Pandemic Darlings The pandemic economy, in original documents
Home Source documents Higher Education Emergency Relief Fund Reporting Requirements (ED-OIG/I20DC0013)

Higher Education Emergency Relief Fund Reporting Requirements (ED-OIG/I20DC0013)

Summary

A final report, ED-OIG/I20DC0013, dated February 26, 2021, from the U.S. Department of Education Office of Inspector General on Higher Education Emergency Relief Fund reporting requirements, addressed to the Acting Assistant Secretary of the Office of Postsecondary Education. It states that 81 of the 100 institutions in its nonstatistical sample complied with Institutional Portion reporting requirements, and that reports could not be located for 19 of the 100 institutions (19 percent), which had drawn down over $5.5 million out of almost $29 million awarded as of September 30, 2020. It states that the 81 reporting institutions spent over $283 million (45 percent) of the Institutional Portion funds obligated to them under Section 18004(a)(1). The Office of Postsecondary Education's response states that it agrees with the suggestions.

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

Issuer
U.S. Department of Education, Office of Inspector General
Document type
Report
Date
2021-02-26

Cite this document

“Higher Education Emergency Relief Fund Reporting Requirements (ED-OIG/I20DC0013).” U.S. Department of Education, Office of Inspector General, dated 2021-02-26. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/ed-oig-heerf-reporting-selected-schools-heerf-reporting-requirements/, SHA-256 e754b51562194cd404ddac2c77e2abffdfe29cb5b8b3a66942840fd0affb57db.

Full text

                  U.S. Department of Education
                  Office of Inspector General




Higher Education Emergency
Relief Fund Reporting
Requirements
February 26, 2021
ED-OIG/I20DC0013

ED OIG Oversight of Coronavirus Aid, Relief, and
Economic Security Act Funding
NOTICE
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




February 26, 2021


TO:           Michelle Asha Cooper, Ph.D.
              Acting Assistant Secretary
              Office of Postsecondary Education

FROM:         Bryon S. Gordon /s/
              Assistant Inspector General for Audit

SUBJECT:      Final Report, “Higher Education Emergency Relief Fund Reporting Requirements,”
              Control Number ED-OIG/I20DC0013


Attached is the subject final report that consolidates the results of our review of the Higher Education
Emergency Relief Fund Reporting Requirements. We received your comments agreeing with the
suggestions in our draft report.

We appreciate your cooperation during this review. If you have any questions, please contact Michele
Weaver-Dugan at (202) 245-6941 or Michele.Weaver-Dugan@ed.gov.

Attachment




                               400 MARYLAND AVENUE, S.W., WASHINGTON, DC 20202-1510

               Promoting the efficiency, effectiveness, and integrity of the Department’s programs and operations.
 Table of Contents
Introduction .......................................................................................................................... 1
Results .................................................................................................................................. 3
Other Matter ...................................................................................................................... 12
Appendix A. Scope and Methodology ................................................................................ 14
Appendix B. Acronyms and Abbreviations ......................................................................... 16
Office of Postsecondary Education Comments .................................................................. 17
              Introduction
              The Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law on
              March 27, 2020. It authorized more than $2 trillion to battle Coronavirus Disease 2019
              (COVID-19) and its economic effects. The CARES Act provides $31 billion for an
              Education Stabilization Fund to prevent, prepare for, and respond to COVID-19,
              domestically or internationally, including $17 billion for State and local agencies and
              $14 billion for the Higher Education Emergency Relief Fund (HEERF).

              Higher Education Emergency Relief Fund
              Congress set aside $14 billion of the $31 billion allotted to the Education Stabilization
              Fund for HEERF under Section 18004 of the CARES Act. The HEERF program has several
              different methods for the distribution of the $14 billion in funds to eligible institutions
              of higher education (institutions) based on a student enrollment formula and institution
              status:

                  •   90 percent ($13 billion) under Section 18004(a)(1) to institutions using a formula
                      based on student enrollment, in which at least 50 percent (according to Section
                      18004(c)) must be reserved to provide students with emergency financial aid
                      grants to help cover expenses related to the disruption of campus operations
                      due to COVID-19 (the “Student Aid Portion”; Catalog of Federal Domestic
                      Assistance (CFDA) 84.425E) and the remainder of which may be used to cover
                      any costs associated with significant changes to the delivery of instruction due
                      to the COVID-19 (the “Institutional Portion”; CFDA 84.425F).

