The Institution acknowledges the finding regarding the late submission of the No Cost Extension (NCE) for HEERF Student Aid funds, which resulted in the ED not approving the extension and subsequently categorizing the $41,146 in distributions to 13 students as unallowed activities.
The delay in submitting the NCE request was due to limited guidance and a lack of awareness regarding the June 30, 2023, filing deadline. The Institution relied heavily on the Program Management Analyst for HEERF-related guidance, and amid the evolving nature of HEERF regulations, the deadline was not effectively communicated or acted upon in time. We accept responsibility for this oversight and are committed to ensuring full compliance with all future grant-related requirements.
1. Coordination with ED for Resolution & Fund Return Process: The Institution will proactively engage with the U.S. Department of Education (ED) to determine the proper process for returning the $41,146 in overdistributed HEERF Student Aid funds. We will promptly comply with any official request from ED regarding the return of funds, ensuring timely resolution of this issue. A designated financial aid compliance officer will oversee communication with ED to track all requirements and submission deadlines.
2. Strengthening Grant Compliance Procedures: A compliance checklist will be introduced for all future grant performance period extensions to ensure deadlines are met well in advance. The Institution will implement a Grant Compliance Tracking System to monitor:
a. Key deadlines for grant extensions, reporting, and compliance filings.
b. Required actions for all active federal grant awards to ensure timely submissions.
3. Enhanced Staff Training & Internal Oversight: The Institution will provide training to financial aid and grant management staff on:
a. Federal grant regulations and performance period compliance.
b. How to track and process NCE filings in a timely manner.
c. Best practices for engaging with ED to ensure compliance and funding oversight.
Staff will also undergo annual refresher training on Title IV and HEERF grant compliance.
4. Improved External Communication & Regulatory Monitoring
a. The Institution will establish direct communication channels with ED representatives and external regulatory advisors to ensure awareness of any changes in grant policies,
extensions, and reporting requirements.
b. Monthly compliance review meetings will be held internally to verify that all federal grant deadlines are on track.
By implementing these corrective actions, the Institution is confident that future federal grant extensions and reporting requirements will be met on time, ensuring continued compliance with all federal funding regulations. We appreciate the recommendations provided and are committed to maintaining strong financial oversight and accountability.
Personnel Responsible for Implementation: Danielle Skinner
Position of Responsible Personnel: President
Expected Date of Implementation: Immediate