Finding Text
Federal Agency: U.S. Department of Education Federal Program Title: HEERF Assistance Listing Number: 84.425 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or Specific Requirement: For the (a)(1) Student Aid Portion (Assistance Listing 84.425E), disbursements made under the Student Aid Portion are required to be made directly to students. ED?s (Eligibility to Receive Emergency Financial Aid Grants to Students under the Higher Education Emergency Relief Programs, May 14, 2021) on student eligibility for HEERF states that all students who are or were enrolled in an institution of higher education on or after the date of the declaration of the national emergency due to the coronavirus (March 13, 2020) are eligible for emergency financial aid grants from the HEERF, regardless of whether they completed a FAFSA or are eligible for Title IV. As it relates to expenditures under the (a)(1) Student Aid Portion, auditors should determine (1) the college or university had a documented plan to distribute funds to students, (2) that the college or university did not place any restrictions on the expenditure of those funds beyond what is in the statute, above, and (3) the college or university expended the entirety of the Student Aid Portion grant on financial aid grants to students and that the college or university did not reimburse itself for any costs or expenses previously issued to students. Condition: During our testing, we noted Clarkson College did not follow their documented distribution plan that was uploaded to their website. Questioned Costs: None Context: The documented distribution plan was for students with an EFC $0-25,000 to receive a disbursement of $1,000 while students with EFC greater than $25,000 received a disbursement of $500. The actual disbursement plan was for students who were Pell eligible during 2022 to receive a $1,000 HEERF disbursement while Non-Pell eligible students to receive a $500 disbursement. Cause: The colleges did not comply with (ED) regulations for allowable costs. Effect: There was inaccurate reporting on the College?s website. Repeat Finding: No Recommendation: We recommend the colleges reevaluate their procedures surrounding allowable costs and costs being charged to the grant to ensure all are allowable costs. Views of responsible officials: There is no disagreement with the audit finding.