Duplicate Higher Education Emergency Relief Fund Grant Awards (ED-OIG/F20CA0047)
Summary
Final Flash Report ED-OIG/F20CA0047 of the U.S. Department of Education Office of Inspector General, dated June 9, 2022, on Duplicate Higher Education Emergency Relief Fund Grant Awards, with a memorandum from Bryon S. Gordon, Assistant Inspector General for Audit. The report states that the OIG identified 25 duplicate HEERF grant awards that the Office of Postsecondary Education made to 24 schools, totaling about $73 million, which had not been corrected and documented in G5 as of August 2021. It states that the 25 duplicate awards represented less than 0.1 percent of the more than 30,000 HEERF awards made. The report includes a recommendation to enhance the Department's ability to prevent, identify, and correct duplicate awards.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
About this report. The Inspector General identified 25 duplicate HEERF grant awards to 24 schools, totaling about $73 million, that had not been corrected and documented in the Department's G5 system as of August 2021. It notified the Office of Postsecondary Education and verified the corrective actions taken. Duplicate awards are a control weakness and an overpayment risk, not a finding of fraud.
- Issuer
- U.S. Department of Education, Office of Inspector General
- Document type
- Report
- Date
- 2022-06-09
Cite this document
“Duplicate Higher Education Emergency Relief Fund Grant Awards (ED-OIG/F20CA0047).”
U.S. Department of Education, Office of Inspector General, dated 2022-06-09. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/duplicate-heerf-grant-awards/
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U.S. Department of Education
Office of Inspector General
Duplicate Higher Education
Emergency Relief Fund Grant
Awards
June 9, 2022
ED-OIG/F20CA0047
ED OIG Oversight of Coronavirus Response Funds
FLASH REPORT
NOTICE
Statements that managerial practices need improvements, as well as other conclusions
and recommendations in this report, represent the opinions of the Office of Inspector
General. The appropriate Department of Education officials will determine what
corrective actions should be taken.
In accordance with Freedom of Information Act (Title 5, United States Code,
Section 552), reports that the Office of Inspector General issues are available to
members of the press and general public to the extent information they contain is not
subject to exemptions in the Act.
UNITED STATES DEPARTMENT OF EDUCATION
OFFICE OF INSPECTOR GENERAL
Audit Services
June 9, 2022
TO: Michelle Asha Cooper, Ph.D.
Deputy Assistant Secretary for Higher Education Programs Delegated the Authority to
Perform the Functions and Duties of the Assistant Secretary, Office of Postsecondary
Education
FROM: Bryon S. Gordon /s/
Assistant Inspector General for Audit
SUBJECT: Final Flash Report, “Duplicate Higher Education Emergency Relief Fund Grant Awards,”
Control Number ED-OIG/F20CA0047
Attached is the subject final flash report consolidating the results of our review of duplicate Higher
Education Emergency Relief Fund grant awards. We have provided an electronic copy to your audit
liaison officer. We received your comments on the draft of this report and considered them as we
prepared the report.
U.S. Department of Education policy requires that you develop a final corrective action plan within
30 days of the issuance of this report. The corrective action plan should set forth the specific action
items and targeted completion dates necessary to implement final corrective actions on the findings and
recommendations contained in this final flash report. Corrective actions that your office proposes and
implements will be monitored and tracked through the Department’s Audit Accountability and
Resolution Tracking System.
In accordance with the Inspector General Act of 1978, as amended, the Office of Inspector General is
required to report to Congress twice a year on the audits that remain unresolved after 6 months from
the date of issuance.
We appreciate your cooperation during this review. If you have any questions, please contact me at
(202) 987-0162 or Daniel Schultz, Director of Pandemic Relief Audits, at (202) 262-1046.
Attachment
400 MARYLAND AVENUE, S.W., WASHINGTON, DC 20202-1510
Promoting the efficiency, effectiveness, and integrity of the Department’s programs and operations.
