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Lincoln College of Technology's Use of Higher Education Emergency Relief Fund Student Aid and Institutional Grants (ED-OIG/A20CA0016)

Summary

A final audit report of the U.S. Department of Education Office of Inspector General, ED-OIG/A20CA0016, dated September 24, 2021, on Lincoln College of Technology's use of Higher Education Emergency Relief Fund Student Aid and Institutional Grants. The report states that the Lincoln Educational Services Corporation (LESC) generally used the Student Aid portion for allowable and intended purposes but did not always do so for the Institutional portion. It states that LESC improperly applied $700,155 of Institutional grant funds to credit 461 students' accounts for rent and improperly used $9,838 for software subscriptions beyond the grant performance period. OIG recommends that the Assistant Secretary for the Office of Postsecondary Education require policy updates and review the reallocated expenditures. The report summarizes LESC's comments and OIG's response.

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
2021-09-24

Cite this document

“Lincoln College of Technology's Use of Higher Education Emergency Relief Fund Student Aid and Institutional Grants (ED-OIG/A20CA0016).” U.S. Department of Education, Office of Inspector General, dated 2021-09-24. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/lincoln-college-technology-heerf/, SHA-256 db72a05c49afc031ec79d542302f91db8698070efdd4969976a5e80945e1b900.

Full text

                 U.S. Department of Education
                 Office of Inspector General




Lincoln College of Technology’s
Use of Higher Education
Emergency Relief Fund Student
Aid and Institutional Grants
September 24, 2021
ED-OIG/A20CA0016

ED OIG Oversight of Coronavirus Response Funds
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




September 24, 2021


Scott Shaw, CEO/President
Lincoln Educational Services Corporation
d/b/a Lincoln College of Technology
14 Sylvan Way, Suite A
Parsippany, NJ 07054


Dear President Shaw:

Enclosed is our final audit report, “Lincoln College of Technology’s Use of Higher Education Emergency
Relief Fund Student Aid and Institutional Grants,“ Control Number ED-OIG/A20CA0016. This report
incorporates the comments you provided in response to the draft report. If you have any additional
comments or information that you believe may have a bearing on the resolution of this audit, you
should send them directly to the following Department of Education official, who will consider them
before taking final Departmental action on this audit:

        Dr. Michelle Asha Cooper
        Acting Assistant Secretary
        Office of Postsecondary Education
        400 Maryland Avenue, S.W.
        Washington, DC 20202

The U.S. Department of Education’s policy is to expedite audit resolution by timely acting on findings
and recommendations. Therefore, if you have additional comments, we would appreciate receiving
them within 30 days.

Sincerely,

/s/

Daniel P. Schultz
Director of Pandemic Relief Audits


Enclosure




                               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
Results in Brief .................................................................................................................... 1
Introduction ........................................................................................................................ 5
Finding 1. LESC Generally Used Student Aid Grant Funds for Allowable and Intended
Purposes ............................................................................................................................. 9
Finding 2. LESC Did Not Always Use Institutional Grant Funds for Allowable and Intended
Purposes ........................................................................................................................... 14
Finding 3. LESC Did Not Follow Federal Cash Management Requirements ..................... 22
Other Matter. Student Aid and Institutional Reporting ................................................... 29
Other Matter. Incorrect Data Universal Number System Number................................... 31
Appendix A. Scope and Methodology............................................................................... 33
Appendix B. LESC Corporate Structure, Schools, and Campuses...................................... 41
Appendix C. Acronyms and Abbreviations........................................................................ 42
LESC Comments ................................................................................................................ 43
                 Results in Brief
                What We Did
                The objective of our audit was to determine whether Lincoln College of Technology
                (Lincoln) used the Student Aid (Assistance Listing Number (ALN) 84.425E) and
                Institutional (ALN 84.425F) portions of its Higher Education Emergency Relief Fund
                (HEERF) funds for allowable and intended purposes. We also reviewed Lincoln’s cash
                management practices and the timeliness and quality of the data Lincoln reported on its
                use of HEERF funds. 1 Our audit covered Lincoln’s HEERF expenditures, cash flows, and
                reporting from the grant award date 2 through December 31, 2020.

                To achieve our audit objective, we interviewed Lincoln Educational Services Corporation
                (LESC) 3 officials who were responsible for drawing down, managing, awarding, spending,
                and reporting on Lincoln’s HEERF grant funds. We also reviewed LESC’s policies and
                procedures and other supporting documentation (for example, bank records, invoices,
                student records) for managing, authorizing, and accounting for HEERF-related
                transactions and expenditures. Additionally, we reviewed a sample of Student Aid grant
                distributions and Institutional grant expenditures to determine whether LESC used the
                Student Aid and Institutional portions of Lincoln’s HEERF funds for allowable and
                intended purposes. We also compared the timing and amounts of drawdowns of HEERF
                funds with LESC’s accounting records (expenditure information) to determine whether
                LESC minimized the time between draw down and disbursement of the funds. Lastly, we
                reviewed HEERF reports that LESC posted on its website covering expenditures from the
                grant date through December 31, 2020, and the school’s accounting records to
                determine whether the school reported timely and quality information.

