U.S. Department of Education's Higher Education Emergency Relief Fund Audit Resolution Activities (ED-OIG/F23AS0141)
Summary
A final flash report, ED-OIG/F23AS0141, dated November 15, 2023, from the U.S. Department of Education Office of Inspector General on the Department's audit resolution activities for the Higher Education Emergency Relief Fund (HEERF). It states that the number of independent audits with HEERF findings requiring resolution by the Grants Risk Management Services Division (GRMSD) increased significantly while the number of GRMSD staff assigned to audit resolution remained relatively constant, resulting in a more than fourfold increase in audits assigned per person. It states that GRMSD assigned 110 audits to staff for resolution in FY 2019 and 112 in FY 2020, reaching 497 by June of FY 2023. It also states that the Department awarded more than $76 billion in HEERF grants to over 4,900 schools.
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
- 2023-11-15
Cite this document
“U.S. Department of Education's Higher Education Emergency Relief Fund Audit Resolution Activities (ED-OIG/F23AS0141).”
U.S. Department of Education, Office of Inspector General, dated 2023-11-15. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/heerf-audit-resolution-activities/
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U.S. Department of Education
Office of Inspector General
U.S. Department of Education’s
Higher Education Emergency
Relief Fund Audit Resolution
Activities
November 15, 2023
ED-OIG/F23AS0141
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
November 15, 2023
TO: Denise L. Carter
Acting Assistant Secretary, Office of Finance and Operations, and Delegated to Perform
the Functions and Duties of the Chief Financial Officer
FROM: Bryon S. Gordon /s/
Assistant Inspector General for Audit
SUBJECT: Final Flash Report, “U.S. Department of Education’s Higher Education Emergency Relief
Fund Audit Resolution Activities,” Control Number ED-OIG/F23AS0141
Attached is the subject final report that consolidates the results of our review of the U.S. Department of
Education’s Higher Education Emergency Relief Fund audit resolution activities. We have provided an
electronic copy to your audit liaison officer. We received your comments agreeing with the
recommendations in our draft report.
U.S. Department of Education policy requires that you submit a 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 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 recommendations that have not been completed 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 bryon.gordon@ed.gov or Keith Cummins, Director, State and Local Advisory and
Assistance Team, at (202) 657-8542 or keith.cummins@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.
Purpose
The purpose of this report is to present information on independent audits with findings
pertaining to the Higher Education Emergency Relief Fund (HEERF) 1 and audit resolution
activities conducted by the U.S. Department of Education (Department). The
significance of the information presented in this report and need for immediate action
by Department management is elevated by the amount of funding provided through the
HEERF program and the Department’s reliance on independent audits as a key
component of its oversight of HEERF grants. This report includes recommendations to
the Department to further assess and strengthen its ability to resolve HEERF audit
findings in a timely and effective manner.
What We Did
We compiled and summarized available information on single and proprietary school
audits with HEERF findings, the status of HEERF audit resolution activities, and audit
resolution staffing levels from April 2020 through June 2023. We interviewed officials
from the Department’s Office of Finance and Operations (OFO), Office of Postsecondary
Education (OPE), and Federal Student Aid (FSA) office regarding their roles and
responsibilities for audit resolution. We obtained and reviewed audit assignment and
resolution information for single audits and HEERF proprietary school audits from fiscal
year 2 (FY) 2019 3 through FY 2023 from OFO’s Office of Acquisition, Grants, and Risk
Management, Grants Risk Management Services Division (GRMSD).
1
HEERF is one of multiple emergency relief funds comprising the Education Stabilization Fund, which
was first authorized and funded under the Coronavirus Aid, Relief, and Economic Security Act (March 27,
2020), and for which Congress later provided additional funding under the Coronavirus Response and
Relief Supplemental Appropriations Act (December 27, 2020) and the American Rescue Plan (March 11,
2021). HEERF grant award recipients are required to submit annual independent audits to the
Department under certain conditions, such as (1) private nonprofit and public schools that expend
$750,000 or more in Federal awards during the non-Federal entity’s fiscal year, (2) proprietary schools
that expend $500,000 or more in HEERF grant funds during the fiscal year, (3) proprietary schools on
Federal Student Aid’s Heightened Cash Monitoring lists in a fiscal year in which the school expended any
HEERF grant funds, and (4) proprietary schools that closed or were in the process of closing.
2
The Federal government's fiscal year runs from October 1 of one calendar year through September 30
of the next calendar year.