                  •   7.5 percent ($1 billion) under Section 18004(a)(2) for grants for Historically Black
                      Colleges and Universities, Tribally Controlled Colleges and Universities, and
                      other Minority-Serving Institutions, as well as other institutions eligible for the
                      Strengthening Institutions Program under parts A and B of title III, parts A and B
                      of title V, and subpart 4 of part A of title VII of the Higher Education Act of 1965,
                      as amended, to address needs directly related to the COVID-19 (CFDAs 84.425J,
                      84.425K, 84.425L, and 84.425M). This 7.5 percent is distributed based on the
                      relative share of funding appropriated under the Further Consolidated
                      Appropriations Act, 2020 (Public Law 116-94).
                  •   2.5 percent ($349 million) under Section 18004(a)(3) for additional funds for
                      institutions under part B of title VII of the Higher Education Act of 1965, as
                      amended, through the Fund for the Improvement of Postsecondary Education
                      (FIPSE), to prioritize schools that received less than $500,000 under other parts
                      of Section 18004 by distributing funds in an amount that, when added to funds
                      received under Section 18004(a)(1) and Section 18004(a)(2), brings each



U.S. Department of Education
Office of Inspector General
ED-OIG/I20DC0013                                                                                          1
                          institution eligible to receive funds through the FIPSE program to an award
                          amount of $500,000 (CFDA 84.425N).

                  Reporting Requirements and Data Collection
                  Institutions receiving funds under Section 18004 of the CARES Act are required to
                  submit (in a time and manner required by the Secretary) a report to the Secretary
                  describing the use of funds distributed from HEERF (Section 18004(e)). In April 2020, the
                  U.S. Department of Education (Department) released guidance directing recipients to
                  complete a Certification and Agreement for Recipient’s Institutional Costs. The
                  certification and agreement states that recipients will submit required quarterly reports
                  to the Secretary, at such time and in such manner and containing such information as
                  the Secretary may reasonably require. In October 2020, the Department hosted a
                  webinar to provide an overview of HEERF grant reporting requirements. During the
                  webinar, the Department released a quarterly public reporting form for Section
                  18004(a)(1) Institutional Portion, 18004(a)(2), and 18004(a)(3) funds. 1 Recipients must
                  post the quarterly reporting form on their primary websites. Recipients were also
                  encouraged to email the link to the Department for record-keeping purposes once
                  reports were posted. The first report was due October 30, 2020, covering the period
                  from first award through September 30, 2020. Subsequent reports are due quarterly
                  and must be posted no later than 10 days after the calendar quarter.




1
    https://www2.ed.gov/about/offices/list/ope/heerf-quarterly-reporting-v131.pdf

U.S. Department of Education
Office of Inspector General
ED-OIG/I20DC0013                                                                                         2
                Results
                The objective of our inspection was to determine (1) whether selected institutions
                receiving funds under the Institutional Portion of HEERF met public reporting
                requirements and (2) the reported usage of the Institutional Portion of HEERF by
                selected institutions. We focused on the first quarterly report, due October 30, 2020,
                covering the period from the date of the first HEERF grant award through
                September 30, 2020.

                We reviewed a nonstatistical sample of 100 institutions that received funding under
                Section 18004(a)(1) of the CARES Act to determine whether they met reporting
                requirements in the CARES Act and the Recipient’s Funding Certification and Agreement
                for the Institutional Portion of the Higher Education Emergency Relief Fund Formula
                Grants Authorized by Section 18004(a)(1) of the CARES Act. Our sample consisted of the
                20 institutions that received the highest amount of funding under the Institutional
                Portion of HEERF and a random sample of 80 institutions, consisting of 20 recipients
                randomly selected from each of 4 categories—State-Controlled Institutions of Higher
                Education, Private Institutions of Higher Education, Profit Organizations, and Other. 2 Of
                the 100 institutions included in our sample, 44 also received funding under Section
                18004(a)(2); 6 institutions also received funding under Section 18004(a)(3).