                What We Found
                LESC generally used the Student Aid portion of Lincoln’s HEERF funds for allowable and
                intended purposes but did not always use the Institutional portion of its funds in



1
 In this document, “HEERF” generally refers to both the Student Aid and Institutional grant funds. We
use “Student Aid” and “Institutional” when the information is specific to the respective grant.
2
  The award date for Lincoln’s Student Aid grant was April 28, 2020, and the award date for its
Institutional grant was May 14, 2020.
3
 At the time of our audit, LESC owned four schools that received HEERF grants, as shown in Appendix B.
LESC centrally administered all four schools’ HEERF grants. Our audit covered only one of LESC’s
schools—Lincoln.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                         1
              accordance with Federal requirements. We found that LESC did not adequately
              document eligibility determinations for a small number of students who received
              emergency financial aid grants, improperly applied Institutional grant funds to credit
              student accounts, improperly charged expenditures that extended beyond the grant
              performance period, and did not follow cash management requirements. Specifically,
              LESC

                  •   did not have policies and procedures with sufficient detail regarding students
                      who did not have an Institutional Student Information Record on file, to ensure
                      that (1) all the steps necessary to verify student eligibility were completed, and
                      (2) eligibility determinations were adequately supported for 202 students who
                      received an emergency financial aid grant, contrary to Federal regulations;

                  •   improperly applied $700,155 of Institutional grant funds to credit 461 students’
                      accounts for rent the students paid to third-party landlords for the months the
                      school was closed due to coronavirus, contrary to U.S. Department of Education
                      (Department) guidance;

                  •   improperly used $9,838 of Institutional grant funds to purchase software
                      subscriptions that extended beyond Lincoln’s 1-year grant performance period,
                      contrary to Federal regulations; and

                  •   did not minimize the time between drawing down and disbursing HEERF funds
                      nor deposit excess HEERF funds in an interest-bearing account, contrary to
                      Federal regulations.
              We also determined that the information in Lincoln’s required HEERF reports posted on
              LESC’s website was generally accurate, complete, and timely. Following the presentation
              of our findings to LESC, LESC officials reallocated the amounts we questioned to other
              expenditures they believed were eligible to be charged to Lincoln’s Institutional grant. If
              these other expenditures are allowable, this would be an acceptable remedy to our
              finding, but we did not review these expenditures.

              What We Recommend
              We recommend that the Assistant Secretary for the Office of Postsecondary
              Education—

                  •   Require LESC to update its policies and procedures to contain sufficient detail
                      to ensure that (1) all the steps necessary to verify student eligibility and
                      distribute emergency financial aid grants to students are completed, and
                      (2) funding determinations are adequately documented and supported.

                  •   Review the allowability of the reallocated Institutional expenditures, and if not
                      allowable, require LESC to return to the Department the $700,155 of

U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                           2
                      Institutional grant funds improperly applied to credit 461 students’ accounts for
                      rent students paid to third-party landlords and the $9,838 improperly spent for
                      subscriptions that extended beyond the grant performance period.

                  •   Require LESC to incorporate Federal cash management requirements in its
                      policies and procedures and determine whether LESC accurately calculated
                      interest and properly remitted the interest.

              LESC Comments
              We provided a draft of this report to LESC for comment.

              LESC agreed with Finding 1 but disagreed with the recommendation, stating its belief
              that such actions are not necessary. LESC stated that when Lincoln is prepared to
              distribute Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA)
              and American Rescue Plan (ARP) funds, it will prioritize students with exceptional need
              based on the student’s Expected Family Contribution or, for an anticipated small
              number of students, a survey instrument designed to identify students with exceptional
              need.

              LESC disagreed with Finding 2 and did not state whether it agreed or disagreed with the
              recommendations. LESC stated that Lincoln nevertheless repurposed the funds in
              question for purposes it believes are allowable. LESC disagreed with the sub-finding
              regarding credits to student accounts for rent that students paid to third-party
              landlords, stating its belief that the Office of Inspector General (OIG) interpreted the
              Department’s guidance too narrowly when reporting that the account credit is not
              equivalent to a cash payment. LESC further stated that Lincoln agreed with the sub-
              finding regarding subscriptions that extended beyond the grant performance period.
              LESC agreed that Lincoln purchased four annual software subscriptions, a portion of
              which extended beyond the end of the grant performance period. LESC stated that even
              though it contends that using Institutional grant funds to reimburse itself for the
              student account credits was permissible, Lincoln reallocated the costs we questioned to
              write off student account balances, which it believes is permissible in accordance with
              the Department’s guidance on lost revenue. LESC also stated that, in addition to
              Lincoln’s action, its other schools have completed a similar reallocation of Institutional
              grant funds.

              LESC agreed with Finding 3 and did not explicitly state whether it agreed or disagreed
              with the recommendations. LESC stated that Lincoln did not have prior experience with
              Federal cash management requirements and did not initially establish all the
              appropriate procedures. LESC said that, after the Department highlighted the cash
              management requirements in guidance published in October 2020, Lincoln deposited its
              HEERF funds in an interest-bearing account, returned the HEERF funds not needed


U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                       3
              immediately to its account in the Department’s G5 system, and calculated and remitted
              interest to the Department. In response to the recommendations, LESC stated that
              Lincoln has revised its cash management policy in accordance with Federal cash
              management regulations and believes its interest calculation was consistent with
              prevailing interest rates during the April through December 2020 timeframe.

              OIG Response
              Regarding Finding 1, we disagree with LESC’s statement that the corrective action
              outlined in Recommendation 1.1 is unnecessary and note that LESC did not state why it
              believes that the recommendation to update its written policies is unnecessary. LESC
              described how Lincoln intends to prioritize students with exceptional need when
              distributing CRRSAA and ARP funds. However, LESC did not address incorporating the
              steps necessary to accomplish this and document funding determinations in written
              policies and procedures.

              Regarding Finding 2, we disagree with LESC’s statement that Lincoln’s use of
              Institutional grant funds to reimburse itself for crediting student accounts for rent
              students paid to third-party landlords was consistent with the Department’s guidance.
              As noted in our finding, crediting student accounts reduced student debt without
              students’ permission. Moreover, the rent credits were not the equivalent of a cash
              payment because students could not readily convert the credits to cash and did not
              have discretion to use the funds for other eligible expenses. The finding acknowledges
              that LESC reallocated the amounts we questioned to other expenditures it believed
              were eligible to be charged to the grant.

