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Finding 2022-001 ? COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Fund Reporting Repeat Finding: Partial Federal Program Title ? U.S. Department of Education COVID-19 Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF COVID-19: HEERF Student Portion: 84.425E COVID-19: HEERF Minority Serving Institutions (MSI): 84.425L Federal Award Year 2021-2022 Condition City Colleges did not have sufficient documentation that internal controls were in place and operating effectively relative to the following areas: ? HEERF Student Reporting: City Colleges did not have sufficient supporting evidence that review controls were performed over the July 1, 2021 ? September 30, 2021 quarterly student report prior to submission. ? HEERF MSI Reporting: City Colleges did not have sufficient supporting evidence that review controls were performed over the July 1, 2021 ? September 30, 2021 quarterly student report prior to submission. City Colleges did not publicly post certain required reports accurately. The following instance of noncompliance was identified: ? HEERF Student Portion: City Colleges posted a report on July 8, 2022 for Wilbur Wright for the period of April 1, 2022 ? June 30, 2022 which did not reconcile to the underlying expense detail as of the date of the report. The difference was $307,750. 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, as applicable; and (3) the annual report. The institutional quarterly portion reporting requirements involve publicly posting completed forms on City College?s website. The forms must be conspicuously posted on City College?s primary website on the same page the reports of City College?s activities as to the emergency financial aid grants to students (Student Aid Portion) are posted. A new, separate form must be posted covering aggregate amounts spent for HEERF I, HEERF II, and HEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after an institution has expended and liquidated all (a)(1) Institutional Portion, (a)(2), and (a)(3) funds and checks the ?final report? box. City Colleges must post this quarterly report form no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, July 10) apart from the first report, which was due October 30, 2020, and the report covering the first quarter of 2021, which was due July 10, 2021. According to an electronic announcement (EA) by the Department of Education (ED) on May 6, 2020, ED required institutions that received a HEERF 18004(a)(1) Student Aid Portion Aid award to publicly post certain information on their website no later than 30 days after award, and update that information every 45 days thereafter by posting a new report. On August 31, 2020, ED revised the EA with 85 FR 53802, which decreased the frequency of subsequent reporting from every 45 days to every calendar quarter. 2 CFR Section 200.303 requires entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure the timely and accurate posting of reports. Questioned Costs There were no questioned costs with respect to this finding. Cause City Colleges did not have effective internal controls in place to ensure reports were posted accurately due to the newness of the program and how quickly it was rolled out. Prevalence Infrequent. 63 reports were required to be submitted in fiscal year 2022 relative to HEERF Student, Institutional, MSI and Annual reporting. 1 report was inaccurate and 14 did not have sufficient evidence of review. Effect The submission of inaccurate reports is noncompliance with the requirements of the grant award and could result in loss of funding or other penalties. Recommendation We recommend City Colleges implement internal controls to ensure reports are posted accurately. Views of responsible officials We agree with this finding. See corrective action plan.