Finding Text
Criteria: 2 CFR 200.303(a) requires the non-Federal entity to establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is managing
the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the
Federal award.
Condition: During our testing of the HEERF Program, for payroll and non-payroll expenditures,
management did not provide sufficient support to justify the allocation of these costs to the program.
Consequently, we were unable to audit the allowability of these costs.
Context: For payroll-related expenditures, we selected a non-statistical sample of 6 payroll items
representing $26,078, all of which did not have documentation of the justification supporting the allocation.
Total payroll expenditures for the program were $110,525. Management estimated the time each
departments’ employees spent on allowable COVID-related activities; however, the documentation of the
calculation and allocation related to the rationale, basis and final allocations were not provided. For nonpayroll
expenditures, we selected a non-statistical sample of 8 items representing $181,428, of which, 5
items representing $97,367 did not have documented justification supporting their allowability. Total nonpayroll
expenditures for the program were $367,323. Management did not consistently document the
justification supporting the allocation of costs to the program. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as
possible, documented policies and procedures to administer the program were not developed and therefore
not all supporting justifications were documented.
Effect: Expenditures could be disbursed for unallowable costs.
Questioned Costs: None
Identification of a repeat finding: This is a repeat finding of 2022-001.
Recommendations: The HEERF Program has ended for the University. We recommend that should similar
programs become available in the future, that management develop documented policies and procedures to
administer the program and that management maintain documentation to demonstrate compliance with its
policies and procedures.
Views of responsible officials: For payroll-related expenditures, management reviewed the duties of
individuals and estimated the percentage of their time allocable to the program based upon knowledge of
office functions, job duties, and additional demands and tasks related to the COVID-19 pandemic. This
review and discussions within the management team resulted in the amounts allocated to the HEERF
program; the percentage allocations assigned were documented in the calculations used to support the
payroll activity recorded during the fiscal year ended June 30, 2023.
For non-payroll related expenditures, documented policies were not developed for the HEERF program
expenditures and as a result supporting justifications were not consistently documented or maintained.
For all expenditures associated with the HEERF program, when documentation was not obtained or
maintained, management was basing decisions on all regulations available at the time and decisions made
did not violate the intent of the program.
The HEERF awards were fully expended as of June 30, 2022 for the Student Portion and as of
September 30, 2022 for the Institutional Portion. Should similar programs become available in the future,
management will develop, in advance of expending funds, documented policies and procedures to
administer the program and will maintain documentation demonstrating compliance with program requirements and related institutional policy and procedure.