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.
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- 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/
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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
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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
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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.
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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.
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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
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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.
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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
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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).
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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.
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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.
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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.
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Office of Inspector General
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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
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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.
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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
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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.
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Office of Inspector General
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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
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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
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