              Regarding Finding 3, we acknowledge the corrective actions that LESC took after the
              Department published guidance highlighting the cash management requirements in
              October 2020. LESC’s actions to incorporate the cash management requirements in its
              policies and procedures were responsive to Recommendation 3.1.

              We did not make any changes to the findings or recommendations based on LESC’s
              comments, except for the addition of Expected Family Contribution in the definition of
              an Institutional Student Information Record in Finding 1. We summarize LESC’s
              comments at the end of each finding and provide the full text of the comments, except
              the attachments, at the end of the report. (see LESC Comments) The attachments
              provided with the written comments could be made available upon request unless
              subject to withholding under a Freedom of Information Act exemption.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                       4
                Introduction
                The Coronavirus Aid, Relief, and Economic Security Act (CARES Act), enacted March 27,
                2020, authorized more than $2 trillion to battle the coronavirus pandemic and its
                economic effects. The CARES Act provided $31 billion for an Education Stabilization
                Fund to prevent, prepare for, and respond to the coronavirus, domestically or
                internationally, including $17 billion for State and local agencies and $14 billion for the
                Higher Education Emergency Relief Fund (HEERF).

                CARES Act Higher Education Emergency Relief Fund
                In Section 18004 of the CARES Act, Congress set aside $14 billion in HEERF funds to
                mitigate the impact of the coronavirus on students and institutions of higher education.
                Section 18004(a)(1) provided about $12.6 billion (90 percent) for direct grants to schools
                to prevent, prepare for, and respond to the coronavirus. Of the remaining HEERF funds,
                7.5 percent ($1 billion) was for formula grants to schools to address needs directly
                related to coronavirus and another 2.5 percent ($349 million) was for schools that the
                U.S. Department of Education (Department) determined had the greatest unmet needs
                related to the coronavirus.

                For direct grants, the Act required schools to distribute at least 50 percent of their
                HEERF funds to students as emergency financial aid grants to help cover expenses
                related to the disruption of campus operations due to the coronavirus. Schools could
                use the remaining funds for additional emergency financial aid grants, or to cover any
                costs associated with significant changes to the delivery of instruction due to the
                coronavirus. The Department’s Office of Postsecondary Education (OPE) is responsible
                for administering and overseeing these grants, which were awarded to more than
                4,500 schools.

                In April 2020, the Department allocated the $12.6 billion to schools as two separate
                grants—50 percent of each school’s total authorization for emergency financial aid
                grants to students under Assistance Listing Number (ALN) 84.425E (Student Aid portion),
                and 50 percent for institutional costs under ALN 84.425F (Institutional portion). 4 In
                addition to submitting an application, the Department required schools to sign separate
                Certification and Agreement forms in order to access their Student Aid and Institutional
                grant funds. Schools had 1 calendar year from the award date of each HEERF grant
                (Student Aid and Institutional) to spend the funds unless the school received a no-cost
                extension. The Department also required schools to report publicly on their use of


4
 Schools had to use the Student Aid portion only for emergency financial aid to students and could also
use some or all of the Institutional portion for emergency financial aid to students.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                              5
                HEERF funds by posting the required information on the school’s primary website on a
                quarterly basis. The Student Aid and Institutional portions of HEERF funds are subject to
                Uniform Administrative Requirements, Cost Principles, and Audit Requirements for
                Federal Awards (Uniform Guidance) in 2 Code of Federal Regulations (C.F.R.) part 200.
                The Uniform Guidance also addresses cash management requirements.

                Additional Coronavirus Relief Legislation
                After the CARES Act, Congress passed two additional coronavirus relief laws that
                provided additional HEERF funding. The Coronavirus Response and Relief Supplemental
                Appropriations Act (CRRSAA) was signed into law on December 27, 2020, authorizing an
                additional $22.7 billion for schools under the HEERF programs. CRRSAA provided
                additional flexibilities in how HEERF funds could be used, including for lost revenue,
                reimbursement for expenses already incurred, technology costs associated with a
                transition to distance education, faculty and staff trainings, and payroll. Additionally,
                section 314(d)(2) of the CRRSAA extended the allowable use provisions listed above to a
                school’s unspent CARES Act funds.

                On March 11, 2021, the American Rescue Plan (ARP) was signed into law, adding
                $39.6 billion in additional HEERF funding. ARP and subsequent Department regulations
                changed the eligibility criteria to allow institutions to provide emergency aid to any
                individual who is enrolled at an eligible institution on or after March 13, 2020, the date
                of the national emergency.

                Lincoln College of Technology
                The Department had allocated Lincoln College of Technology (Lincoln) a total of
                $24.9 million in coronavirus relief funds by the conclusion of our fieldwork in May 2021.
                In April and May of 2020, the Department awarded Lincoln $13.3 million in CARES Act
                HEERF funds—almost $6.7 million (50 percent) for the Student Aid portion
                (ALN 84.425E) and almost $6.7 million (50 percent) for the Institutional portion
                (ALN 84.425F). The Department awarded Lincoln $7.3 million in student aid grant funds
                (ALN 84.425Q) under CRRSAA in March 2021, and $4.3 million in supplemental grant
                funds (ALN 84.425Q) under ARP in August 2021. 5

                Lincoln is a for-profit school that offers training in the areas of automotive technology
                and skilled trades, such as welding, electrical technology, and heating, ventilation, and



5
  CRRSAA and ARP authorized new HEERF funding for proprietary schools to be used only for emergency
financial aid grants to students. The Department allocated these funds under its Proprietary Institutions
Grant Funds for Students program (ALN 84.425Q). Our audit covered only the CARES Act HEERF funds.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                             6
              air conditioning (HVAC). These diploma and certificate programs typically take between
              19 to 136 weeks to complete. Each month, new students enroll in and existing students
              graduate from these programs.