                A draft of this report was provided to the Office of Postsecondary Education (OPE) for
                comment. In its response, OPE acknowledged that while the report does not require a
                formal corrective action plan, it agreed with the suggestions noted and identified
                actions it is taking or plans to take to address them.

                We did not make any substantive changes to the report as a result of OPE’s comments.
                The full text of OPE’s response is included at the end of this report.

                Compliance with Reporting Requirements
                We determined that 81 of the 100 institutions included in our sample complied with
                Institutional Portion reporting requirements. We noted that 80 of the institutions
                posted reports on their websites dated on or before the October 30, 2020, deadline and
                that 1 posted a report dated October 31, 2020.




2
  The Other category consists of all other institution types, as defined by the Federal Assistance Award
Data System, that received Institutional Portion funds. Our sample included institutions categorized as
Independent School Districts, Non-Profit Organizations, State, County or Local Governments, and Small
Businesses.

U.S. Department of Education
Office of Inspector General
ED-OIG/I20DC0013                                                                                           3
                We were unable to locate Institutional Portion reports anywhere on the websites
                associated with 19 of the 100 (19 percent) institutions included in our sample. These
                19 institutions had drawn down over $5.5 million out of almost $29 million (19 percent)
                awarded to these institutions as of September 30, 2020, the end of the reporting
                period. 3 Eight of the 19 (42 percent) non reporting institutions were Profit
                Organizations. Six of the 19 institutions (32 percent) also received funding under
                Section 18004 (a)(2). [See Figure 1 for a breakdown of non-reporting sampled institution
                types.]

                  Figure 1. Non-Reporting Sampled Institution Types


                                                           5%
                                                     5%                  16%




                                                                                32%
                                               42%




                            State Controlled     Private        Profit         Other   Highest Awards




                As part of a different ongoing concurrent Office of Inspector General (OIG) HEERF
                review related to selected institutions’ use of HEERF funds, we reviewed schools with
                risk factors 4 and identified four additional institutions that were not included in our
                sample for this review for which the audit team could not locate quarterly Institutional
                Portion reports. These four institutions had drawn down all of their awarded funds—
                over $4 million as of September 30, 2020, the end of the reporting period.




3
  Because funds awarded under Section 18004 are all reported on the same form, our review includes
information related to Section 18004(a)(2) and Section 18004(a)(3) funding, where applicable, for
schools that were selected as part of our sample of Section 18004(a)(1) schools that also received these
funds.
4
 These institutions were identified as being on Federal Student Aid’s quarterly heightened cash
monitoring report dated September 1, 2020, had minimal grant experience, and/or were awarded more
than $1 million in HEERF Institutional and Student Aid Portion funds combined.

U.S. Department of Education
Office of Inspector General
ED-OIG/I20DC0013                                                                                           4
              Further, we found that 6 of the 27 (22 percent) institutions in our sample that reported
              expenditures in the Other Uses category did not follow Department instructions or did
              not provide sufficient detail. Specifically, 1 of the 27 institutions that reported
              expenditures under the Other Uses category did not provide explanatory notes in
              accordance with Department instructions. We also noted that at least four institutions
              reported Other Uses expenditures that appeared to fall under another reporting
              category, including costs associated with transitioning to online instruction, refunds to
              students, and staff training. Finally, we noted that one institution described its Other
              Uses expenditures simply as “indirect costs” with no further explanation.

              Reported Usage of Funds
              According to the posted quarterly reports, as of September 30, 2020, the 81 reporting
              institutions have spent over $283 million (45 percent) of the total Institutional Portion
              funds obligated to them under Section 18004(a)(1). The 38 institutions that also
              received funds under Section 18004(a)(2) and the 6 institutions that received funds
              under Section 18004(a)(3) reported expenditures of 17 percent and 11 percent of
              obligated funds, respectively (see Table 1).

                   Table 1. Percentage of Award Spent—All Reporting Sampled Institutions
                        Fund         Total Amount Spent             Percentage Spent

                        (a)(1)           $283,395,340                     45%

                        (a)(2)              14,568,773                    17%

                        (a)(3)                 196,857                    11%

                        Total            $298,160,970                     42%



              Section 18004(a)(1)
              Of the 81 institutions that reported, we noted that the most frequently reported
              expenditure categories for Section 18004(a)(1) funds included Campus Safety
              (48 institutions), Additional Distance Learning Equipment (41 institutions), Tuition
              Reimbursement (35 institutions), Technology Hardware (29 institutions), and Other




U.S. Department of Education
Office of Inspector General
ED-OIG/I20DC0013                                                                                          5
                Uses 5 (27 institutions). The majority of Section 18004(a)(1) funds were spent on Tuition
                Reimbursement (56 percent).

