Information on the Federal Program: HEERF Institutional Portion (AL Number 84.425F) – U.S. Department of Education
Criteria or specific requirement: 2 CFR Section 200.334 - Financial records, supporting documents, statistical records, and all other non-federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the federal awarding agency or pass-through entity in the case of a subrecipient.
Higher Education Emergency Relief Fund Lost Revenue Frequently Asked Questions - An institution must adequately document its estimate of lost revenue, including its rationale, calculations, methodology, underlying data, and budgets or projections used to determine the amount of lost revenue.
Condition: At the time the lost revenue estimation was made, the University did not contemporaneously document its rationale, calculations, or methodology. Based on a review of parking revenue data subsequently compiled from the previous four years, it was determined that the amount reported as lost revenue in 2022 was reasonable; however, the contemporaneous record retention criteria was not satisfied.
Cause: The University did not retain contemporaneously prepared documentation supporting its estimate of lost revenue including its rationale, calculations, and methodology.
Effect: Contemporaneously prepared documentation and justification of the lost revenue estimation was not available to be audited. Historical parking revenue data from the previous four years was subsequently compiled and provided to support the amount reported as lost revenue in 2022 was reasonable.
Recommendation: We recommend the University review the internal controls over the administration of federal funds to ensure future documentation is created and retained in accordance with specific grant requirements with an emphasis on the specific requirements of grants new to the University.
Views of responsible officials and planned corrective actions: The University concurs with the finding and has taken proactive measures to ensure compliance. Specifically, the University has established a digital folder dedicated to maintaining all records pertaining to HEERF funding and lost revenue calculations.
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