Finding Text
Assistance Listings number and name: 84.425E COVID-19 - Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Student Portion Award numbers and years: P425E201812, April 24, 2020 through June 30, 2023 Federal agency: U.S. Department of Education Compliance requirement: Activities allowed or unallowed and allowable costs/cost principles Questioned costs: None Condition?Contrary to federal guidance, the District used emergency financial assistance monies to satisfy the student?s outstanding account balance without obtaining the student?s prior consent to do so for 3 of 30 emergency financial assistance transactions we tested. Specifically, the District misapplied $500 of program monies, for a total of $1,500, to discharge each of these student?s outstanding account balance with the District rather than directly disbursing these monies to the students. However, we noted no questioned costs as a result of this noncompliance since the students were eligible to receive financial assistance monies. Effect?By the District not obtaining a student?s prior consent to discharge their outstanding account balance rather than disbursing the monies directly to the student, the program?s objective to provide students with emergency financial assistance that may be used at the student?s discretion to help defray costs for food, housing, health care, or childcare?in addition to tuition costs?may not be met. Further, the student could face undue financial hardship. Cause?The District did not have a documented process in place to ensure that it obtained a student?s prior consent for applying emergency financial assistance to the student?s outstanding account balance. Criteria?Federal guidance requires the District to obtain a student?s prior written or electronic consent prior to applying emergency financial assistance to discharge the student?s outstanding account balance with the District.1 In addition, the District must establish and maintain effective internal control over federal awards that provides reasonable assurance that it administers federal programs in compliance with all applicable laws, regulations, and award terms (2 Code of Federal Regulations [CFR] ?200.303). Recommendations?The District should: 1. Develop and implement written policies and procedures to ensure the District obtains each student?s written or electronic consent prior to applying any emergency financial assistance to the student?s outstanding account balance. 2. For those instances in which the District misapplied emergency financial assistance to students? outstanding account balances, determine if the students agree with the discharge of the outstanding account balances or want direct payment of those monies and make any necessary adjustments. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 U.S. Department of Education. (2021). Higher Education Emergency Relief Fund III, Frequently Asked Questions, Question 11. https://www2.ed.gov/about/offices/list/ope/arpfaq.pdf