Finding Text
Criteria: There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion (Quarterly Student Report); 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Institutional Reports), as applicable; and 3) the annual report (Annual Report). The Coronavirus Aid, Relief, and Economic Security (CARES) Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While American Rescue Plan (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Per the Form Instructions included on the ?Quarterly Budget and Expenditure Reporting for HEERF I, II, and III (a)(1) Institutional Portion, (a)(2), and (a)(3), if applicable? form, the completed form must be conspicuously posted on the institution?s primary website no later than 10 days after the end of each calendar quarter. Additionally, the Form Instructions include that reports must be maintained for at least three years after the submission of the final report. Condition: Management did not provide sufficient documentation to support the data included in the Annual Report, Quarterly Institutional Reports and Quarterly Student Reports. In addition, for one quarter, a Quarterly Institutional Report and a Quarterly Student Report was not retained on the University?s website. Context: Management provided documentation to support the information included in the reports; however, in several instances, the information provided either did not agree to the data included in the reports or it was unclear as to how the information supported the reports. In addition, the Quarterly Institutional Report and Quarterly Student Report for the quarter ended September 30, 2021 was prepared and posted on the University?s website; however, the reports were erroneously removed. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures over reporting for the program were not developed. Additionally, due to staff turnover, information was not retained in a manner that allowed it to be easily retrieved and compiled in a manner supporting the reports. Effect: The reports that were completed could contain inaccurate or incomplete data. In addition, the University was not compliant with the requirement to maintain the reports on the University?s website. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2021-003. Recommendations: As the HEERF Program has ended for the University, we recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to evidence the internal controls. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) and Office of Financial Aid work to follow all federal reporting regulations and guidance mandated for the Federal grant & contract programs. For future programs, the Institutional Research, the Office of Sponsored Projects and the Financial Aid Office will generate the reports and will implement layers of review procedure to ensure that the reports are accurate, complete, submitted timely, and if needed, posted in HPU website. For the Institution portion, the Manager for Grants and Contracts will prepare the grant report and this report will be reviewed by the Assistant VP for OSP. For the student portion the periodic reports will be prepared by the staff of the Office of Financial Aid and will be reviewed by the Director of the Financial Aid office. The Business Office will perform a high-level independent review for completeness and accuracy. Finally, moving forward, all the files and documents that support the grant report will be retained.