Purpose
This flash report presents our finding concerning duplicate Higher Education Emergency
Relief Fund (HEERF) grant awards to institutions of higher education.1 This report
includes a recommendation to enhance the U.S. Department of Education’s
(Department) ability to prevent, identify, and correct duplicate HEERF grant awards.
While analyzing HEERF program award data in the Department’s grants management
system (G5), we identified schools that were awarded the same HEERF award twice
(duplicate awards). Due to the limited nature of our review, this report covers only
duplicate awards and not other types of award discrepancies.
What We Did
We reviewed G5 data to identify duplicate HEERF awards as of August 2021. The review
covered HEERF funds that the Department awarded to schools from April 2020 through
August 2021 for eight HEERF subprograms under three laws—the Coronavirus Aid,
Relief, and Economic Security Act (CARES Act), the Coronavirus Response and Relief
Supplemental Appropriations Act (CRRSAA), and the American Rescue Plan (ARP).2 For
each duplicate award identified, we reviewed supporting documentation such as grant
applications, grant award notifications, and activity reports to validate that a duplicate
award existed. We also interviewed officials from the Department’s Office of
Postsecondary Education (OPE) about their policies, procedures, and processes for
identifying, correcting, and documenting duplicate awards. We notified OPE of the
duplicate awards identified and verified corrective actions taken by OPE.
What We Found
We identified 25 duplicate HEERF grant awards that OPE made to 24 schools, totaling
about $73 million, which had not been corrected and documented in G5 as of August
2021. OPE officials stated that their processes for reviewing and approving HEERF
applications and awards, which evolved over time, resulted in OPE identifying and
correcting many duplicate HEERF grant awards. However, we found that OPE’s
processes did not always prevent or timely identify and correct duplicate HEERF grant
1
In this report, we use the term “award” to mean a grant award or an obligation; and the term “school”
to mean an institution of higher education. An “obligation” is defined as a financial commitment to pay
the grantee based on the terms and conditions for funding.
2
The CARES Act, Public Law 116-136, was enacted on March 27, 2020; CRRSAA, Public Law 116-260, was
enacted on December 27, 2020; and ARP, Public Law 117-2, was enacted on March 11, 2021.
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awards, and that OPE did not consistently document activities taken to correct duplicate
awards. Overall, OPE could improve its quality assurance review process for HEERF and
other future emergency Federal education programs to lessen the risk of making
overpayments to schools and of schools drawing down more funds than they were
allocated.
Background
The HEERF program provides grants to schools to prevent, prepare for, and respond to
the coronavirus. Funding for the HEERF was authorized under three laws—$13.9 billion
through the CARES Act, $22.7 billion through the CRRSAA, and $39.6 billion through the
ARP. Collectively, these coronavirus relief laws provide more than $76 billion for the
HEERF program, which comprises 10 subprograms that are identified by separate
Assistance Listing Numbers (ALN). In Appendix B, we list the 10 HEERF subprograms and
identify the 8 subprograms we reviewed.3
The Department divided the primary HEERF funding stream between two
subprograms—50 percent as the Student Aid Portion (ALN 84.425E) subprogram for
emergency financial aid grants and 50 percent as the Institutional Portion (ALN 84.425F)
subprogram for the remaining funds. The eight remaining subprograms provided
additional funding to eligible schools.
For each subprogram that we reviewed, the Department allocated HEERF funding to
eligible schools based on statutorily established allocation formulas. The process for
awarding HEERF grants generally entailed schools submitting an application that
identified the applicable subprogram and allocation amount as determined by the
Department. After reviewing the application, Department staff made the grant award by
issuing a Grant Award Notification to the school and obligating the funds in the G5
system. Once the funds were obligated, schools could access and draw down the funds.
The Department generally distributed CRRSAA and ARP funding as supplements to
existing CARES Act grant awards, which did not require the school to submit another
application. Schools that did not receive HEERF funding under the CARES Act were
subject to the application process to receive CRRSAA funding. Schools that did not
receive HEERF funding under the CARES Act or CRRSAA were subject to the application
process to receive ARP funding.
