Finding Text
Finding 2022-002: Significant Deficiency ? Reporting - Higher Education Emergency Relief Fund Federal Program: COVID-19 Education Stabilization Fund Federal Agency: U.S. Department of Education Pass-Through Entity: Not Applicable Assistance Listing Number (ALN): 84.425E, 84.425F, 84.425L Federal Award Number: P4245F201343, P425E203377, P425L200181 Federal Award Year: May 31, 2022 Criteria: The U.S. Department of Education (the Department) has issued guidance for the Education Stabilization Funds (ESF) Higher Education Emergency Relief Funds (HEERF) for quarterly reporting for all sections (a)(1), (a)(2), (a)(3) and (a)(4) that requires that institutions to prepare a report for each quarter for funds that are drawn down and disbursed/spent. The reports are to be posted on the institution?s website within 10 days of the calendar quarter end. Additionally, institutions are required to prepare an annual report and submit to the Department summarizing the uses of the HEERF funds for the calendar year. Condition/Context: The quarterly and annual reporting contained some information that did not agree to support provided, and some of the quarterly reports were not posted to the University?s website within the required time frame. ? For both the institutional and student portions of the grant, there was no quarterly report for the period ending June 30, 2021. Reporting was posted for the period ending May 31, 2021 which reported the final activities for the second round of HEERF awards. There were drawdowns that occurred during the month of June 2021 for both portions of the third round of HEERF funding that were incorrectly included in the September 30, 2021 quarterly reports. ? The University?s institutional portion quarterly report for September 30, 2021 reported the total for only lost revenue from auxiliary sources and this did not agree to support provided. ? The 2021 annual report had some information that did not agree to the underlying support provided by the University. Specifically, the total for lost revenue and the total for other uses, and the required two new uses (direct outreach and monitoring and suppressing) were not reported although the support file provided did include costs for those items. Cause: The University?s control surrounding preparing, reviewing and posting the reports did not deter or prevent errors in the reporting or not posting of the quarterly reports to the University?s website. Additionally, the University?s supporting files did not agree to the information reported. Effect: The University?s student and institutional portion reports contained some information that was cumulative and not quarterly as required and the institutional portion and annual report contained some information that was not accurate. Additionally, two of the required quarterly reports were not posted to the University?s website. Questioned Costs: Not applicable Recommendation: The University should put into place policies and procedures ensure compliance with federal grant reporting requirements, including completing required reports accurately and timely. It is suggested that the University revise the reports posted to ensure completeness and accuracy for each required quarterly report (both student and institutional). Management?s Response: Management recognizes the significant deficiency, yet stands firm that that the guidance (FAQs, webinars, web posting, templates) for the HEERF reporting by the US Department of Education was confusing, contradictory, and ever-evolving. Management did its best to follow the reporting requirements, and as a result, will implement new practices to address this matter going forward.