Finding Text
2022-006 Federal Agency: U.S. Department of Education Pass-through Entity: Oregon Higher Education Coordinating Commission (84.425C) Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Pass-through Grant Number: 20-075M Program Name: Education Stabilization Fund Allowable Costs/Activities under Higher Education Emergency Relief Funds (HEERF) Significant Deficiency in Internal Control over Compliance Criteria - 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 final rule (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. The CRRSAA and ARP requires that schools prioritize students with exceptional need, such as students who receive Pell Grants. However, students do not need to be Pell recipients or students who are eligible for Pell grants in order to receive a financial aid grant. Condition ? The College provided emergency grants to students with the student portion of the HEERF funding, but the College could not provide evidence that the student met the definition of ?eligible student?. The emergency grants were used to relieve the delinquent student accounts. There were 5 students identified in our testing that were not ?enrolled in an institution of higher education on or after the date of the declaration of the national emergency (March 13, 2020).? It appears the 5 students were not enrolled at the College on or after March 13, 2020, and the College did not obtain evidence that the students were enrolled on or after this date at another institution of higher education. Cause ? The College did not want to turn away prior students with current financial need based on their enrollment status. This was how management interpreted the guidance from the DOE. Effect - The College may have awarded student HEERF funds to individuals that did not qualify to receive these funds. Questioned Costs ? The known disbursements to individuals that may not be qualified to receive an emergency grant using student funds is $5,983. This known questioned costs extrapolates to a potential ?likely? questioned cost of $29,700 when viewed in relation to the sample and the whole population. Context/Sampling ?The College disbursed aid to 242 students from their HEERF awards in fiscal year 2022. From the total population of student disbursements made in fiscal year 2022, we selected 45 students for testing. Repeat Finding - No Recommendation - The College should implement a process to adequately document their review and approval of students to receive aid under HEERF. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.