OPE is responsible for administering the HEERF program. After the CARES Act was
enacted in March 2020, OPE relied primarily on existing staffing levels and grant-
3
At the time of our analysis, the Department had not made awards under two of the HEERF
subprograms. As a result, we did not include those subprograms in our review.
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management policies and procedures to process and distribute a large volume of
funding to schools as quickly as possible. In September 2020, OPE established the
Emergency Response Unit (ERU) to centralize its management and oversight of the
HEERF program.4 The ERU performed various HEERF grant administration and oversight
functions such as processing grant awards and providing guidance and technical
assistance to grantees.
Duplicate HEERF Awards
Our review of G5 data identified 24 schools that had 25 duplicate HEERF awards totaling
about $73 million, as of August 2021.5 We determined that these 25 duplicate awards
occurred across 6 HEERF subprograms and from the funds provided under all
3 coronavirus relief laws (CARES Act, CRRSAA, and ARP). Twenty of the duplicate awards
involved the Student Aid Portion (ALN 84.425E) or Institutional Portion (ALN 84.425F)
subprograms. OPE made 13 of the 25 duplicate awards under the CARES Act between
April and November of 2020. While the 25 duplicate awards represented less than
0.1 percent of the more than 30,000 HEERF awards made by OPE under the CARES Act,
CRRSAA, and ARP, it is important for OPE to take timely steps to address duplicate
awards and prevent further duplicate awards.
School and OPE Processing Errors
Two scenarios generally describe the duplicate awards we identified. In the first
scenario, we determined that 15 schools had each submitted 2 applications for the
same HEERF subprogram. OPE processed both applications and made duplicate awards
for the same subprograms. Most of these schools submitted two applications for the
Student Aid Portion subprogram under the CARES Act. However, based on the
descriptive information included in the application, it appears that the schools intended
for one of the applications to be for the Institutional Portion subprogram. One school
had multiple locations and submitted separate applications for the Student Aid Portion
and Institutional Portion subprograms for two of its locations, resulting in a duplicate
award for each subprogram. We noted that the CARES Act allocation table for the
4
For the first 4 months after its creation (September–December 2020), the ERU’s sole responsibility was
to implement the Institutional Resilience and Expanded Postsecondary Opportunity subprogram
(ALN 84.425P). In January 2021, OPE began assigning administrative and oversight responsibilities for
the larger HEERF portfolio to the ERU with full responsibility for the entire HEERF portfolio having been
assigned to the ERU by August 2021.
5
One school had duplicate awards for 2 subprograms resulting in 25 duplicate awards across the
24 schools.
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Student Aid Portion and Institutional Portion subprograms may have caused some
confusion. For each school, the table listed the total allocation for the two subprograms
combined and the minimum allocation for emergency financial aid grants to students,
but not did not name the two subprograms nor their respective allocation amounts.
Since schools had to submit an application for each subprogram, some schools may
have confused the two subprograms on the application. Under the CRRSAA and ARP,
however, the allocation tables did identify the Student Aid Portion and Institutional
Portion subprograms by name and ALN and each school’s allocation amount for each
subprogram.
In the second scenario, we determined that the remaining nine schools had submitted
only one application for the HEERF subprogram and OPE processed duplicate HEERF
awards under one application. In both scenarios, OPE processed duplicate awards that
made more funds available for these schools than the approved allocation amounts.
OPE officials stated that, in general, duplicate awards were typically due to schools
submitting multiple applications or applying under different names. In addition, OPE
officials stated that creating separate subprograms for the Student Aid Portion and
Institutional Portion resulted in OPE staff inadvertently approving some duplicate
awards, primarily under the CARES Act when the Department had to manually process
an unprecedented volume of awards in an expedited manner.
Impact of Duplicate Awards
The 25 duplicate awards that we identified resulted in a total of about $73 million in
additional HEERF funds that were available for the 24 schools to access and draw down.
