Finding Text
Finding 2023-002: Education Stabilization Fund Allowable Costs and Allowable Activities
Federal Agency: Department of Education
Program: COVID-19 Education Stabilization Fund: 84.425
Criteria: The American Rescue Plan (ARP) established two required uses of the HEERF III institutional grant funds for public and private nonprofit institutions in which a portion of funds must be used to: (a) implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the HEA. This requirement was also in place for the HEERF Strengthening Institutions Program funding received by WCCC.
Condition: The internal control system to ensure WCCC’s compliance with the ARP required uses of HEERF III institutional and HEERF Strengthening Institutions Program grant funds were not operating effectively. WCCC reported on their annual reports for Years 2 and 3, encompassing the use of the aforementioned HEERF specific funds, that $0 was spent on both categories.
Cause: Controls were not in place to ensure WCCC’s compliance with the ARP allowable costs and allowable activities requirement to spend HEERF III and HEERF Strengthening Institutions funds on the above stated categories.
Effect: WCCC was not in compliance with the ARP requirements for spending a portion of HEERF III and HEERF Strengthening Institutions Program funds on the above stated categories. WCCC spent all HEERF III and HEERF Strengthening Institutions Program grant funds on revenue replacement, which is not the above stated categories.
Repeat Finding: This is not a repeat finding.
Questioned costs: Unknown
Recommendation: We recommend that WCCC implement procedures to designate an individual responsible for reviewing all grant funding for allowable costs and allowable activities requirements and that the designated individual ensure that grant funding is being spent in accordance with those requirements.
View of Responsible Officials and Planned Corrective Action: WCCC continued to provide the same Covid outreach programs as they had in years one, two, and three to their Students and Employees and community.
- Vaccination clinics were continued and are still offered. However, these are at no cost to the University, student, or employee.
- Hand sanitizer, masks and other items are always available to those who require, but were paid for from prior years funds.
- When advertising for all Covid related events Westmoreland used sources which were at no cost to the College.
- The staff time to organize and manage events did not get allocated to the grant, however would have been covered under the lost revenue recognition.