                Conversely, the least frequently reported categories by the 81 reporting institutions
                included Subsidized Off-Campus Housing (7 institutions) and Subsidized Food Service
                (4 institutions). Overall, institutions spent less than 4 percent of Section 18004(a)(1)
                funds on Subsidized Off-Campus Housing (2 percent), Additional Class Sections
                (.7 percent), Internet (.6 percent), Staff Training (0.4 percent), and Subsidized Food
                Service (0.1 percent). [See Figure 2 below for a breakdown per category of number of
                institutions reporting and percentage of expentures reported.]

                Figure 2. Section 18004(a)(1) Reporting per Category—All Reporting Sampled
                Institutions


                      60                                                                                  60%

                      50                                                                                  50%

                      40                                                                                  40%

                      30                                                                                  30%

                      20                                                                                  20%

                      10                                                                                  10%

                       0                                                                                  0%




                               Number of Institutions Reporting      Percentage of Expenditures


                A further breakdown of reported expenditures by institution type, to include top
                expenditure categories reported and top category by percentage of expenditures
                reported, is noted in Table 2 below.




5
  Examples of Other Uses expenditures included faculty and staff payroll during transition to online
instruction, costs to ship remote learning technology, rent, utilities, and other costs associated with
reduced classroom capacity.

U.S. Department of Education
Office of Inspector General
ED-OIG/I20DC0013                                                                                               6
              Table 2. Breakdown of Reported Expenditures

                                      Top 3 Expenditure Categories              Top Category
               Institution Type        (Percentage of Institutions       (Percentage of Expenditures
                                               Reporting)                         Reported)

                                      Tuition Reimbursement (68.4%)
                                          Campus Safety (57.9%)
                Highest Awards                                           Tuition Reimbursement (56%)
                                        Additional Distance Learning
                                            Equipment (52.6%)

                                          Campus Safety (52.9%)
                State-Controlled
                                       Technology Hardware (47.1%)       Tuition Reimbursement (60%)
                   Institutions
                                      Tuition Reimbursement (47.1%)

                                       Tuition Reimbursement (50%)
                                          Campus Safety (35.7%)
               Private Institutions                                      Tuition Reimbursement (91%)
                                        Additional Distance Learning
                                            Equipment (35.7%)

                                          Campus Safety (83.3%)
                                      Additional Instruction Equipment
              Profit Organizations                 (58.3%)               Technology Hardware (27%)
                                        Additional Distance Learning
                                            Equipment (58.3%)

                                        Additional Distance Learning
                                            Equipment (73.7%)
                      Other                                                  Campus Safety (26%)
                                          Campus Safety (68.4%)
                                            Other Uses (42.1%)



              Observations noted regarding reported expenditures include the following:

                  •    Campus Safety was a reported expenditure category by all institution types.
                       Reported uses of funds under this category included Personal Protective
                       Equipment, hand sanitizer, cleaning supplies, and supplies and signage to
                       promote social distancing.
                  •    Tuition Reimbursement was a frequently reported expenditure category by
                       State-Controlled Institutions, Private Institutions, and institutions receiving the
                       highest award amounts.
                  •    Additional Distance Learning Equipment was a frequent expenditure category
                       by Private Institutions, Profit Organizations, institutions receiving the highest
                       award amounts, and Other institutions. Reported uses of funds under this