According to G5 data, most of the schools did not draw down funds from the duplicate
award; however, eight schools did draw down the funds. At the time of our review, we
determined that:
• Two schools drew down and retained about $1.2 million in duplicate award
funds.
• Three schools drew down about $3.2 million in HEERF funds from the incorrect
subprogram because they had two Student Aid Portion (ALN 84.425E) awards
and did not have an Institutional Portion (ALN 84.425F) award. The schools drew
down and used their duplicate Student Aid Portion award as their Institutional
Portion award resulting in the schools drawing down the correct amount of
HEERF funding in total.
• Three schools drew down about $600,000 in HEERF funds and returned the
funds 4–8 months later.
• Sixteen schools did not draw down funds from the duplicate HEERF award.
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Guidance and Requirements for Administering HEERF Fu nds
Federal guidance issued before and in response to the coronavirus addresses the need
for Federal agencies to safeguard the coronavirus relief funding and establish written
policies and procedures to manage risk.
Office of Management and Budget (OMB) Memorandum M-20-21 (April 2020),
Implementation Guidance for Supplemental Funding Provided in Response to the
Coronavirus Disease 2019 (COVID-19) explained how Federal agencies should implement
CARES Act programs. It directs agencies to balance speed with transparency and
consider three core principles: mission achievement, expediency, and transparency and
accountability. To adhere to these principles, the guidance directs agencies to continue
to use standard best practices for planning, awarding, and managing grants and other
forms of assistance. Agencies should also balance the need for expediency with steps to
mitigate risk of fraud, waste, abuse, and improper payments.
OMB Memorandum M-21-20 (March 2021), Promoting Public Trust in the Federal
Government through Effective Implementation of the American Rescue Plan Act and
Stewardship of the Taxpayer Resources explained how Federal agencies should
implement the ARP program and effectively steward these funds. The guidance states
that agencies should consider the impact that the increased volume of program
applications and limitations in resources relative to volume of applications or funding
have on the program’s payment integrity. The agency should consider whether those
risk factors are significant enough to warrant the implementation of additional payment
integrity risk mitigation strategies prior to disbursing funds.
The U.S. Department of Education Departmental Directive, Guide for Managing Formula
Grant Programs (OFO-F: 2-111, August 2019)6 requires that all principal officers
administering formula grant programs establish or update, by June 1 of each year,
written standard operating procedures which are required for the approval of
applications, obligation and award of formula grants, and monitoring of formula
grantees.
OPE Steps to Prevent, Identify, and Correct Duplicate HEERF
Awards
OPE officials stated that OPE’s policies and procedures for administering HEERF grants,
including identifying and correcting duplicate awards, evolved over time. According to
the officials, OPE’s primary focus after the CARES Act was enacted was to allocate and
6
This guide, which OPE officials said that staff used to manage the HEERF program, is the Department-
wide policy and procedural framework for formula grant programs.
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award HEERF grant funds to schools as quickly as possible. OPE took some steps to
prevent, identify, and correct duplicate awards, as described below. However, we
determined that these steps were not adequate to timely identify, correct, and
document activities taken to correct duplicate awards.
OPE Procedures Under the CARES Act
Prior to our review, the U.S. Government Accountability Office (GAO) reported on the
Department’s process for approving and awarding HEERF grants under the CARES Act.7
In July 2021, GAO reported that OPE did not effectively design and implement
procedures needed to identify erroneous award amounts. GAO estimated that OPE
awarded grants in excess of their allocated amount to 5.5 percent (about 262) of all
schools receiving HEERF grants under the CARES Act. Within its sample of awards, GAO
identified three schools that had HEERF award discrepancies—two schools with
duplicate awards and one school with an award greater than its allocation.8
The GAO report stated that the erroneous awards, including duplicate awards, were the
result of OPE relying primarily on existing staffing levels and grant-management policies
and procedures to administer HEERF grants. The report stated that OPE’s procedures
only called for staff to review grant amounts as part of the award-preparation process
(pre-award). In addition, GAO reported that OPE staff initially checked all grant awards
to mitigate the risk of duplicates and confirm the accuracy of the award, but this post-
award quality assurance review was not part of OPE’s policies and procedures, and staff
did not regularly perform the reviews due to staffing constraints as the number of
grants increased.
