Finding Text
Information on the federal program: COVID-19 Education Stabilization Fund (Assistance Listing Number 84.425) HEERF: Institutional Portion (84.425F), Minority Serving Institutions (MSIs) (84.425L), and Student Aid Portion (84.425E); United States Department of Education; Award Year 2021-22; Compliance Requirement ? Reporting; Type of Finding ? Material Noncompliance. Criteria: Uniform Guidance Compliance Supplement 2022 Section 4-84.425 (ESF Section 2) ? III.L.3.b. and c. (Special Reporting) require quarterly public reporting for (a)(1) Institutional Portion, (a)(2), and (a)(3) funds and for (a)(1) Student Aid Portion. The quarterly student reporting includes a requirement to disclose the method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive. Higher Education Emergency Relief Fund III Frequently Asked Questions #51 requires public quarterly reports to remain online for a period of at least three years after the submission of the last quarterly or annual performance report. Condition: The noncompliance for Reporting was as follows: 1) We found no evidence that the following items had been posted to the University?s website: a. The fall 2021 criteria for determining eligible award amounts for students. b. The student portion quarterly reports for 3rd and 4th quarters 2021 and 1st quarter 2022. 2) As of September 19, 2022 and November 22, 2022, when we reviewed the University?s website, we were unable to access any student or institutional quarterly reports, including the reports we cited in our 2020-21 audit report as finding 2021-001. 3) The institutional quarterly reports had errors: a. September 30, 2021 report showed incorrect quarterly amounts. b. December 31, 2021 report showed the amounts for the quarter ended September 30, 2021 instead of December 31, 2021. c. The final quarterly report included cumulative expenditures for the ARP funding instead of the quarterly expenditure amounts. This report was also dated January 6, 2022 instead of March 31, 2022. Cause: University management did not have controls in place to (1) ensure that quarterly reporting would take place, (2) review quarterly reporting for accuracy, or (3) ensure that the reporting would remain available online for three years from the submission of the final report. Effect: The student award eligibility information and accurate quarterly reporting was not made publicly available, and was not maintained online for three years, as required by the grant. Questioned Costs: n/a for this compliance requirement. Context: Total required quarterly institutional and student reports for the year: 6 (program ended prior to March 31, 2022). Student eligibility was calculated differently for each of the two main semesters; only the criteria for spring 2022 was available online. Recommendations: Management should review the Compliance Supplement and other HEERF guidance, post the required reporting online as soon as possible, and take steps to ensure that it will be kept publicly available online for three years. Training should be provided regarding federal grants in the future to ensure that all grant reporting requirements are met. Responsible Official?s Response and Corrective Action Planned: see corrective action plan.