Finding Text
Criteria or specific requirement: Per the Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. In accordance with section 2003 of the American Rescue Plan Act of 2021 (ARPA) (Pub. L. 117-2) (supplemental award or grant) by the U.S. Department of Education and section 2003 of the ARPA and section 314 of the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) (Pub. L. 116-260), recipients must promptly and timely provide a detailed accounting of the use and expenditure of the funds provided by these supplemental award in such manner and with such frequency as the Secretary may require. There are three required components: 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 (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: During our reporting testing, we noted that there were elements of the student quarterly reporting, institutional quarterly reporting, and annual reporting that were not accurate. Questioned costs: N/A Context: We tested two of the four required quarterly student reports, two of the four required quarterly institutional reports, and the required annual report. Noncompliance on each report is below: Student Quarterly Reporting ? On both reports tested, the University reported total amount and count of emergency financial aid grants distributed cumulatively based on appropriation, not on a quarterly basis, as prescribed. Non-Compliant Institutional Quarterly Reporting. ? One of the two reports tested was an estimate of expenses incurred instead of being updated for actual expenses in the preceding quarter. Non-Compliant Annual Reporting ? The total amounts of emergency financial aid grants disbursed directly to students and applied to satisfy student's outstanding account balances on the 2021 Annual Report were incorrect. Cause: The policies and procedures of the University did not ensure that grant reporting requirements were accurately met. Effect: The University was not in compliance with HEERF reporting requirements. Repeat finding: No Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. View of responsible official: The University agrees with the finding.