GAO recommended that the Department design and implement procedures for
regularly conducting quality assurance reviews of obligated amounts for higher
education grants, including HEERF, to help identify and correct erroneous awards in a
timely manner. GAO reported that the Department agreed to the recommendation and
stated that it had already established, and would continue to enhance, procedures for
quality control of grant awards.
OPE Efforts to Enhance Procedures under CRRSAA and ARP
Our review included OPE’s response to the GAO report as well as OPE’s policies and
procedures implemented under CRRSAA and ARP. OPE officials stated that the process
7
COVID-19: Continued Attention Needed to Enhance Federal Preparedness, Response, Service Delivery,
and Program Integrity (GAO-21-551), July 2021.
8
The 2 schools that GAO identified with duplicate awards were not among the 24 schools we identified.
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described in the GAO report enabled staff to prevent many potential duplicate awards
during the initial awarding of HEERF funds under the CARES Act. For the CRRSAA and
ARP awards, OPE officials stated that the ERU implemented steps to identify and resolve
duplicate awards prior to and after obligating HEERF funds. The officials stated that the
ERU created a process using a business analytics tool and spreadsheets whereby staff
manually compared grant award numbers on the spreadsheets and corrected duplicates
prior to awarding the funds. OPE officials further stated that this process included
multiple staff checking each grant award after funds were obligated.
OPE officials explained that their processes were continuously improving, and the
number of duplicate awards decreased as staff worked through each iteration of HEERF
funding. The officials also explained that, when duplicate awards were identified, staff
would place a payment flag in G5 to prevent the school from drawing down funds
without first requesting approval from OPE. They also stated that staff would later
complete any corrective actions when time permitted. According to the OPE officials,
staff should document corrective actions in G5.
Improvements Needed to OPE Procedures
Even as their processes evolved over time, we noted that OPE did not have written
procedures for identifying and correcting duplicate awards in a timely manner or for
documenting schools identified as having a duplicate award and the corrective action
taken. OPE officials did not provide records detailing all of the duplicate awards that its
processes had identified, nor the corrective actions taken, because OPE did not
consistently document this information. In a few instances, OPE documented the
corrective action in emails to the school and not in G5.
Additionally, OPE documented the ERU’s process for awarding HEERF funds in
November 2021, after it had already obligated HEERF funds to schools under CRRSAA
and ARP. We noted that this process included a step designed to highlight duplicate
school information, such as school names and identification numbers. However, OPE
officials stated that staff did not perform reviews of G5 data that specifically searched
for duplicate award amounts, such as the analysis we performed. OPE officials further
stated that they plan to hire an experienced person to perform data analytics.
Duplicate Award Trends
As described above, OPE officials stated that the number of duplicate awards declined
with each iteration of HEERF funding. Our results identified fewer duplicate awards
under CRRSAA and ARP than we identified under the CARES Act, but found that the
number of duplicate awards actually increased slightly from CRRSAA to ARP. Of the 25
duplicate awards we identified, OPE made 13 duplicate awards under the CARES Act,
5 duplicate awards under CRRSAA, and 7 duplicate awards under ARP. We noted
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3 payment flags annotated in G5 prior to us notifying OPE of the 25 duplicate awards,
and 15 payment flags annotated in G5 after we notified OPE. At the time of our review,
the remaining seven duplicate awards did not have a payment flag recorded in G5 due
to a duplicate award.