3
FY 2019 audit resolution data was used as the pre-coronavirus baseline for our comparison purposes.
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Office of Inspector General
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What We Found
The number of independent audits with findings pertaining to HEERF and requiring
resolution by GRMSD increased significantly over the past few years, as did the number
of audits with complex findings as determined by GRMSD. However, the number of
GRMSD staff assigned to audit resolution activities remained relatively constant during
this same period—resulting in a more than fourfold increase in the number of audits
assigned for resolution per person. OFO management stated that GRMSD’s staffing
capacity was established to provide audit resolution services for the anticipated volume
of HEERF audits it assessed early in the performance period, but that the volume and
complexity of the audits has increased significantly over time. GRMSD is now facing a
significant backlog of outstanding HEERF audits requiring resolution and without
immediate action, the timeliness and effectiveness of the resolution of HEERF audit
findings could be reduced.
Audit Resolution and Roles and Responsibilities
The Department relies on annual independent audits of public, private non-profit, and
proprietary institutions of higher education (schools) as a primary component of its
oversight of the more than $76 billion in HEERF grants that it awarded to over
4,900 schools. OPE emphasized the importance of independent audits in its two annual
letters 4 to HEERF recipients, stating that
[a]udits form a critical component of the Federal Government’s proper
oversight of grant programs generally, and of the disaster relief
provided during the novel coronavirus (COVID-19) pandemic specifically.
Quality audits are reliable and effective tools to improve the integrity
and effectiveness of the Department programs and help reassure the
American public, the Congress, and the Department’s Office of the
Inspector General that taxpayer dollars are used efficiently and
effectively.
4
The Department’s annual audit requirement letters to HEERF recipients dated March 8, 2021, and
March 23, 2022.
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Generally, the Department’s program offices are responsible for audit resolution for the
grant programs they administer, except for audits under GRMSD’s purview. 5 However,
Department management determined in 2020 that GRMSD would be responsible for
resolving independent audits of HEERF recipients. The Director of GRMSD said the
rationale at the time was that the unit had performed a similar role in resolving
independent audits of other emergency programs authorized under the American
Recovery and Reinvestment Act of 2009.
Data Quality Conditions and Limitations
The scope of our review was limited by certain data quality conditions, noted here and
elsewhere in the report, that must be considered when using the results presented.
Importantly, because GRMSD tracks audits by the date on which they are assigned for
resolution rather than by the fiscal year that they cover, we were not able to accurately
assess when audits were due or the number of audits that should have been submitted.
GRMSD relied on listings provided by the U.S. Census Bureau’s Federal Audit
Clearinghouse (FAC) and FSA’s eZ-Audit contractor 6 as the universe of HEERF audits
entering its audit resolution process. We did not verify the reliability of or otherwise
corroborate GRMSD’s audit resolution tracking data because it was produced by GRMSD
intake processes that relied on the manual review of audit reports. Additional
verification of audit findings for the purpose of assessing the reliability of GRMSD’s
tracking data was beyond the scope of this limited review.
GRMSD’s Audit Resolution Workload
The number of independent audits requiring resolution by GRMSD and the backlog of
unresolved audits have increased significantly in response to audit requirements
covering recipients of HEERF and other coronavirus relief grant funds. As shown in
Figure 1, GRMSD assigned 110 audits to staff for resolution in FY 2019 and 112 in
FY 2020, which represent the baseline of its pre-coronavirus audit resolution workload.
After the Department started receiving audits required by the coronavirus relief
programs in FY 2021, the number of audits that GRMSD assigned to staff for resolution
5
GRMSD is responsible for the resolution of all findings from external audits of the Department’s
discretionary grant programs and findings involving cash management and subrecipient monitoring from
external audits of the Department’s formula grant programs.
6
FSA’s contractor administers its eZ-Audit web application that provides proprietary schools receiving
funding from HEERF and student financial assistance from other Department programs with a paperless,
single point of submission for financial statements and compliance audits.
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sharply increased—reaching 497 by June of FY 2023, the end of the period covered by
this review. Single audits with HEERF findings have been the largest contributing factor
in the increase of the overall number of audits that GRMSD assigned to staff for
resolution since the beginning of the coronavirus pandemic. As shown in Figure 1, the
number of single audits with HEERF findings that GRMSD assigned to staff grew by
about 260 percent starting in FY 2021 and continuing through FY 2023. It is important to
note that the data points in Figure 1 do not include the additional HEERF proprietary
school audits that GRMSD received for FY 2021 and subsequent submissions because
GRMSD had yet to complete intake processing and assignment of those audits, as
discussed in the HEERF Proprietary School Audit Resolution section below.
