Finding Text
2022-005 - FINDING - Noncompliance with Grant Report Requirements Federal Agency: Department of Education Assistance Listing Numbers: 84.425 Program Names and Award Numbers: Education Stabilization Fund Under the Coronavirus Aid, Relief, And Economic Security Act [COVID-19 Higher Education Emergency Relief Fund: MSI Portion (P425L200096)); COVID-19 Higher Education Emergency Relief Fund: Institution Portion (P425F200852); COVID-19 Higher Education Emergency Relief Fund: Student Portion (P425E201821); and COVID-19 Governor's Emergency Education Relief Fund (21GEERNEIU)] Program Expenditures: $18,210,693 Questioned Costs: None Northeastern Illinois University (University) did not have adequate procedures in place to ensure the Education Stabilization Fund - Higher Education Emergency Relief Fund (HEERF) reporting requirements were submitted accurately and timely. During our testing of the University?s compliance with the grant reporting requirements for HEERF, we noted the University did not review the required reports to ensure accuracy and compliance with the reporting requirements of the grant agreement. We noted the following: Four of 4 (100%) Quarterly Public Reports for the Student Aid portion were not correctly completed. The reports were missing 3 of the 7 requirements. The missing requirements were items 1, 4 and 5 described below. The Federal Register Document No. 2020-19041 released on August 31, 2020 directs each HEERF - Student Portion participating institutions to post the following information on the institution?s primary website no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30) thereafter: 1) an acknowledgement that the institution signed and returned to the Department of Education (Department) the Certification and Agreement and the assurance that the institution has used, or intends to use, no less than 50 percent of the funds; 2) the total amount of funds that the institution will receive or has received from the Department; 3) the total amount of grants distributed to students; 4) the estimated total number of students at the institution eligible to participate and receive the grant; 5) the total number of students who have received the grant; 6) the method(s) used by the institution to determine which students receive the grant and how they would receive; and, 7) any instructions, directions or guidance provided by the institution to students concerning the grant. Three out of 8 (38%) Quarterly Public Reports were posted to the University website 1 day late in one instance and not posted to the University?s website in two instances. The Department of Education Quarterly Budget and Expenditure Reporting Form requires the University to post the Quarterly Public Reports covering each quarterly reporting period (September 30, December 31, March 31, June 30), no later than 10 days after the end of each calendar quarter. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control designed to reasonably ensure compliance with Federal laws, statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure that all earmarking requirements are reviewed to ensure compliance. University officials stated required reports were not timely and accurately submitted due to turnover within the University resulting in staffing constraints. Failure to meet grant reporting requirements is noncompliance with federal regulations and could result in loss of grant funding in future years. (Finding Code No. 2022-005, 2021-008, 2020-011) RECOMMENDATION - We recommend the University improve its grant reporting and monitoring process to adhere with grant request for proposal and application agreement. UNIVERSITY RESPONSE - The University agrees with the recommendation.