
One out of the forty students selected for testwork did not properly fill out an application to ensure they were eligible to receive the HEERF funding through the University. The University’s documented plan outlines that the student must complete an application and then the HEERF award amount would be based on the answers within the application. The University did not properly design internal controls to ensure that all students had completed an application before HEERF awarding.
Cause
The University did not have policies and procedures in place to ensure that all students had completed an application before awarding HEERF funds.
Effect
Ineligible students may have received HEERF awards.
Questioned Costs
There are no known questioned costs related to this finding.
Recommendation
We recommend that the University strengthen its policies and procedures over the student awarding process in relation to the HEERF funds. We also recommend that the University ensure that internal controls are properly designed to ensure compliance with awarding students HEERF funds.
Views of Responsible Official
The University concurs with this finding but cannot respond why the student was awarded outside the of procedure and methodology set up for awarding HEERF Funds. The decisions were made by individuals no longer with the University and no documentation was found to determine why the student was awarded outside the policy in place. The Controller’s Office and Financial Aid Office are working together to make sure that in future funds like the HEERF will have documentation attached to secure that we follow procedure and policy and document any exceptions.