Figure 1. Audits GRMSD Assigned to Staff for Resolution from FY 2019–FY 2023 7
Additionally, as shown in Figure 2, the total number of audits that were assigned to staff
but that were not resolved increased by 400 percent from FY 2021 yearend to FY 2022
yearend, indicating that the backlog of audits awaiting resolution has grown
substantially. A GRMSD official said that this was one method for tracking backlog, but
also noted that these unresolved audits would not always be considered untimely.
Another measure of the backlog of audits requiring resolution that can be observed in
GRMSD’s tracking data is overdue audits at yearend. The number of overdue audits at
yearend increased by 163 percent from FY 2021 to FY 2022.
7
The data for FY 2023 provided in this figure cover the period October 2022 through June 2023.
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Figure 2. Active and Overdue Audits at Yearend from FY 2019–FY 2023 8
Uncertainty exists regarding the completeness of GRMSD’s records of audits requiring
resolution because it had not assessed recipient expenditure data and other records to
ensure that all audits required by HEERF grant award conditions entered its tracking
process for each annual audit cycle. 9 GRMSD’s records were limited to independent
audits received and processed through its intake procedures. Consequently, the results
presented in this report are based on the audits received by the Department and do not
necessarily account for all required HEERF recipient audits, including incidents where
HEERF recipients did not submit audits to the Department as required by grant award
conditions.
HEERF Proprietary School Audit Resolution
GRMSD has not made adequate progress on its resolution of HEERF proprietary school
audits over the past year and has not identified the number of audits with findings from
FSA’s 2021 submission that it will need to resolve. GRMSD’s processes for the intake and
resolution of HEERF proprietary school audits are separate from its single audit
8
The data for FY 2023 provided in this figure cover the period October 2022 through June 2023.
9
A GRMSD official said that completeness checks were performed in the past under normal conditions;
however, management determined that it would be impractical to assess for HEERF grants because of
the number of award recipients and expected increases in resolution workload. The official also said that
in FY 2021, OPE officials conducted some limited completeness checks and identified several recipients
that had not submitted independent audits as required by the applicable grant award conditions.
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resolution processes. The Director of GRMSD said that additional overtime funding for
staff would have been applied to resolve HEERF proprietary school audits, but that
expected funding for this purpose was reduced, as discussed further below. GRMSD’s
tracking records indicated that the HEERF proprietary school audits from FSA’s 2020
submissions are nearly resolved. Because of our data quality concerns and lack of
processed audit records for FSA’s 2021 submissions, we did not conduct additional
review procedures related to GRMSD’s resolution of HEERF proprietary school audits.
GRMSD had to create the audit resolution and tracking process for HEERF proprietary
school audits on short notice after realizing that the process used for single audits was
not feasible due to implementation challenges. FSA’s eZ-Audit contractor 10 codes HEERF
proprietary school audits as they are submitted into eZ-Audit and then provides FSA
with listings of HEERF proprietary school audits on a rolling basis. FSA then periodically
forwards these listings to GRMSD in batches for resolution. GRMSD began resolving
audits from FSA’s 2020 submissions in November 2021.
Staffing Levels Assigned to Audit Resolution Activities
The number of GRMSD staff assigned to audit resolution activities remained relatively
constant even as its workload increased significantly during the period covered by our
review. In FY 2019, before the coronavirus pandemic began, 6.5 full-time equivalent
(FTE) staff were assigned to the Department’s audit resolution activities according to
GRMSD’s records. In July 2020, the Department’s former Audit Resolution and Risk
Management Services divisions merged to create GRMSD. During this period of
reorganization and through FY 2021, attrition reduced the staffing level assigned to
audit resolution activities to an average of five FTEs. The combined audit resolution and
risk management staff generally retained their respective roles and responsibilities until
around May 2023, when three staff whose primary responsibilities related to risk
management activities were assigned audit resolution activities in addition to their
regular duties. This adjustment increased the staff assigned to audit resolution activities
to an average of 6.25 FTEs for FY 2022 and FY 2023. See Figure 3.
10
FSA’s existing eZ-Audit contractor administers the Department’s process for the intake of Title IV
proprietary school audit submissions.
