Finding Text
Quarterly Reporting of Emergency Financial Aid Grants to Students and Annual Reporting for COVID-19 Education Stabilization Fund
Type of Finding - Noncompliance with Reporting compliance requirements and material weakness in internal control over compliance
Program: COVID-19 Education Stabilization Fund
Assistance Listing Number: Education Stabilization Fund 84.425
Federal Agency: U.S. Department of Education
Criteria - In accordance with 86 FR 26213, institutions are required to publicly post certain information on their website. Institutions must publicly post their report as soon as possible, but no later than thirty days after May 13, 2021 or thirty days after the date the U.S. Department of Education first obligated funds under the Higher Education Emergency Relief Fund (HEERF) I, II, or III to the institution for emergency financial aid grants to students, whichever comes first. The report must be updated no later than ten days after the end of each calendar quarter.
The U.S. Department of Education developed the referenced HEERF data collection form to collect information regarding expenditures under sections 18004(a)(1), 18004(a)(2), and 18004(a)(3) of the CARES Act. Grantees are required to utilize the form to satisfy annual reporting requirements.
Condition - The College did not publicly post a report covering emergency financial aid grants to students within the ten day time limit for the quarters ending March 31, 2023 and June 30, 2023.
The College submitted the Higher Education Emergency Relief Fund (HEERF) data collection form (OMB No. 1840-0850) developed by the U.S. Department of Education for the period January 1, 2022 through December 31, 2022. The submitted form contained errors within the report regarding the number of non-Pell and Pell grant recipients who received a portion of the HEERF student aid and the amount of HEERF student aid portion disbursed to students.
Cause - A material weakness in internal controls over compliance exists relating to reporting. The individual responsible for reporting compliance did not have sufficient understanding of the reporting compliance requirements and there were no monitoring controls to ensure reporting was being done in accordance with the compliance requirements. Internal controls over compliance should be sufficient to ensure accurate and timely reporting with requirements.
Effect - Institutions that have not met the reporting requirements as communicated by the Department of Education may be subject to enforcement actions, up to and including being determined to be ineligible for certain other HEERF program funding.
Expenditures reported in the HEERF data collection form were incorrect resulting in inaccurate data reported to the U.S. Department of Education.
Questioned Costs - Not applicable.
Context - The institution did not publicly post two of the four required quarterly reports within the ten day requirement from quarter-end. The two reports filed untimely were filed twenty-five and twenty-six days from quarter-end.
The institution reported the information to the Department of Education timely, however, the number of HEERF student recipients that are undergraduate full-time pell grant recipients was reported incorrectly. The number of students reported on the data collection form was 187, but the College incorrectly excluded fifteen additional students and the number reported should have been 202. This caused other data points on the form to be misrepresented as well, as they were calculated using the incorrect listing of students.
Identification as a Repeat Finding - The College had a similar finding for the year ended June 30, 2022 identified as finding 2022-003. Recommendation - Provide personnel additional training on the reporting requirements under CRRSAA and ARP as communicated by the Department of Education. Refine the processes and internal controls surrounding compliance with reporting to ensure information is reported timely and accurately. This should include a review of the prepared reports and monitoring of compliance with the requirements.
We recommend the College provide education on the annual reporting requirements to personnel involved in the preparation and review of the HEERF data collection form. We also recommend management utilize the correction period communicated by the U.S. Department of Education to submit corrections for the annual report.
Views of Responsible Official - Management concurs with the findings and is in the process of reviewing policies and procedures to comply with the requirements.