Finding Text
Criteria: Recipients of HEERF funding must acknowledge that it may not condition the receipt of an
emergency financial aid grant on continued or future enrollment with the Recipient. Recipients also
acknowledge that it may not require a student to consent to the application of the emergency financial aid
grant to the student’s outstanding account balance as a condition of receipt of or eligibility for an emergency
financial aid grant funding. The recipient also acknowledges that adding preconditions to receiving a
financial aid grant that thwart this requirement may be subjected to oversight and corrective action. In
consideration for this award, Recipients agree that they hold these grant funds in trust for students and act in
the nature of a fiduciary for students.
Condition: We tested 36 students receiving student aid to verify that students had been notified of their
award, received the funds directly and funds were applied as student requested on their signed and dated
HEERF Notification and Authorization Form. Of the 36 tested 10 had issues. For 3 students, their account
was credited for the award, and they had authorized payment by check; For 7 students, there was no form
found directing how funds should be disbursed to them from VUU.
Cause: Weak processes and controls over the notification of students of their award and distribution of awards
based on student’s authorization/instruction.
Effect: Potential issues with the Department of Education regarding noncompliance.
Questioned costs: $-0-
Perspective information: These findings relate to the inappropriate distribution of awards to student
accounts when students had instructed that their award not be posted to their student’s account and authorized
they be made by check. For the other students the funds were posted to the student accounts and there was no
evidence of authorization from the student.
Identification of repeat findings: Not a repeat finding.
Recommendation: The University should increase its efforts to ensure that major program compliance
requirements are understood, and controls are implemented to ensure compliance.
Views of responsible officials: See Client’s Corrective Action Plan.