U.S. Department of Education
Office of Inspector General
ED-OIG/I20DC0013                                                                                             7
                      category included equipment and software needed to support online
                      instruction.
                  •   Technology Hardware was an expenditure reported by almost half of State-
                      Controlled Institutions; Additional Instructional Equipment was an expenditure
                      reported by over half of Profit Organizations. Reported uses of Technology
                      Hardware included laptops and software for student use. Reported uses of
                      Additional Instructional Equipment included scientific mannequins and science
                      kits for students to conduct laboratory sessions remotely.
                  •   Over 40 percent of institutions in the Other category reported Other Uses for
                      expenditures. These Other Uses included:
                          o    Administrative overhead;
                          o    Making registration forms available online and accessible;
                          o    Cost of student workers that would have been laid off because the
                               campus was shut down;
                          o    Indirect costs;
                          o    COVID mitigation personnel expense;
                          o    Marketing;
                          o    Non-refundable travel;
                          o    Tuition assistance/scholarships for students whose education was
                               negatively impacted due to the disruption of campus operations;
                          o    Support of employee remote work;
                          o    Travel disruption expenses;
                          o    Support of emergency non-tuition related student needs;
                          o    Loss of rental revenue; and
                          o    Costs associated with the significant changes to the delivery of
                               instruction due to COVID-19.

                  •   Tuition Reimbursement comprised the largest amount of expenditures for
                      Private Institutions (91 percent), State-Controlled Institutions (60 percent), and
                      institutions receiving the highest award amounts (56 percent).
                  •   Technology Hardware comprised the largest amount of expenditures for Profit
                      Organizations (27 percent); Campus Safety comprised the largest amount of
                      expenditures for Other institutions (26 percent).




U.S. Department of Education
Office of Inspector General
ED-OIG/I20DC0013                                                                                           8
                Section 18004(a)(2)
               While 38 of the 44 institutions that also received Section 18004 (a)(2) funds posted
               reports as required, only 18 reported expenditures of Section 18004(a)(2) funds during
               this reporting quarter. We noted that the most frequently reported expenditure
               categories for the 18 institutions 6 that received and reported Section 18004(a)(2) funds
               included Campus Safety (6 institutions), Additional Emergency Financial Aid Grants to
               Students (6 institutions), Tuition Reimbursement (3 institutions), and Tuition Discounts
               (3 institutions). The largest portion of Section 18004(a)(2) funds were spent on
               Additional Emergency Financial Aid Grants to Students (35 percent). However, only
               institutions in the Highest Awards and State-Controlled Institution categories reported
               any spending under this category. State-Controlled institutions reported the largest
               portion of their expenditures under Additional Class Sections; Other institutions
               reported the largest portion of their expenditures under Replacing Lost Revenue due to
               Lost Enrollment. The Private institution reported all of its expenditures in the Tuition
               Reimbursement category. [See Figure 3 below for a breakdown per category of number
               of institutions reporting and percentage of expenditures reported.]




6
 Of the 18 institutions in our sample that received and reported expenditures of Section 18004(a)(2)
funds, 6 were in the Highest Awards category, 7 were in the State-Controlled Institutions category,
1 was in the Private Institutions category, and 4 were in the Other category.

U.S. Department of Education
Office of Inspector General
ED-OIG/I20DC0013                                                                                       9
               Figure 3. Section 18004(a)(2) Reporting per Category—All Reporting Sampled
               Institutions


                          7                                                                           40%

                          6                                                                           35%
                                                                                                      30%
                          5
                                                                                                      25%
                          4
                                                                                                      20%
                          3
                                                                                                      15%
                          2
                                                                                                      10%
                          1                                                                           5%
                          0                                                                           0%




                               Number of Institutions Reporting      Percentage of Expenditures


               Section 18004(a)(3)
               For the six institutions 7 in our sample that received Section 18004(a)(3) funds, while all
               six institutions reported, only two institutions reported Section 18004(a)(3)
               expenditures. Expenditures were reported in three categories: Replacing Lost
               Revenue—Non-Tuition, Additional Distance Learning Equipment, and Other Uses. The
               majority of 18004(a)(3) funds were spent on Replacing Lost Revenue—Non-Tuition
               (93 percent).

