Finding Text
Finding 2022-003 ? Inadequate Controls Over and Compliance with Reporting Requirements Assistance Listing: 84.425 Program Title: Education Stabilization Fund Subprograms: Higher Education Emergency Relief Fund (?HEERF?) Governor?s Emergency Education Relief (?GEER) Federal Agency: Department of Education 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 (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES, CRRSAA, and ARP institutional quarterly portion reporting requirements involve publicly posting completed forms on the institution?s website. The forms must be conspicuously posted on the institution?s primary website on the same page the reports of the IHE?s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. The GEER grant agreement requires quarterly reporting of expenditures to be submitted no later than 30 calendar days following the three month period covered by the report. Condition The HEERF Q2 2022 Institutional Portion report was not posted to the College?s website by the due date of July 10, 2022. The report was posted only after the College was informed by the auditors that it had not been posted. In addition, when comparing the College?s drawdowns and expenditures to the amount reported on the Q2 2022 Student Aid Portion report, a $2,437,286 variance, with drawdowns exceeding the amount reported on the quarterly report, was noted. The drawdowns were accurate with the report amount in error. Quarterly reporting for GEER was submitted late as follows: quarter ending 9/30/21 submitted 100 days late, quarter ending 12/31/21 submitted 101 days late, quarter ending 3/31/22 not submitted. No expenditures were incurred and no report was submitted for the quarter ending 6/30/22. For GEER II, no expenditures were reported for the quarters ending 9/30/21 and 12/31/21 and one report was submitted for both quarters on 2/18/22. In addition, $6,219.49 was reported as expended on the GEER?s 3/31/22 quarterly report and in the general ledger but the amount was never requested for reimbursement. Finally, total expenditures on the two GEER II quarterly reports were $12,069.44 less than total expenditures per the general ledger detail and the schedule of expenditures of federal awards but was ?trued up? in the next reporting period according to College staff. Effect Without sufficient internal controls over grant reporting, the College could submit erroneous grant reports and fail to comply with federal reporting requirements. Cause The failure to timely post the quarterly report on the College?s website appears to have been an oversite. The error in the Student Aid Portion report was a result of some general ledger accounts set up incorrectly causing expenditures to be posted to the wrong account and not included on the report. The GEERs reporting errors appears to be the result of staff turnover. Recommendation The College should implement a process to review grant reporting requirements and grant reports to ensure that they are accurate and that all reporting requirements are consistently followed. Management?s Response The College indicated that employee turnover resulted in multiple people involved in grant reporting during the year and that they intend to hire a grant accountant and implement proper procedures to address the issues.