Correction of Duplicate HEERF Awards
Our review of G5 data found that OPE did not always identify or correct the erroneous
awards in a timely manner. As of January 2022, OPE had corrected 24 of the
25 duplicate HEERF awards that we identified and was working to resolve the duplicate
award for the remaining school. OPE corrected 18 of the 24 duplicate awards after we
brought them to its attention and corrected another 5 awards after we identified them
as unresolved but before we notified OPE. One duplicate award was corrected in
June 2021, which was before our analysis, but the correction was not documented in
G5.
We determined that the length of time to correct the 24 resolved duplicate awards
identified by our review ranged from an average of about 4 months (for grants awarded
under the ARP) to more than 16 months (for CARES Act grants), as shown in Table 1. For
example, OPE made a duplicate CARES Act award to one school in July 2020 but did not
reduce the school’s grant award by the duplicate amount until November 2021. Another
school had two Student Aid Portion (ALN 84.425E) awards under the CARES Act in July
2020 but OPE did not document until January 2022 that the school was authorized to
treat the duplicate award as its Institutional Portion (ALN 84.425F) award.
Table 1. Length of Time to Correct Duplicate Awards
Law Number of Duplicate Award Correction Dates Average Time to
Awards Dates Correct
CARES Act 12 April 2020– June 2021– 16.8 months
November 2020 January 2022
CRRSAA 5 January 2021– August 2021– 7.6 months
May 2021 November 2021
ARP 7 May 2021– August 2021– 4.4 months
August 2021 January 2022
Total 24 - - -
SOURCE: Office of Inspector General (OIG) Analysis of G5 Data (24 resolved duplicate awards) and
OPE Correspondence with 3 Schools
OPE resolved the 24 erroneous awards in one of the following ways:
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• reducing the school’s grant award by the duplicate award amount in G5
(20 duplicate awards involving 19 schools),
• authorizing the school to treat the duplicate Student Aid Portion (ALN 84.425E)
award as its Institutional Portion {ALN 84.425F) award (3 schools),9 or
• reducing the school’s ARP award amount in G5 by the duplicate CARES Act
award amount (1 school).
After completing our review, the one remaining duplicate award, which OPE had been in
the process of correcting, appeared to be resolved. According to a G5 activity report, in
March 2022 the school had returned the duplicate CARES Act award funds it had drawn
down in July 2020.
Risks Associated with Duplicate Awards
Without a more effective quality assurance review process to timely identify, correct,
and document duplicate awards, there is heightened risk of OPE making overpayments
to schools resulting in some schools drawing down more funds than they were
allocated. The $73 million in duplicate awards we identified was at risk of the 24 schools
drawing down and inappropriately spending the funds. Although most of these schools
did not draw down or later returned funds from their duplicate award, at the time of
our review two schools had drawn down and retained $1.2 million in duplicate CARES
Act awards. OPE recovered the funds from one school by reducing its ARP award by the
amount of the duplicate award in January 2022, and the other school returned the
funds in March 2022. Nevertheless, it is important that OPE have adequate procedures
in place to prevent and timely identify and correct duplicate awards as well as to
adequately document these actions. To strengthen these procedures, OPE could use
data analytics, including analyses of award amounts, to supplement its processes for
identifying duplicate awards.
What We Recommend
We recommend that the Assistant Secretary for Postsecondary Education—
1.1 Design and implement written policies and procedures for HEERF and other
future emergency programs that specifically address (1) application and award
verification procedures designed to prevent duplicate awards from occurring,
(2) quality assurance reviews of obligated HEERF funds including analyses to
9
OPE documented the corrective action via email correspondence with the school.
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identify duplicate awards, and (3) the correction and documentation of
erroneous awards in a timely manner.
OPE Comments
We provided a draft of this report to OPE for comment. We summarized OPE’s
comments below and provide the full text of the comments at the end of this report.
While OPE did not state whether it agreed or disagreed with the finding, OPE agreed
with the recommendation, stating that it has already established and will continue to
enhance procedures for quality control of grant obligations to schools, including
application and award verification procedures, quality assurance reviews of HEERF grant
awards, and the correction and documentation of erroneous awards in a timely manner
for potential use in future emergency programs. OPE noted that the Department was
aware of all but 1 of the 25 duplicate awards we had identified, and that it had fully
resolved or was in the process of resolving the duplicate awards. OPE also described its
efforts to award HEERF grant funds quickly with limited staff and resources while
establishing and enhancing quality controls to identify, correct, and eliminate award
errors.
