Finding 52441 (2022-006)

Significant Deficiency
Requirement
B
Questioned Costs
$1
Year
2022
Accepted
2023-01-11
Audit: 52798
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: The College awarded emergency grants to students who may not have been eligible, as they were not enrolled on or after March 13, 2020.
  • Impacted Requirements: Compliance with federal guidelines for disbursing HEERF funds, specifically the requirement that grants be given only to eligible students.
  • Recommended Follow-up: The College should establish a process to properly document and verify student eligibility for HEERF aid before disbursement.

Finding Text

2022-006 Federal Agency: U.S. Department of Education Pass-through Entity: Oregon Higher Education Coordinating Commission (84.425C) Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Pass-through Grant Number: 20-075M Program Name: Education Stabilization Fund Allowable Costs/Activities under Higher Education Emergency Relief Funds (HEERF) Significant Deficiency in Internal Control over Compliance Criteria - For the (a)(1) Student Aid Portion (Assistance Listing 84.425E), disbursements made under the Student Aid Portion are required to be made directly to students. ED?s final rule (Eligibility to Receive Emergency Financial Aid Grants to Students under the Higher Education Emergency Relief Programs, May 14, 2021) on student eligibility for HEERF states that all students who are or were enrolled in an institution of higher education on or after the date of the declaration of the national emergency due to the coronavirus (March 13, 2020) are eligible for emergency financial aid grants from the HEERF, regardless of whether they completed a FAFSA or are eligible for Title IV. The CRRSAA and ARP requires that schools prioritize students with exceptional need, such as students who receive Pell Grants. However, students do not need to be Pell recipients or students who are eligible for Pell grants in order to receive a financial aid grant. Condition ? The College provided emergency grants to students with the student portion of the HEERF funding, but the College could not provide evidence that the student met the definition of ?eligible student?. The emergency grants were used to relieve the delinquent student accounts. There were 5 students identified in our testing that were not ?enrolled in an institution of higher education on or after the date of the declaration of the national emergency (March 13, 2020).? It appears the 5 students were not enrolled at the College on or after March 13, 2020, and the College did not obtain evidence that the students were enrolled on or after this date at another institution of higher education. Cause ? The College did not want to turn away prior students with current financial need based on their enrollment status. This was how management interpreted the guidance from the DOE. Effect - The College may have awarded student HEERF funds to individuals that did not qualify to receive these funds. Questioned Costs ? The known disbursements to individuals that may not be qualified to receive an emergency grant using student funds is $5,983. This known questioned costs extrapolates to a potential ?likely? questioned cost of $29,700 when viewed in relation to the sample and the whole population. Context/Sampling ?The College disbursed aid to 242 students from their HEERF awards in fiscal year 2022. From the total population of student disbursements made in fiscal year 2022, we selected 45 students for testing. Repeat Finding - No Recommendation - The College should implement a process to adequately document their review and approval of students to receive aid under HEERF. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.

Corrective Action Plan

Finding 2022-006 Federal Agency Name: Department of Education Program Name: Education Stabilization Fund ALN 84.425 Finding Summary: The College provided emergency grants to students with the student portion of the HEERF funding, but the College could not provide evidence that the student met the definition of ?eligible student?. The emergency grants were used to relieve the delinquent student accounts. There were 5 students identified in our testing that were not ?enrolled in an institution of higher education on or after the date of the declaration of the national emergency (March 13, 2020).? It appears the 5 students were not enrolled at the College on or after March 13, 2020, and the College did not obtain evidence that the students were enrolled on or after this date at another institution of higher education. Responsible Individuals: Courtney Judah, Director of Institutional Effectiveness Corrective Action Plan: Ongoing training was conducted with Enterprise Management Software support to develop reporting and process steps to prevent reporting errors and improve accuracy for student?s assistance. Prevention to include creation of reports for awards pending and detailed disbursement and reconciliations schedules. Develop ongoing student intervention processes to identify student with emergency financial need. Student Funding Committee formed that processes request includes verification of enrollment, number of credits, and financial aid standing. Committee includes representatives from Financial Aid, Advising, Foundation, and the Business Office. The College has entered into an agreement with a third-party financial aid provider to service and administer financial aid awards, reporting and reconciliation. Contracted services include award packaging, document collection and compliance review, disbursement logs, direct flow of federal funds, account reconciliation and exit process. The added third-party support reduced workload on Financial Aid and allowed for a more proactive engagement with student emergency funding needs. Contacted Department of Education grant administrator for guidance on program requirements and compliance. Completed and will continue to participate in ongoing Department of Education training. Anticipated Completion Date: June 30, 2023