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Figure 3. FTEs Assigned to Audit Resolution Activities from FY 2019–FY 2023 11
GRMSD offered overtime hours for existing staff in December 2021 to address the
additional workload created by the increase in audits required by the coronavirus relief
programs. According to the Director of GRMSD, his division spent about $35,000 on
overtime payments, but expected funding for this purpose was reduced, creating an
approximately $65,000 gap needed to address the increased workload. The Director of
GRMSD said that OFO management requested additional funding and provided data on
staffing needs in support of the request but had not received any additional funding at
the time of this review. The Director also said that OFO management considered
outsourcing HEERF audit resolution activities but decided against it based on challenges
that staff experienced when the resolution process was outsourced for audits of
emergency programs authorized by the American Recovery and Reinvestment Act of
2009.
HEERF Audit Resolution Procedures and Finding Complexity
When GRMSD made its initial assignments of HEERF single audits to staff for resolution
in November 2020, the Director advised staff to use existing abbreviated resolution
11
The data for FY 2023 provided in this figure cover the period October 2022 through June 2023.
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procedures 12 to increase the timeliness of resolving audit findings at the lower range of
the complexity scale, with ratings from 1 through 3. GRMSD’s audit finding complexity
scale consists of ratings from 1 through 5, with audits rated 1 being the least complex
and audits rated 5 being the most complex. Audits with complexity ratings of 1 through
3 contain findings with questioned costs under $100,000 13 and generally less complex
recommended corrective actions, such as procedural enhancements. Audits with
complexity ratings of 4 or 5 contain findings with questioned costs over $100,000, a
recommendation for the Department itself to determine the appropriate amount of
questioned costs, or material compliance issues that are nonmonetary in nature or
require coordination with other Department offices to resolve.
The number of audits with HEERF findings that GRMSD rated at the higher range of the
complexity scale (ratings of 4 or 5), grew from a total of 9 in FY 2021, to 13 in FY 2022,
to 37 through June of FY 2023—an increase of more than 300 percent during the period
covered by our review. GRMSD staff were required to perform full resolution
procedures on these higher complexity audits that included additional verification
activities beyond the abbreviated resolution procedures, such as coordination with the
Office of General Counsel and OPE. OPE officials provided HEERF subject matter
expertise on various programmatic or compliance issues at weekly audit work group
meetings and in response to audit-specific requests from GRMSD, in addition to OPE’s
other oversight activities covering HEERF. While GRMSD was able to apply the
abbreviated resolution procedures for most findings, the increasing number of audits
with complex HEERF findings required additional work to resolve, reduced the
timeliness of the resolution process, and contributed to backlogs of unresolved HEERF
audits.
12
According to the Department’s “Handbook for External Post Audit Process” (ACSH-OFO-007),
abbreviated resolution can be used when it is clear that corrective actions have been or can be fully
implemented quickly, a serious violation does not exist, the grantee has no other open audits, the audit
meets applicable guidance and standards, there are no open repeat findings, and the findings are
procedural or questioned costs are less than $25,000.
13
GRMSD guidance states that audits with a complexity rating of 3 could have questioned costs between
$10,001 and $100,000. Consequently, because questioned costs must be less than $25,000 for staff to
use abbreviated resolution procedures, the use of these procedures may not always be appropriate for
such audits and should be evaluated on a case-by-case basis.
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Timeliness of Audit Resolution
The Department’s ability to timely resolve independent audits covering its grant
programs is a crucial factor in ensuring effective oversight of these programs. It is
particularly important for programs that the Department has designated as higher-risk
pursuant to OMB’s “Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards” (2 Code of Federal Regulations (C.F.R.) Part 200), as it
did for the Education Stabilization Fund, including HEERF, and that provide for
substantial emergency funding over a short period of time. In such cases, there is
greater urgency to identify and correct any instances of noncompliance.
A GRMSD official said that they have prioritized the timely resolution of HEERF single
audits for the past year because the Department’s audit tracking system applies a
6-month timeliness standard, as required by Federal rules. 14 For HEERF proprietary
school audits, GRMSD has not applied the same 6-month timeliness standard because
the intake and resolution processes are completely separate from its HEERF single audit
resolution processes. 15 Instead, the Director of GRMSD stated that the statute of
limitations 16 for the recovery of questioned costs has been viewed as the timeliness
threshold for proprietary school audits and he did not expect that it would expire for
any HEERF audits.