              The school consists of eight campuses located in six States, including its main campus in
              Indianapolis, Indiana. According to Lincoln Educational Services Corporation (LESC)
              officials, most students are working adults (25–26 years old), about 20 percent of the
              students are recent high school graduates, and almost 70 percent of students are
              eligible to participate in Title IV of the Higher Education Act of 1965 (Title IV) Federal
              student aid programs. All of the campuses are nationally or regionally accredited. Only
              the Nashville campus has a dormitory to house students.

              In April 2020, LESC owned and operated a total of 4 schools with 22 campuses located in
              14 States (including Lincoln, the subject of this audit). The Department awarded HEERF
              grants (Student Aid and Institutional portions) to each school. LESC centrally
              administered the HEERF grants for all of its schools. In Appendix B, we depict the
              organizational structure of LESC’s schools and campus locations, and each school’s
              CARES Act HEERF grants.

              Impact of Coronavirus
              Prior to March 13, 2020, the date of the national emergency, Lincoln’s campuses
              generally provided only in-person instruction except for a few blended programs (both
              in-person and remote instruction). In March 2020, Lincoln closed all its campuses
              (including the Nashville dormitory) and transitioned classes from in-person, hands-on
              instruction to 100-percent online, remote instruction. According to LESC officials, the
              school was able to quickly pivot to distance learning because many students already had
              computers provided as part of their educational program. LESC acquired computers for
              some instructors and for students enrolled in some welding and HVAC programs which
              previously did not require computers. LESC also obtained e-books for students and
              purchased software to enhance its online learning platform.

              Depending on their location, school campuses began to reopen between May and July
              2020 for in-person instruction. As of August 2020, all campuses had reopened with
              social distancing protocols in place, including limiting the number of students on campus
              at one time and continuing to use some distance learning (blended instruction). Instead
              of hiring additional staff, Lincoln incurred significant amounts of overtime for existing
              employees and instructors to accommodate social distancing measures such as smaller
              class sizes and extended instruction and business office hours. To adhere to social
              distancing protocols when Lincoln’s Nashville campus and dormitory reopened, LESC
              contracted with several hotels to house some students who would normally reside in
              the dormitory.



U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                       7
              The number of students either enrolled or on leave of absence also illustrates the
              impact of the coronavirus, as shown in Figure 1. Lincoln’s enrollment before the national
              emergency averaged 5,100 students. Enrollment declined to about 4,900 students after
              the national emergency was declared in March 2020, then trended upward to an
              average of about 5,500 students from March 2020 to January 2021. During that same
              period, an average of 15 students were on leave of absence before the national
              emergency. That number increased to a high of about 300 students on leave of absence
              in June 2020 and decreased to zero students in January 2021. LESC officials stated that
              they kept their schools operating by providing students remote access to online classes,
              financial aid, and other services, and by putting resources in place to help students
              continue their education and to learn new skills during the coronavirus pandemic. They
              attributed Lincoln’s enrollment increase to these measures.

              Figure 1. Lincoln College of Technology Student Enrollment and Leave of Absence,
              January 2019 through January 2021

                              7,000                                 National Emergency Declared,                   350
                                                                          March 13, 2020

                              6,000                                                                                300

                              5,000                                                                                250




                                                                                                                           Leave of Absence
                 Enrollment
                              4,000                                                                                200

                              3,000                                                                                150

                              2,000                                                                                100

                              1,000                                                                                50

                                 0                                                                                 0




                                      Number of Students Enrolled             Number of Students on Leave of Absence


              SOURCE: Office of Inspector General (OIG) Analysis of Lincoln’s Enrollment and Leave of Absence
              Data




U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                                       8
                Finding 1. LESC Generally Used Student Aid
                  Grant Funds for Allowable and Intended
                  Purposes
                LESC generally used Lincoln’s Student Aid grant funds to award emergency financial aid
                grants to students in accordance with applicable Federal requirements. As of
                December 31, 2020, LESC had awarded emergency financial aid grants to 8,435 students
                totaling $6.3 million of the $6.7 million in Student Aid grant funds awarded to Lincoln
                under the CARES Act. However, as discussed later in this finding, we found that LESC did
                not adequately document eligibility determinations for a small number of students,
                contrary to Federal regulations. In addition, as discussed in Finding 3, LESC did not
                manage Lincoln’s Student Aid grant funds in accordance with Federal cash management
                requirements.

                How LESC Awarded and Distributed Student Aid Grant Funds
                Congress intended for Student Aid grant funds to provide students emergency financial
                relief for expenses related to the disruption of campus operations, including students’
                cost of attendance, such as food, housing, course materials, technology, health care,
                and childcare. The Department directed schools to award emergency financial aid grants
                only to students who were or could be eligible to participate in Title IV programs
                (Title IV-eligible). 6 Schools had discretion in determining the amount of individual
                emergency financial aid grants and how to distribute the funds to students.

                LESC’s policy was to distribute emergency financial aid grants before May 1, 2020, to
                existing students who were or could be Title IV-eligible, and to consider students’
                financial needs when determining the amount individual students would receive. The
                Institutional Student Information Record (ISIR) contains information the student
                reported on the Free Application for Federal Student Aid (FAFSA) form, which includes
                information for determining a student’s Title IV eligibility and Expected Family
                Contribution (EFC). For students who did not have an ISIR on file, LESC had a policy to
                determine if they could be Title IV-eligible, which we address later in this finding. For
                students who had an ISIR on file, LESC’s policy was to determine the amount a student
                would receive based on factors that included the student’s EFC; whether the student
                resided in a school dormitory or third-party housing; and whether the student had
                graduated between March 13 and April 30, 2020. For students who were active as of
                May 1, 2020, and had an ISIR on file, the amount of emergency financial aid grants these


6
 As described later in this finding, Department regulations published in May 2021 changed the eligibility
criteria so that students no longer had to be Title IV-eligible to receive an emergency financial aid grant.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                           9
              students received ranged from $500 to $1,500, and was $500 for all other students. For
              new students who began school after May 1, 2020, with an ISIR, LESC’s policy was to
              award emergency financial aid grants in the amount of $500.