               Department Oversight Efforts
               In discussions with OPE officials, they noted that they are monitoring institutional
               compliance with HEERF reporting requirements and that their initial focus was on
               Student Aid Portion reporting. With regard to Institutional Portion reporting, OPE
               officials noted that they are in the process of compiling a database of institutions that



7
 Both institutions in our sample that received and reported Section 18004(a)(3) funds were in the Other
category.

U.S. Department of Education
Office of Inspector General
ED-OIG/I20DC0013                                                                                           10
              sent links to their quarterly Institutional Portion reports, similar to what they compiled
              for quarterly Student Aid Portion reporting. As of December 10, 2020, OPE officials
              stated that they had compiled links to Institutional Portion reports for approximately
              1,500 institutions and indicated that they do verify that the reports are posted at the
              identified links. They have also recently begun searching for reports from institutions
              that did not provide links. During January 2021, they expect to be implementing the
              same process that they have implemented for the Student Aid Portion reports. This
              consisted of follow-up emails to institutions with missing reports or incorrect
              information. The officials noted that they would also likely follow up with institutions
              that did not provide enough context in the explanatory notes regarding the Other Uses
              category on the Institutional Portion reports. Institutions not complying with reporting
              requirements after several follow up attempts are receiving a formal letter. The letter
              identifies that the institution is not in compliance with reporting requirements and
              provides a date by which it must become compliant or else it will face enforcement
              actions. These actions include placing the institution in high-risk status and/or
              terminating the institution’s HEERF grants.




U.S. Department of Education
Office of Inspector General
ED-OIG/I20DC0013                                                                                      11
              Other Matter
              Section 18004(c) of the CARES Act allows institutions to use up to one-half of the total
              funds received under Section 18004(a)(1) to cover any costs associated with significant
              changes to the delivery of instruction due to COVID-19. The funding for the Institutional
              Portion is separate from the funding made available for the Student Aid Portion.
              Institutions must have previously entered into the funding certification and agreement
              for the Student Aid Portion to be eligible to receive funds for the Institutional Portion.

              To determine whether institutions receiving an award under the Institutional Portion of
              HEERF had met this condition, we reviewed the universe of institutions that received an
              award under the Institutional Portion of HEERF to identify whether these institutions
              had previously received an award under the Student Aid Portion. We attempted to
              match Institutional Portion awards with Student Aid Portion awards based on Recipient
              Identification (Recipient ID), OPE Identification (OPE ID), Data Universal Numbering
              System (DUNS) number, Tax Identification Number (TIN), institution name and/or award
              amount. Overall, we found that 3 of 4,649 Institutional Portion awards did not match to
              a HEERF Student Aid Portion award based on any of the noted fields. We found
              weaknesses in matches associated with 16 additional Institutional Portion awards, to
              include the following:

                  •   four Institutional Portion awards only matched Student Aid Portion awards by
                      institution name and award amount. Other identifying information including
                      Recipient ID, OPEID, DUNS, and TIN did not match;
                  •   one Institutional Portion award had a Student Aid Portion award of $0;
                  •   one institution appeared to have a matching Student Aid Portion award based
                      on the award amount and the first and last name of a specific individual
                      identified as a contact person at the institution for the awards. However,
                      because the institution name, Recipient ID, OPEID, DUNS number, and TIN do
                      not match, it is unclear whether these awards are associated with the same
                      institution;

                  •   ten Institutional Portion awards matched to a Student Aid Portion award by
                      institution name, award amount, and TIN. Other identifying information
                      including Recipient ID, OPEID, and DUNS did not match.
              We provided OPE officials with the detailed information associated with the anomalies
              identified above. After reviewing OPE’s response in conjunction with associated
              information in G5, we still have concerns associated with two of the three awards for
              which we could not find an associated Student Aid Portion award. Student Aid Portion
              awards noted by OPE as matching awards appeared to already have another
              Institutional Portion award match that was not related to the Institutional awards we

U.S. Department of Education
Office of Inspector General
ED-OIG/I20DC0013                                                                                      12
              noted and did not match on recipient name and/or award amount. Regarding the
              Institutional Portion award for which the Student Aid Portion award was $0, OPE
              indicated that the Student Aid Portion was deobligated in error because of what
              appeared to be a duplicative application but did not note whether the funds had in fact
              been awarded or were being reobligated. Regarding the other anomalies noted, OPE
              essentially indicated agreement with the matches we noted and did provide matching
              OPEIDs for several of the awards but did not provide any explanations regarding why
              other identifying fields did not match. We are providing related suggestions below
              regarding the unresolved anomalies and note that we may perform additional work
              related to these issues in the future.