Based on our observations during this limited review, GRMSD may be at risk of not
being able to support the timely resolution of HEERF audit findings. GRMSD should
further assess its audit resolution capacity and processes, and Department management
should use the updated audit resolution status information to ensure that GRMSD has
the resources necessary to appropriately prioritize the timely and effective resolution of
HEERF audit findings. While we did not assess the effectiveness of GRMSD’s standard or
14
For HEERF single audits, 2 C.F.R. section 200.513(c)(3) states that the Federal awarding agency must
issue a management decision as prescribed in 2 C.F.R. section 200.521, and follow up on audit findings
to ensure that the recipient takes appropriate and timely corrective action.
15
For HEERF proprietary school audits, section 8(b)(2) of OMB Circular A-50 requires prompt resolution
and corrective actions on audit recommendations. It states that in the case of audits performed by non-
Federal auditors, resolution should be made within 6 months after receipt of the report by the Federal
government.
16
34 C.F.R. section 81.31(c) establishes a statute of limitations for programs administered by the
Department. The Department cannot seek recovery of funds that were spent more than 5 years before
an auditee receives a program determination letter.
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abbreviated audit resolution processes during this review, it is possible that a continuing
backlog of outstanding audits and the closeout of HEERF grants could create an
incentive for GRMSD to further abbreviate its audit resolution procedures. These factors
could potentially reduce the effectiveness of the HEERF audit resolution process and the
value of associated oversight activities.
What We Recommend
We recommend that the Assistant Secretary, Office of Finance and Operations—
1.1 Assess GRMSD’s future workload based on the anticipated volume and
complexity of independent audits with potential HEERF findings that are likely to
be submitted through the end of the grant closeout period, coordinating with
other Department offices as necessary for assistance and to obtain relevant
data to inform this assessment.
1.2 Evaluate whether the staffing level assigned to HEERF audit resolution activities
is sufficient to support the timely and effective resolution of all outstanding and
anticipated HEERF single and proprietary school audit findings, and if not,
develop and implement a plan of action to address the issue.
Department Comments
We provided a draft of this flash report to the Department for review and comment. We
summarize the Department’s comments here and provide the full text of its comments
at the end of the report.
In its response, the Department stated that it concurred with our two recommendations
and had begun taking steps to address the finding. The Department described the
challenging circumstances that it faced during the implementation and ongoing
administration of the HEERF program due to the unprecedented funding amounts,
number of recipients, and compressed timeframes. The Department also described the
corrective actions that it has planned and recently initiated in support of the timely and
effective resolution of HEERF audit findings, including assessing the remaining HEERF
audit resolution workload through the end of the grant closeout period, requesting
additional overtime funds to help eliminate the backlog of unresolved audits, and
prioritizing the assignment and resolution of audit findings with questioned costs.
OIG Response
We acknowledge the challenging circumstances that the Department faced in
administering the HEERF program and audit resolution process and appreciate its
prompt response to address our recommendations. We reviewed the Department’s
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proposed corrective actions and believe that they would be responsive to our
recommendations if implemented as described.
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Appendix A. Scope and Methodology
Our review covered all audits requiring resolution by GRMSD from October 1, 2018,
through June 30, 2023; however, we focused on independent audits of HEERF recipients
from April 2020 through June 2023. We conducted our review remotely from June 2023
through August 2023. We held an exit conference and discussed the results of our
review with Department officials on August 28, 2023.
Use of Computer-Processed Data
While we believe that GRMSD’s audit resolution data are acceptable for the limited
purpose of presenting our general observations in this report, we were not able to
obtain reasonable assurance of the reliability of data for other purposes. As a result, the
audit resolution status figures presented in this report should only be used for the
purposes stated in this report. In consideration of known data quality conditions and
limitations as discussed above, our use of computer-processed data to support
observations presented in this report was limited to information about HEERF audits
and the status of audit resolution activities.
Compliance with Standards
We prepared this flash report in alignment with OIG’s quality control standards and the
Council of Inspectors General for 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 the conclusions and recommendations contained in this
report.
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Office of Inspector General
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Appendix B. Acronyms and Abbreviations
C.F.R. Code of Federal Regulations
CIGIE Council of the Inspectors General on Integrity and Efficiency
Department U.S. Department of Education
FAC U.S. Census Bureau Federal Audit Clearinghouse
FSA Federal Student Aid
FTE full-time equivalent
FY fiscal year
GRMSD Grants Risk Management Services Division
HEERF Higher Education Emergency Relief Fund
OFO Office of Finance and Operations
OMB Office of Management and Budget
OPE Office of Postsecondary Education
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Department Comments
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U.S. Department of Education
Office of Inspector General
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