              To distribute emergency financial aid grant funds as quickly as possible, LESC contracted
              with a third-party servicer to mail students their funds via a debit card and a check.
              Using the debit card would automatically cancel the check and depositing or cashing the
              check would reduce the value on the debit card to zero. Students could use the debit
              card at more than 70,000 in-network locations without incurring a surcharge. LESC
              officials stated that they monitored whether students had activated the debit card or
              cashed the check, attempted to contact students who had not, and deactivated debit
              cards that were not activated within 90 days. They also said that funds from the
              deactivated cards were reissued as emergency financial aid grants to other eligible
              students.

              LESC did not require students to complete an application. Instead, LESC compiled data
              from its student management system to determine student eligibility and grant award
              amounts. LESC informed students by email and letter that they had been awarded an
              emergency financial aid grant, provided instructions on how to access their grant funds,
              and provided a list of frequently asked questions (FAQ) to help answer questions
              students might have about the grant. LESC’s FAQs explained that emergency financial
              aid grants under the CARES Act were for expenses related to the disruption of campus
              operations due to coronavirus (such as food, housing, course materials, technology,
              health care, and childcare); and included a hyperlink to the Department’s website for
              additional information about the Act. According to LESC officials, students also received
              a survey on their actual and planned uses of grant funds, and based on “hundreds” of
              survey responses, students predominately used the funds for housing, food, childcare,
              and transportation.

              LESC Did Not Adequately Document Eligibility Determinations
              for a Small Number of Students
              Of the 8,435 students who received an emergency financial aid grant, LESC did not have
              documentation to support its eligibility determinations for 202 students. The
              202 students did not have an ISIR (non-ISIR students) on file in May 2020 and LESC’s
              policy was to determine if the students could be Title IV-eligible and thus eligible to
              receive emergency financial aid grants. However, we found that LESC’s written policies
              and procedures did not provide sufficient detail to ensure that (1) all the steps
              necessary to verify student eligibility were completed, and (2) eligibility determinations
              were adequately supported. When we asked for clarification during our testing, LESC
              decided to re-evaluate the 202 students because supporting documentation was not
              available.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                      10
                To help ensure the Department’s grant funds are used for intended purposes and
                intended program goals are achieved, Federal regulations require recipients to maintain
                adequate records of source documentation of all amounts charged to Federal awards.
                Financial management systems for non-Federal entities, such as Lincoln, must include
                documentation of compliance with Federal statutes and regulations, must be sufficient
                to satisfy reporting requirements, and must be able to show that funds were used
                according to terms and conditions of the award (2 C.F.R. § 200.302(a)). Records must
                also adequately identify the source of funds for federally funded activities and contain
                source documents supporting the usage of the award (2 C.F.R. § 200.302(b)(3)).

                For the 202 non-ISIR students, LESC officials could not determine how student eligibility
                was reviewed because the student management system did not contain all of the data
                needed to support that the students could be Title IV-eligible. They also could not
                provide documentation of the review. They said that the senior executive, who oversaw
                the review of these students’ eligibility, passed away in July 2020. Thus, LESC’s lack of
                documentation supporting its eligibility determinations for these 202 students did not
                comply with Federal requirements.

                When LESC officials re-evaluated the non-ISIR students, they found that 24 of the
                202 students were not Title IV-eligible. 7 The officials were not able to clearly describe
                the cause for their error in initially determining the 24 students to be Title IV-eligible.
                They explained that communication issues among LESC officials and staff, coupled with
                the focus on quickly providing grants to students, were factors for the error.
                Nevertheless, the reason for the error might have been more evident or detected earlier
                had LESC maintained documentation of its eligibility determinations.

                After LESC distributed emergency financial aid grants to the 202 students in May 2020,
                the Department issued additional guidance addressing student eligibility. In June 2020,
                the Department published an Interim Final Rule (IFR) 8 clarifying that students had to be
                Title IV-eligible to receive an emergency financial aid grant under the CARES Act. In its
                October 2020 FAQ Rollup Document, the Department further clarified that the IFR was
                not intended to have a retroactive effect and that the Department would “not initiate
                any enforcement action based solely upon its early guidance as to student eligibility for



7
  We sampled 9 of the 202 students who received an emergency financial aid grant and did not have an
ISIR on file, as shown in Table 7 (Group 2) in Appendix A. We also confirmed that 2 of the 9 students
were among the 24 students who LESC subsequently determined were not Title IV-eligible.
8
 Eligibility of Students at Institutions of Higher Education for Funds Under the Coronavirus Aid, Relief,
and Economic Security (CARES) Act, IFR (85 FR 36494), June 17, 2020.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                            11
               HEERF emergency student financial aid grants that were disbursed to students prior to
               the effective date of the IFR (June 17, 2020).” On May 14, 2021 (after our audit period),
               the Secretary of Education amended Department regulations to allow institutions of
               higher education to award emergency financial aid grants to students who were
               currently or previously enrolled at an eligible institution as of March 13, 2020, the date
               the national emergency was declared, regardless of whether they are Title IV-eligible. 9
               Despite the subsequent clarifications in Department guidance and regulations, we
               concluded that LESC did not maintain adequate documentation to support emergency
               financial aid grants awarded to non-ISIR students and charged to Lincoln’s Student Aid
               grant.

