Information on the Federal Program: HEERF Student, Institutional, and HBCU Portion (AL Numbers 84.425E, 84.425F and 84.425J) – U.S. Department of Education
Criteria or specific requirement: Federal Register Vol. 85, No. 169 and Vol. 86, No. 91 state that reporting information must appear in a format and location that is easily accessible to the public. This information must be updated no later than 10 days after the end of each calendar quarter. Additionally, HEERF FAQ guidance published by the Department of Education states an Institution can discharge the complete balance of student debt and reimburse themselves through their HEERF grants by reporting the discharge as lost revenue from academic sources in quarterly and annual reporting.
Condition: The report for the quarter ended March 31, 2022, was revised in 2023, and the University removed the original version from their website. All quarterly reports, excluding the Institutional report for the quarter ended December 31, 2023, used cumulative totals of grant receipts instead of quarterly totals.
Cause: The University did not have the proper internal controls in place to ensure that all reporting requirements were being adhered to.
Effect: The University is not in compliance with the reporting requirements for HEERF funds specified by the Department of Education.
Recommendation: We recommend the University review all previously submitted reporting documentation and update per the current guidance posted by the Department of Education. The University should also implement and maintain an effective system of internal controls over the administration of HEERF funds to ensure funds are reported accurately and timely, in accordance with grant requirements.
Views of responsible officials and planned corrective actions: The University concurs with the finding. Additional procedures have been implemented to ensure the timely completion of all federal HEERF reports. In addition, the HEERF public reporting requirements have been met and the University was deemed in compliance by the Department of Education as of September 2023.
128.