Categories

Questioned Costs Student Financial Aid Subrecipient Monitoring Internal Control / Segregation of Duties Allowable Costs / Cost Principles Eligibility Significant Deficiency

Other Findings in this Audit

  • 42657 2022-007
    Material Weakness
  • 52432 2022-003
    Material Weakness Repeat
  • 52433 2022-004
    Material Weakness Repeat
  • 52434 2022-003
    Material Weakness Repeat
  • 52435 2022-004
    Material Weakness Repeat
  • 52436 2022-003
    Material Weakness Repeat
  • 52437 2022-004
    Material Weakness Repeat
  • 52438 2022-003
    Material Weakness Repeat
  • 52439 2022-004
    Material Weakness Repeat
  • 52440 2022-005
    Significant Deficiency Repeat
  • 52442 2022-007
    Material Weakness
  • 52443 2022-005
    Significant Deficiency Repeat
  • 52444 2022-006
    Significant Deficiency
  • 52445 2022-007
    Material Weakness
  • 52446 2022-005
    Significant Deficiency Repeat
  • 52447 2022-006
    Significant Deficiency
  • 52448 2022-007
    Material Weakness
  • 52449 2022-005
    Significant Deficiency Repeat
  • 52450 2022-006
    Significant Deficiency
  • 619099 2022-007
    Material Weakness
  • 628874 2022-003
    Material Weakness Repeat
  • 628875 2022-004
    Material Weakness Repeat
  • 628876 2022-003
    Material Weakness Repeat
  • 628877 2022-004
    Material Weakness Repeat
  • 628878 2022-003
    Material Weakness Repeat
  • 628879 2022-004
    Material Weakness Repeat
  • 628880 2022-003
    Material Weakness Repeat
  • 628881 2022-004
    Material Weakness Repeat
  • 628882 2022-005
    Significant Deficiency Repeat
  • 628883 2022-006
    Significant Deficiency
  • 628884 2022-007
    Material Weakness
  • 628885 2022-005
    Significant Deficiency Repeat
  • 628886 2022-006
    Significant Deficiency
  • 628887 2022-007
    Material Weakness
  • 628888 2022-005
    Significant Deficiency Repeat
  • 628889 2022-006
    Significant Deficiency
  • 628890 2022-007
    Material Weakness
  • 628891 2022-005
    Significant Deficiency Repeat
  • 628892 2022-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $755,318
93.575 Child Care and Development Block Grant $469,489
84.268 Federal Direct Student Loans $423,894
17.259 Wia Youth Activities $177,822
84.002 Adult Education - Basic Grants to States $156,723
10.855 Distance Learning and Telemedicine Loans and Grants $125,397
17.258 Wia Adult Program $114,475
17.277 Workforce Investment Act (wia) National Emergency Grants $104,573
84.031 Higher Education_institutional Aid $75,998
84.425 Education Stabilization Fund $54,782
84.007 Federal Supplemental Educational Opportunity Grants $53,600
59.037 Small Business Development Centers $47,404
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $34,341
47.076 Education and Human Resources $31,440
21.027 Coronavirus State and Local Fiscal Recovery Funds $30,420
84.033 Federal Work-Study Program $12,549
17.278 Wia Dislocated Worker Formula Grants $11,684