              Suggestions
              We suggest that OPE further review the anomalies noted for awards without matching
              Student Aid Portion awards, ensure that funds were awarded to the recipient for which
              it mistakenly deobligated funds, and continue to research reasons for other anomalies
              noted related to recipient identifiers, taking needed corrective actions as warranted.

              Office of Postsecondary Education Comments
              OPE stated that it agrees with the suggestions. It acknowledged the grant that was
              deobligated in error and stated that staff are currently working with the Office of the
              General Counsel to correct it. OPE stated that it will continue to conduct quality control
              checks to identify and correct any other anomalies. OPE noted that it has created a unit
              specifically dedicated to administering and monitoring HEERF grants for which it is
              currently in the hiring phase.

              OIG Response
              OIG acknowledges OPE’s plans to implement the noted actions to address the
              suggestions as well as OPE’s noted efforts related to administering and monitoring
              HEERF grants.




U.S. Department of Education
Office of Inspector General
ED-OIG/I20DC0013                                                                                      13
              Appendix A. Scope and Methodology
              To answer our objective, we reviewed the laws, criteria, and guidance related to HEERF
              reporting requirements. We conducted discussions with OPE officials and staff to gain
              an understanding of the program and efforts by the Department to ensure grantee
              compliance with reporting requirements. We also reviewed prior OIG, Government
              Accountability Office and other Federal agencies’ reports related to our objective.

              For the institutions included in our sample, we reviewed quarterly public reporting
              forms posted on institution websites to determine whether they met reporting
              requirements in the CARES Act and the Recipient’s Funding Certification and Agreement
              for the Institutional Portion of the Higher Education Emergency Relief Fund Formula
              Grants Authorized by Section 18004(a)(1) of the CARES Act. In addition, we compiled
              information related to the expenditure categories reported by the institutions on their
              quarterly reports.

              Sampling Methodology
              Using the Department’s grants management system, G5, we identified a universe of
              4,649 institutions that received HEERF funds specific to the Institutional Portion (CFDA
              84.425F) under Section 18004(a)(1) of the CARES Act. We stratified the universe into
              four categories by institution type, as defined by the Federal Assistance Award Data
              System: State-Controlled Institutions of Higher Education, Private Institutions of Higher
              Education, Profit Organizations, and Other. We then selected a random sample of
              20 institutions from each category, for a total of 80 institutions. Because we did not
              weight the sample results by their probabilities of selection, the percentages reported in
              this audit are not statistical estimates and should not be projected over the unsampled
              grants.

              Our sample also included a judgmental selection of the 20 institutions receiving the
              highest award amounts. Since we selected these institutions judgmentally, results
              described in this report related to these institutions may not be representative of all
              institutions and should not be projected.

              In total, we selected 100 institutions for review, representing $649,726,605 of the
              $6,126,606,069 awarded under the Institutional Portion of Section 18004(a)(1).

              Use of Computer-Processed Data
              We relied on computer-processed data obtained from the Department’s G5 system. We
              used G5 for the purpose of identifying the universe of grants awarded under Section
              18004(a)(1) and related obligation and drawdown amounts. G5 is the official system of
              record for the Department’s grants data and is widely used and relied on by Department


U.S. Department of Education
Office of Inspector General
ED-OIG/I20DC0013                                                                                        14
              officials. As a result, we considered it to be the best available data for the purpose of
              our review.

              Compliance with Standards
              We conducted fieldwork at Department offices in Washington D.C. from October 2020
              through December 2020.

              We conducted this inspection in accordance with the Council of the Inspectors General
              on Integrity and Efficiency’s “Quality Standards for Inspection and Evaluation” as
              appropriate to the scope of the inspection described above. Those standards require
              that we plan the work to obtain sufficient and appropriate data and other information
              to provide a reasonable basis for our conclusions. We believe that the information
              obtained provides a reasonable basis for the conclusions contained in the report.