               With the additional funding provided by the Department’s Proprietary Institutions Grant
               Funds for Students program (ALN 84.425Q) under CRRSAA and ARP, it is important that
               LESC have a sufficiently detailed plan for distributing the funds to students and
               maintains documentation to support all student grant awards. The CRRSAA and ARP
               directed schools to prioritize grants to students with exceptional need when distributing
               emergency financial aid grants. Furthermore, the Department’s ARP guidance states
               that institutions “should carefully document how they prioritize students with
               exceptional need in distributing emergency financial aid grants to students, as the
               Department is exploring reporting requirements regarding the distribution of
               emergency financial aid grants to students (see 2 C.F.R. § 200.334).” 10

               Recommendation
               We recommend that the Assistant Secretary for the Office of Postsecondary Education
               require LESC to—

               1.1 Update its written policies and procedures to contain sufficient detail to ensure
                   that (1) all the steps necessary to verify student eligibility and distribute funds to
                   students under the CARES Act and subsequent coronavirus legislations are
                   addressed and completed, (2) funding determinations are adequately documented
                   and supported in accordance with 2 C.F.R. § 200.302, and (3) students with
                   exceptional need are prioritized in accordance with CRRSAA and ARP.




9
 The May 2021 regulation applies to emergency financial aid grants to students under the HEERF
programs as originally enacted under the CARES Act and continued through the CRRSAA and ARP.
10
  Higher Education Emergency Relief Fund III Frequently Asked Questions, American Rescue Plan Act of
2021, published May 11, 2021 (Questions 7 and 11 updated May 24, 2021). Question 11 addressed the
requirements for making emergency financial aid grants to students.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                       12
              LESC Comments
              LESC agreed with the finding but disagreed with the recommendation, stating its belief
              that the actions contained in the recommendation are not necessary. LESC stated that
              when Lincoln is prepared to distribute CRRSAA and ARP funds, it will prioritize students
              with exceptional need by distributing larger emergency student financial aid grants to
              students with relatively lower amounts of EFC. For the relatively small number of
              students who Lincoln anticipates will not have EFC information, it will use a survey
              instrument designed to identify students with exceptional need.

              OIG Response
              We disagree with LESC’s statement that the corrective action outlined in the
              recommendation is unnecessary and note that LESC did not state why it believes that
              the recommendation to update its written policies is unnecessary. As noted in the
              finding, Federal regulations require recipients, such as Lincoln, to maintain adequate
              supporting documentation to ensure grant funds are used in accordance with the terms
              and conditions of the award. LESC described how Lincoln intends to prioritize students
              with exceptional need when distributing CRRSAA and ARP funds. However, its
              comments do not address incorporating in written policies and procedures the steps
              necessary to prioritize students with exceptional need and ensure funding
              determinations for each student are adequately documented and supported, as
              required by 2 C.F.R. § 200.302.

              We did not make any changes to the finding and recommendation based on LESC’s
              comments, except to add EFC in the description of the ISIR.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                    13
              Finding 2. LESC Did Not Always Use Institutional
                Grant Funds for Allowable and Intended
                Purposes
              As of December 31, 2020, LESC had spent $3.4 million (51 percent) of the $6.7 million in
              Institutional grant funds awarded to Lincoln. We determined that LESC spent
              $2.7 million (79 percent) for allowable purposes but spent about $710,000 (21 percent)
              of the $3.4 million for unallowable purposes. Specifically, as discussed later in this
              finding, LESC applied $700,155 to credit student accounts for the amount of rent
              students paid to third-party landlords and used $9,838 for subscriptions that extended
              beyond the grant performance period. In addition, as discussed in Finding 3, LESC did
              not manage Lincoln’s Institutional grant funds in accordance with Federal cash
              management requirements.

              After we concluded our audit fieldwork, LESC officials informed us that they decided to
              reallocate the amounts we questioned to what they believe were other eligible
              expenditures, as described near the end of this finding.

              How LESC Used Institutional Grant Funds
              Under the CARES Act, Congress intended for schools to use Institutional grant funds to
              cover any costs associated with significant changes to the delivery of instruction due to
              coronavirus. In deciding how to use Lincoln’s Institutional grant funds, LESC officials
              stated that they reviewed expenditures incurred to date (or expected to be incurred
              within the grant period) to keep the school operating when campuses closed for 2 to
              3 months due to coronavirus and then re-opened. To help in their decision-making on
              what costs might be allowable for reimbursement under the grant, they consulted with
              LESC’s Title IV compliance auditor and submitted questions to the Department.

              Of the $3.4 million spent as of December 31, 2020, LESC reported using 74 percent for
              expenditures related to student housing and 26 percent for expenditures related to
              technology and campus safety, as shown in Table 1 on the following page. According to
              LESC officials, the housing-related expenditures were for (1) hotel lodging for students
              who were displaced from their dormitory housing to allow for social distancing when
              the Nashville campus re-opened; (2) refunds of housing or meal fees in the form of a
              credit to student accounts for about 470 students who had to leave their dormitory
              housing when the Nashville campus and cafeteria closed; and (3) as discussed later in
              this finding, reimbursement in the form of a credit to student accounts for rents that
              461 students paid for third-party housing. The remaining expenditures included
              purchases of computers to enable remote instruction for students enrolled in programs
              that did not previously require computers; software subscriptions for distance learning,



U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                     14
                as discussed later in this finding; and campus safety supplies such as personal protection
                equipment.

