Finding Text
Information on the Federal Program: HEERF Student, Institutional, and HBCU Portion (CFDA Numbers 84.425E, 84.425F and 84.425J) – U.S. Department of Education
Criteria: Federal Register Vol. 85, No. 169 and Vol. 86, No. 91 state that reporting information must appear in a format and location that is easily accessible to the public. This information must be updated no later than 10 days after the end of each calendar quarter. Additionally, HEERF FAQ guidance published by the Department of Education states an Institution can discharge the complete balance of student debt and reimburse themselves through their HEERF grants by reporting the discharge as lost revenue from academic sources in quarterly and annual reporting.
Condition and context: The University does not have the Student Funding Report for the quarter ending June 30, 2021, posted to their website. The Institutional and HBCU portion report for the quarter ended September 30, 2020, was created more than 10 days after the end of the quarter. The Institutional and HBCU portion report for the quarter ended March 31, 2021, was revised in 2022, and the University removed the original version from their website; therefore it cannot be determined if the reporting deadline requirement was met. The University reported discharge of student debt as emergency financial aid grants to students instead of lost revenue from academic sources on the Institutional and HBCU portion report for the quarter ended March 31, 2021.
Questioned Cost: $0
Cause: The University did not have the proper internal controls in place to ensure that all reporting requirements were being adhered to.
Effect: The University is not in compliance with the reporting requirements for HEERF funds specified by the Department of Education.
Recommendation: We recommend the University review all previously submitted reporting documentation and update per the current guidance posted by the Department of Education. The
University should also implement and maintain an effective system of internal controls over the administration of HEERF funds to ensure funds are reported accurately and timely, in accordance with grant requirements.