Finding Text
Finding 2023-002 – COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Fund Reporting
Repeat Finding: No
Federal Program Title – U.S. Department of Education
Pass-Through Entity: Illinois Community College Board
COVID-19 Education Stabilization Fund
Higher Education Emergency Relief Fund (HEERF)
COVID-19: HEERF Institutional Portion: 84.425F
COVID-19: HEERF Minority Serving Institutions (MSI): 84.425L
Federal Award Year 2022-2023
Condition
The College did not publicly post a certain required report timely. The following instance of noncompliance was identified:
• HEERF Institutional Portion and MSI: The College posted a report to their website on October 23, 2023, for the period of April 1, 2023 – June 30, 2023, which was 110 days after the required deadline of July 10, 2023.
Criteria
There are three components to reporting for HEERF: (1) public reporting on the (a)(1) Student Aid Portion; (2) public reporting on the (a)(1) Institutional Portion, (a)(2), and (a)(3) subprograms, as applicable; and (3) the annual report.
The institutional quarterly portion reporting requirements involve publicly posting completed forms on the College’s website. The forms must be conspicuously posted on the College’s primary website on the same page the reports of the College’s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted.
A new, separate form must be posted covering aggregate amounts spent for HEERF I, HEERF II, and HEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after an institution has expended and liquidated all (a)(1) Institutional Portion, (a)(2), and (a)(3) funds and checks the “final report” box. The College must post this quarterly report form no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, July 10).
2 CFR Section 200.303 requires entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure the timely and accurate posting of reports.
Questioned Costs
There were no questioned costs with respect to this finding.
Cause
The College mistakenly overlooked the timely submission of the last quarterly report as this was the end of the grant period.
Prevalence
Infrequent. 4 quarterly reports and 1 annual report were required to be submitted in fiscal year 2023 relative to HEERF Institutional and MSI. 1 quarterly report was not published timely.
Effect
The untimely submission of reports is noncompliance with the requirements of the grant award and could result in loss of funding or other penalties.
Recommendation
We recommend the College implement monitor their internal controls to ensure reports are posted timely.
Views of responsible officials
We agree with this finding. See corrective action plan.