                Table 1. Lincoln’s Institutional Expenditures through December 31, 2020

                                                                                                      Percent of
                     Category of Expenditure                            Amount
                                                                                                        Total

                  Housing: Hotel Lodging for Social
                                                                        $973,567                          28%
                       Distancing (Nashville)

                  Housing: Dormitory Housing and
                                                                         858,016                          25%
                       Meal Fees (Nashville)

                    Housing: Third-Party Housing                         700,155                          21%


                     Technology (Hardware and
                                                                         889,078                          26%
                    Software) and Campus Safety

                                Total                                  $3,420,816                         100%
                SOURCE: OIG analysis of Lincoln’s quarterly Institutional expenditure reports posted on
                LESC’s website for the periods ending September 30 and December 31, 2020

                LESC Improperly Applied Institutional Grant Funds to Credit
                Student Accounts for Rent Students Paid to Third-Party
                Landlords
                In December 2020, LESC improperly applied $700,155 of Lincoln’s Institutional grant
                funds to credit student accounts to reduce student debt owed to LESC or the
                Department for rent (“rent credits”) that 461 students paid to third-party landlords for
                the 2 to 3 months that school campuses were closed due to coronavirus. Pre-dating the
                CARES Act, LESC had contracts with third parties that offered housing services and
                referred students to these third-party entities as the preferred, first-choice housing
                provider (third-party landlord). 11 A student in need of housing could choose to rent from
                this third-party landlord or any other landlord and was legally obligated to the landlord
                for rent payments. A student could also choose to authorize the school to pay the




11
  LESC had contracts with third-party entities that offered housing services at four of Lincoln’s
campuses. In addition to the distinction of being the “preferred housing provider,” the service providers
assisted students in finding roommates, housing, and other related services. The contract specified that
the legal obligation for students’ rent remained with the student regardless of the source of payment.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                                 15
                student’s rent from either available funds in the student’s account or financing provided
                by LESC. 12

                Because the 461 students paid rent directly to a third-party landlord, Department
                guidance specified that LESC should have made direct cash payments or equivalent to
                reimburse the students for their rent payments. LESC officials stated that their decision
                to issue “rent credits” in December 2020 was based on the Department’s guidance,
                which was in response to a question LESC had submitted. Question 34 in the
                Department’s FAQ Rollup Document (October 2020) states:

                        Question: My institution has students that paid housing fees for April
                        and May 2020 for collegiate housing, but who were not there physically
                        due to [the coronavirus pandemic]. Can our institution provide our
                        students an account credit for the rent amount paid and be reimbursed
                        through the HEERF?

                        Answer: If an institution chooses to reimburse students for rent
                        payments they made, in addition to campus housing fees, during a time
                        when the student could not remain in campus housing “due to
                        significant changes to the delivery of instruction due to the
                        coronavirus,” then that is a permissible use of funds from the
                        Institutional Portion of its allocation under section 18004(a)(1) of the
                        CARES Act to reimburse itself for this cost. However, in such a case, if
                        the student paid rent directly to an entity other than the institution,
                        then the institution would need to issue the rent credit to the student in
                        the form of a cash payment, or equivalent. However, if the rent
                        payments were made to the institution, then the institution can
                        reimburse the student for those payments by issuing an account credit
                        for the rent amount paid.

                LESC did not provide student housing facilities nor charge rent to students who resided
                in properties owned by third-party landlords. Students’ rental agreements were



12
  At the time of enrollment, students could enter into an agreement with LESC to finance any unpaid
amounts on student accounts via an institutional loan covering unpaid educational services, including
tuition, fees, books, supplies, and related services. Other unpaid amounts could result if the student
chose to authorize LESC to facilitate making the student’s rent payments to third-party landlords. The
institutional loan was a retail installment contract that typically had a 7-year repayment period, an
interest rate of 9 percent, and provided the students with an option to defer loan repayment while
enrolled in school.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                         16
                between the student and the landlord, and not the school. Under the financing
                arrangement between LESC and the student, LESC issued the student a monthly “rent
                stipend” housing check payable to the student or third-party landlord. This transaction
                either reduced the amount of available funds (including from Federal student aid
                sources) 13 in the student’s account or increased the amount of funds the student
                borrowed from the school by the amount of the payment to the third-party landlord. In
                either case, students were using their own or borrowed funds to pay their rent to third-
                party landlords and did not make rent payments to the school.

                The Department’s guidance addresses the form in which a school would issue a “rent
                credit” depending on whether the student paid rent directly to a third-party entity or to
                the school. Issuing an account credit to reimburse students for rent would be
                permissible if students made rent payments to the school, which was not the case for
                LESC. Instead, students paid rent to a third-party entity, in which case the guidance
                states that the school would need to issue the rent credits to the students in the form of
                cash payments or equivalent. Contrary to this guidance, LESC issued account credits and
                not direct payments to the students. By issuing the credits, LESC used Institutional grant
                funds to pay down the students’ debt owed on Title IV loans or to the school without
                students’ permission. 14

                LESC officials claimed they followed the Department’s guidance. However, we
                determined that they incorrectly concluded that posting the rent credit to the student
                accounts was equivalent to a form of cash payment. The rent credit was not the
                equivalent of a cash payment because students could not readily convert the credits to
                cash. By issuing an account credit instead of cash or an equivalent, students did not
                have discretion to use the funds for other eligible expenses that might have provided
                more timely and effective relief for their own circumstances related to the disruption of
                campus operations due to coronavirus.

                Of the $700,155 in Institutional grant funds that we questioned, we were not able to
                determine the amount that LESC returned to the Department to pay down students’
                Title IV loans and the amount that LESC used to pay down students’ institutional debt.
                Additionally, LESC officials could not readily provide this information.



13
  Federal student aid programs under Title IV of the Higher Education Act could include Pell grants and
Direct Loans.
14
  In February 2021, LESC told students that the credit would offset the rent the students paid to their
third-party landlords and could result in a reduction of their institutional loan or Federal student loan
balance.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                            17
              As we reviewed documentation related to Lincoln, we noted that LESC also applied
              “rent credits” to student accounts for students enrolled in at least one of its other
              schools. We recommend that the Assistant Secretary for the Office of Postsecondary
              Education determine if the “rent credit” issue occurred at LESC’s other schools and take
              corrective action as appropriate.