OPE also provided technical comments regarding our trend analysis of negative
transactions that we discussed in the draft report. OPE stated that the negative
transactions used as indicators in our analysis are not always an accurate indicator of
duplicate awards and provided examples of other reasons for negative transactions.
OIG Response
OPE’s proposed action to continue to improve quality control procedures to prevent,
identify, correct, and document erroneous grant awards is responsive to our
recommendation, if it is implemented as described and includes thorough analyses to
identify duplicate awards.
Regarding OPE’s statement that Department officials were aware of all but one of the
duplicate awards that we identified, we did not receive evidence showing when OPE
became aware of the duplicate awards. As noted in our finding, OPE did not consistently
document the existence of duplicate awards that it had identified. In addition, OPE
corrected most of the 25 duplicate awards we had identified after we brought them to
its attention.
Regarding OPE’s technical comments about negative transactions, we agree that these
transactions are not always an accurate indicator of duplicate awards.
The draft report discussed and referenced negative transactions (under the headings
Duplicate Award Trends, Correction of Duplicate HEERF Awards, and Appendix A) and
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characterized as "significant” the number of duplicate awards that OPE identified and
corrected (under What We Found). Based on OPE’s technical comments, we removed
the discussion and references regarding negative transactions and modified Appendix A
accordingly. We also replaced the word “significant” with the word “many” to reflect
what OPE officials told us during our review. We did not make further changes to the
finding or recommendation in response to OPE’s comments.
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Appendix A. Scope and Methodology
We reviewed G5 data to identify duplicate HEERF awards as of August 2021. To achieve
our objective, we downloaded HEERF grant award and transaction reports from G5 and
used data analytics to identify duplicate award amounts. For each duplicate award, we
reviewed supporting documentation in G5, including External Award Activity History
Detail Reports, Flag Activity Reports, Applications, Certification and Agreement letters,
and Grant Award Notifications, to validate that a duplicate award existed. Our review
covered all HEERF funds that OPE awarded to schools from April 2020 through August
2021 for eight HEERF subprograms under the CARES Act, CRRSAA, and ARP.
We also gained an understanding of the following Federal requirements and guidance,
and reviewed a GAO report, relevant to administering HEERF funds and duplicate HEERF
awards:
• Federal Requirements and Guidance—OMB Memorandum M-20-21
(April 2020), Implementation Guidance for Supplemental Funding Provided in
Response to the Coronavirus Disease 2019 (COVID-19); OMB Memorandum
M-21-20 (March 2021), Promoting Public Trust in the Federal Government
through Effective Implementation of the American Rescue Plan Act and
Stewardship of the Taxpayer Resources; and U.S. Department of Education
Departmental Directive, Guide for Managing Formula Grant Programs
(OFO-F: 2-111, August 2019); and
• GAO Report—COVID-19: Continued Attention Needed to Enhance Federal
Preparedness, Response, Service Delivery, and Program Integrity (GAO-21-551),
July 2021.
To gain an understanding of OPE’s policies, procedures, and processes for identifying,
correcting, and documenting duplicate awards prior to and after HEERF funds were
obligated, we interviewed senior OPE officials, including ERU officials; reviewed
corrective actions taken in response to GAO’s July 2021 report; and reviewed the
reasons duplicate awards occurred and actions taken to correct them for the 24 schools
we identified as having 25 duplicate awards.
We also verified the corrections that OPE made for 24 of the 25 duplicate awards we
identified by reviewing supporting documentation in G5, including transaction reports,
grant award notifications, and comment fields. We also reviewed OPE correspondence
with the three schools that were authorized to treat the duplicate Student Aid Portion
(ALN 84.425E) award as an Institutional Portion (ALN 84.425F) award. For the one school
that OPE was working to resolve at the time of our review, we downloaded a G5 activity
report and noted the return of funds in March 2022.