U.S. Department of Education
Office of Inspector General
ED-OIG/I20DC0013                                                                                          15
              Appendix B. Acronyms and Abbreviations
               CARES Act       Coronavirus Aid, Relief, and Economic Security Act

               COVID-19        Coronavirus Disease 2019

               CFDA            Catalog of Federal Domestic Assistance

               Department      U.S. Department of Education

               DUNS            Data Universal Numbering System

               FIPSE           Fund for the Improvement of Postsecondary Education

               HEERF           Higher Education Emergency Relief Fund

               institutions    Institutions of higher education

               OIG             Office of Inspector General

               OPE             Office of Postsecondary Education

               OPEID           Office of Postsecondary Education Identification

               Recipient ID    Recipient Identification

               TIN             Tax Identification Number




U.S. Department of Education
Office of Inspector General
ED-OIG/I20DC0013                                                                     16
               Office of Postsecondary Education Comments

                          UNITED STATES DEPARTMENT OF EDUCATION
                                 OFFICE OF POSTSECONDARY EDUCATION




MEMORANDUM

DATE:                  February 18, 2021

TO:                    Bryon S. Gordon
                       Assistant Inspector General for Audit

FROM:                  Michelle Asha Cooper, Ph. D
                       Acting Assistant Secretary
                       Office of Postsecondary Education

SUBJECT:               Comments on Draft Audit Report-- “Higher Education Emergency Relief
                       Fund Reporting Requirements,” ED-OIG/I20DC0013

Thank you for providing us the opportunity to comment on the draft audit report. We have
reviewed the draft audit report, “Higher Education Emergency Relief Fund Reporting
Requirements,” ED-OIG/I20DC0013 and are providing comments to the report through this
memorandum. As requested, we are sending a copy of this memo, as a PDF file to Michele
Weaver-Dugan, Regional Inspector General for Audit, Internal Operations/Philadelphia Audit
Team (Michele.Weaver-Dugan@ed.gov). We are also including an electronic copy in a
Microsoft Word file to meet accessibility requirements of Section 508 of the Rehabilitation Act
of 1973, as amended.

It is our understanding that the objective of the inspection was to determine (1) whether selected
institutions receiving funds under the Institutional Portion of HEERF met public reporting
requirements and (2) the reported usage of the Institutional Portion of HEERF by selected
institutions. Further, the report focused on the first quarterly report, which grantees were to post
on their websites by October 30, 2020, covering the period from the date of the first HEERF
grant award through September 30, 2020. Additionally, we acknowledge that while the report
does not require a formal corrective action plan, we will address the suggestions included in the
report.

We provide our specific comments on the draft report as follows:



U.S. Department of Education
Office of Inspector General
ED-OIG/I20DC0013                                                                                  17
Suggestions – Office of Postsecondary Staff need to further review the anomalies noted for
awards without matching Student Aid Portion award, ensure that funds were awarded to
the recipient for which it mistakenly de-obligated funds, and continue to research reasons
for other anomalies noted related to recipient identifiers, taking needed corrective actions
as warranted.

RESPONSE

We agree with OIG’s suggestions. The Department acknowledges the anomaly referenced in the
sampling. The grant award P425E204186 was de-obligated in error because it was mistakenly
identified as a duplicative application. During OIG’s engagement with ED, OIG requested that
ED review the “E” Student portion award and the “F” Institutional portion award match between
applications P425F202830 and P425E204186. After staff reviewed the application, the error was
identified, and staff is working with the Office of General Counsel to correct the obligation.

In reference to OIG’s suggestion for OPE staff to continue to research any other possible
anomalies, the Department acknowledges that it will continue to conduct quality control checks
to identify and correct any other anomalies. To this end, given the additional workload that has
been created for OPE staff, we have created a unit specifically dedicated to administering and
monitoring HEERF grants. While we are still in the hiring phase for the unit, we have identified
a Director for this unit.

Thank you for the opportunity to respond to the draft audit report. If you have questions about
any of our comments, please contact Karen.Epps@ed.gov Director for the Emergency Assistance
Response Unit.




cc:    Michele Weaver-Dugan




U.S. Department of Education
Office of Inspector General
ED-OIG/I20DC0013                                                                              18


File and source

File
ed-oig-heerf-reporting_Selected-Schools-HEERF-Reporting-Requirements.pdf
Size
2,575,801 bytes
SHA-256
e754b51562194cd404ddac2c77e2abffdfe29cb5b8b3a66942840fd0affb57db
Our copy
ed-oig-heerf-reporting_Selected-Schools-HEERF-Reporting-Requirements.pdf
Original
oig.ed.gov
Back to top