Finding 621705 (2022-001)

Criteria or Specific Requirement: The Code of Federal Regulations, 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. There are three components to reporting for Higher Education Emergency Relief Funds (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 Act 18004(e) and the 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 ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Specific to the quarterly reports, institutions are required to post two separate reports (institutional and student) for each quarter, including the quarterly reports from previous quarters. Quarterly reports should appear on the institution?s website as separate documents by quarter and should not be cumulative. Condition: The University is not in compliance with Student Aid quarterly reporting requirements for HEERF. Questioned Costs: None Context: We tested two of the four required Student Aid Quarterly Reports. While management was able to provide ?look back? reports for our testing, and we concluded the reports tested were completed accurately and timely, we noted that the Student Aid Quarterly Reports were not being maintained on the University?s website as required. We did note that the Institutional Quarterly Reports were being maintained on the Institution?s website as required. Cause: The University was not aware that the Student Aid Quarterly Reports were required to be maintained on the University?s website. Effect: The University was not in compliance with requirement to maintain Student Aid Quarterly Reports on the University?s website. Repeat Finding: No Recommendation: We recommend that the University post and maintain the Student Aid Quarterly reports on the University?s website, as required. In addition, in order to prevent similar instances in the future, we recommend the University ensure interpretation of guidance is accurate through the use of trainings, consultations, and direct correspondence with the regulatory agency, when necessary, to ensure full understanding of reporting requirements. View of Responsible Official: The University agrees with the finding.