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Our review addressed schools that had duplicate awards and not other types of award
discrepancies. To try to corroborate the number of duplicate awards that OPE had
corrected for each iteration of HEERF funding, we analyzed G5 data to identify instances
of award amounts that were later reversed by the exact same dollar amount (negative
obligation) as of January 2022. We did not verify whether the negative obligations were
in fact duplicate awards or due to other types of discrepancies.
Use of Computer-Processed Data
The use of computer-processed data for our flash report was limited to querying and
downloading reports from G5 containing HEERF grant award data, including award
numbers and authorization amounts. We analyzed this data to identify duplicate HEERF
awards to schools. To assess the reliability of our analysis, our Technology and Analytics
Services specialists independently verified the results of our query. We also performed
limited data quality checks by reviewing supporting documentation and determined
that the G5 data used in our analysis were reliable for the purposes of this review.
Compliance with Standards
We conducted our work in accordance with OIG’s quality control standards and the
Council of the Inspectors General on Integrity and Efficiency’s (CIGIE) “Quality Standards
for Federal Offices of Inspector General,” which require that we conduct our work with
integrity, objectivity, and independence. We believe that the information obtained
provides a reasonable basis for our conclusions.
We performed our review remotely from September 2021 through January 2022 and
updated our work in March 2022 to reflect the return of funds from the one remaining
school that was unresolved during the time of our review. We held an exit conference
with OPE officials on January 13, 2022, to discuss the results of our review.
U.S. Department of Education
Office of Inspector General
ED-OIG/F20CA0047 13
Appendix B. Higher Education Emergency Relief
Funds Subprograms
Table 2 lists the 10 HEERF subprograms and identifies the 8 subprograms included in our
review. Our review did not include the Institutional Resilience and Expanded
Postsecondary Opportunity (ALN 84.425P) and Supplemental Assistance to Institutions
of Higher Education (ALN 84.425S) subprograms because OPE had not awarded HEERF
funding for these subprograms as of August 2021.
Table 2. HEERF Subprograms
Assistance Listing Subprogram Name Included in
Number and Alphabetic OIG Review
Identifier
84.425E Student Aid Portion X
84.425F Institutional Portion X
84.425J Historically Black Colleges and Universities X
84.425K Tribally Controlled Colleges and Universities X
84.425L Minority Serving Institutions X
84.425M Strengthening Institutions Program X
84.425N Fund for the Improvement of Postsecondary X
Education Formula Grant
84.425P Institutional Resilience and Expanded -
Postsecondary Opportunity
84.425Q Proprietary Institutions Grant Funds for Students X
84.425S Supplemental Assistance to Institutions of Higher -
Education
U.S. Department of Education
Office of Inspector General
ED-OIG/F20CA0047 14
Appendix C. Acronyms and Abbreviations
ALN Assistance Listing Number
ARP American Rescue Plan
CARES Act Coronavirus Aid, Relief, and Economic Security Act
CRRSAA Coronavirus Response and Relief Supplemental Appropriations
Act
CIGIE Council of the Inspectors General on Integrity and Efficiency
Department U.S. Department of Education
ERU Emergency Response Unit
GAO U.S. Government Accountability Office
HEERF Higher Education Emergency Relief Fund
OIG Office of Inspector General
OMB Office of Management and Budget
OPE Office of Postsecondary Education
U.S. Department of Education
Office of Inspector General
ED-OIG/F20CA0047 15
OPE Comments
U.S. Department of Education
Office of Inspector General
ED-OIG/F20CA0047 16
U.S. Department of Education
Office of Inspector General
ED-OIG/F20CA0047 17
U.S. Department of Education
Office of Inspector General
ED-OIG/F20CA0047 18
U.S. Department of Education
Office of Inspector General
ED-OIG/F20CA0047 19
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