Finding Text
2023-004 – Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance
Department of Education
Federal Assistance Listing Number: 84.425E, 84.425F, 84.425L
Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion, Higher Education Emergency Relief Funds (HEERF) Institutional Portion, Higher Education Emergency Relief Funds (HEERF) Minority Serving Institutions (MSIs)
Federal Award Number: P425E200777, P425F201298, P425L200234
Award Year: 2022-23, 2021-22, 2020-21
Criteria – Under the Coronavirus Aid, Relief, and Economic Security Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act 314(e) institutions that received funds under HEERF I and HEERF II are required to submit a report to the secretary on how the school used its HEERF funds. While the American Rescue Plan did not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329.
Condition/context – A sample of 5 special reports from the population of 5 special reports was selected. Two of the quarterly reports were not posted timely. In addition, the University could not provide consistent institutional records for the data included in the reports nor could they provide support that the reports were reviewed prior to posting. Three of the four quarterly reports were corrected based on the audit procedures performed, the University did not properly identify these as “corrected” upon posting to the University website.
Our sample was not, and was not intended to be, statistically valid.
Questioned costs – None.
Cause/effect – Due to the turnover in the business office, the University did not post its quarterly reports timely and was unable to provide consistent institutional records for the data included in the reports or documented review of the reports prior to posting. The lack of support for data reported and documented review results in a material noncompliance with the reporting compliance requirement.
Repeat finding – Yes, 2022-005
Recommendation – We recommend the University update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report. We recommend each report be posted to the University’s website on separate documents by quarter and should not be cumulative. We also recommend the University implement a process to ensure the submission dates and publication dates are maintained to ensure compliance with the reporting due dates and that the data submitted in the reports is properly supported by institutional records. Lastly, we recommend each report be properly reviewed by someone other than the preparer and that the review be documented with a signature and date.
Views of responsible officials and planned corrective actions – Heritage University will update the previously posted reports to accurately reflect the actual expenditures during FY21, FY22 & FY23 on the University’s website by quarter. Going further, it will be the Grant accountant’s practice that the submission dates and publication dates are maintained and documented with reporting due dates. All documents will be reviewed and approved by the VP of Administration/CFO with dated signatures.