Finding Text
Criteria or specific requirement: The student emergency financial aid grant is provided to the student, and may be used by the student for any component of the student's cost of attendance or for emergency costs that arise due to coronavirus, such as tuition, food, housing, health care, or child care. Institutions may not compel a student to use a portion of their grants to satisfy any existing debts or balance. In addition, per the Uniform Guidance 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. Condition: A portion of the HEERF Student Aid Portion funds were awarded to students only if the student signed and returned a letter authorizing the College to use those funds to pay off their account balance for five terms. Questioned Costs: $143,186 Context: We performed testing over 40 disbursements made to students from the HEERF Student Aid Portion disbursements noting 10 of the disbursements were unallowable. The College drew down federal funding from the student portion award to cover the costs incurred. The College also reported the disbursements made on their quarterly reporting. Cause: The College sent letters to students notifying them of available funding and requesting their permission to use the funding for that purpose. The letter indicated the funding would be made from Institution Portion of the HEERF funds. When applying the funds to the student accounts, the College used HEERF Student Aid Portion funds. Effect: The College was not in compliance with allowable costs under the HEERF Student Aid Portion requirements. As a result of this noncompliance, the College incorrectly drew down funds from the HEERF Student Aid Portion and reported unallowed costs on their quarterly reports for the student portion. Repeat Finding: No Recommendation: We recommend the College implement procedures to review HEERF funding sources before applying to expenditures to ensure appropriate application. Views of responsible officials: There is no disagreement with the audit finding.