Finding Text
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. In accordance with section 2003 of the American Rescue Plan Act of 2021 (ARP) (Pub. L. 117-2) (supplemental award or grant) by the U.S. Department of Education and section 2003 of the ARP and section 314 of the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) (Pub. L. 116-260), recipients must promptly and timely provide a detailed accounting of the use and expenditure of the funds provided by these supplemental award in such manner and with such frequency as the Secretary may require. 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 (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: The University is not in compliance with quarterly and annual reporting requirements for HEERF Institutional and Student Grants. Questioned costs: N/A Context: We tested two of the four required quarterly student reports, two of the four required quarterly institutional reports, and the one required annual report. During our testing of this sample for the HEERF reporting requirements at Southern Oregon University, we noted: 1) Non-Compliant Student Quarterly Reporting a. Neither of the two quarterly student reports tested had an acknowledgement that the University signed and returned to the Department of Education the Certification and Agreement and the assurance that the University has used the applicable amount of funds designated under the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) to provide Emergency Financial Aid Grants to Students. Both of these were required elements of the student quarterly reporting. b. On both reports tested, the University reported total amount of emergency financial aid grants distributed, the estimated total number of students at the institution that are eligible to receive emergency financial aid grants, and the total number of students who have received an emergency financial aid grant cumulatively, not on a quarterly basis. Additionally, the reports were cumulative as of days mid-month. 2) Non-Compliant Institutional Quarterly Reporting. a. The Original report published for the third quarter of 2021 was not retained on the website. The revised report was published in January 2022. Ultimately the reports were not posted timely within the 10-day requirement. b. The first quarter of 2022 report was also published 1 day after the deadline on 4/11/2022. 3) Non-Compliant Annual Reporting a. Institutional amounts spent in accordance with section 2003(5) of the American Rescue Plan Act of 2021 were not correctly reported on the 2021 annual report. Specifically, no amounts were reported for earmarking requirements in accordance with the ARP Institutional Appropriation expended in 2021. Cause: Staff turnover and misunderstanding of reporting guidance caused the reporting non-compliance. Effect: The University was not in compliance with HEERF reporting requirements. Repeat finding: Yes 2021-003 Recommendation: We recommend that the University continue to review their reporting policies and procedures to ensure accurate and timely reporting. View of responsible official: The University agrees with the finding.