              LESC Improperly Used Institutional Grant Funds for
              Subscriptions that Extended beyond the Grant Performance
              Period
              LESC improperly used $9,838 of its Institutional grant funds to purchase software
              subscriptions that extended beyond Lincoln’s 1-year grant performance period. The
              performance period for Lincoln’s Institutional grant was from May 14, 2020, through
              May 13, 2021. According to cost principles specified in Uniform Guidance at 2 C.F.R.
              § 200.309, “a non-Federal entity may charge to the Federal award only allowable costs
              incurred during the period of performance ….” Thus, LESC should not have charged costs
              incurred after May 13, 2021, to Lincoln’s Institutional grant.

              During the grant period, LESC purchased annual subscriptions from four vendors for
              various online learning systems, including collaboration and communication software,
              online study tools and testing services, and learning management platform. However, a
              portion ($9,838) of the $43,117 in subscription costs extended beyond the 1-year grant
              period, as shown in Table 2.

              Table 2. Subscriptions Extending beyond Lincoln’s Institutional Grant Performance
              Period, May 14, 2020, through May 13, 2021
                                                                          Total           Amount
            Vendor          Subscription         Subscription Period   Subscription   Extending beyond
                                                                         Amount         May 13, 2021

                            Online testing        Aug. 2020 through
            Vendor 1                                                      $9,069           $1,968
                          environment tools           July 2021

                        Online access security    June 2020 through
            Vendor 2                                                       7,338            363
                              services                May 2021

                           Online teaching        Oct. 2020 through
            Vendor 3                                                      18,491            7,101
                             software                Sept. 2021

                          Workforce mobile        June 2020 through
            Vendor 4                                                       8,219            406
                            application               May 2021

              Total               -                       -              $43,117           $9,838
              SOURCE: OIG analysis of LESC’s Expenditure Data



U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                    18
                  Recognizing their limited experience administering Federal grants, LESC officials stated
                  that they decided to charge the total amount for the annual subscriptions to the grant
                  after consulting with their external Title IV compliance auditor. We noted that this
                  consultation did not address the cost principles applicable to Federal grants. By charging
                  to the grant the cost of subscriptions that extended beyond the grant performance
                  period, LESC officials did not apply nor appear to understand the applicable cost
                  principles contained in Uniform Guidance.

                  While the dollar amount of costs we questioned was small, it is critical that grantees not
                  prepay costs that extend beyond the grant performance period. Properly allocating
                  costs to the grant performance period helps to protect taxpayer dollars; minimize the
                  risk of fraud, waste, and abuse; and ensure Federal funds are used for allowable and
                  intended purposes.

                  As we reviewed documentation related to Lincoln, we noted that LESC also purchased
                  subscriptions for its other schools; thus, we believe the issue of using Institutional grant
                  funds to purchase subscriptions extending beyond the grant performance period might
                  have also occurred at these schools. We recommend that the Assistant Secretary for the
                  Office of Postsecondary Education determine if this issue occurred at LESC’s other
                  schools and take corrective action as appropriate.

                  LESC Reallocated Questioned Costs
                  After we discussed our audit results at the Exit Conference, 15 LESC officials informed us
                  that they reallocated the amounts we questioned in this finding to other expenditures
                  they believed were eligible to be charged to the grant. The officials stated that they
                  reallocated Lincoln’s Institutional grant funds to write off $710,274 in unpaid accounts
                  receivable for 148 students who withdrew from the school due to coronavirus. They also
                  provided an electronic spreadsheet detailing the write-off amounts for each student.
                  LESC officials said that their rationale for reallocating the funds was based on the
                  Department’s March 19, 2021, FAQ question 3. 16 Additionally, they stated that they




15
     We held an exit conference with LESC officials on May 25, 2021.
16
   The Department published guidance titled, Higher Education Emergency Relief Fund (HEERF I, II, and
III) Lost Revenue Frequently Asked Questions, March 19, 2021. HEERF I refers to grant funds awarded
under the CARES Act, HEERF II refers to the CRRSSA, and HEERF III refers to the ARP. Question 3 in this
FAQ addresses the potential sources of lost revenue that may be reimbursable under the HEERF grant
programs, including unpaid student accounts receivable.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                           19
              planned to revise Lincoln’s HEERF Institutional expenditure report on its website for the
              applicable quarter to reflect this change.

              Because we had concluded our audit fieldwork, we did not review the additional
              documentation LESC provided in relation to this reallocation. We recommend that the
              Assistant Secretary for the Office of Postsecondary Education review the reallocated
              funds for allowability during the audit resolution process. We will provide the
              spreadsheet, which contains student information, to OPE under separate cover.

              Recommendations
              Regarding LESC’s decision to reallocate the amounts we questioned in this finding, we
              recommend that the Assistant Secretary for the Office of Postsecondary Education—

                  2.1 Review the reallocated funds and determine whether LESC’s use of $710,274 of
                      Lincoln’s Institutional grant funds to write off unpaid accounts receivable for
                      students, who withdrew from the school due to coronavirus, was allowable
                      and for the intended purposes of applicable coronavirus relief legislation.
              If LESC’s reallocation of Lincoln’s Institutional grant funds is deemed unallowable, we
              recommend that the Assistant Secretary for the Office of Postsecondary require LESC
              to—

                  2.2 Return to the Department the $700,155 of Lincoln’s Institutional grant funds
                      that LESC improperly applied to credit student accounts for rent students paid
                      to third-party landlords and the $9,838 that LESC improperly spent for
                      subscriptions extending beyond the grant performance period and determine if
                      these issues occurred at LESC’s other schools and take corrective action as
                      appropriate.

              LESC Comments
              While LESC disagreed with the finding, LESC stated that Lincoln nevertheless repurposed
              the funds in question for uses it believes are allowable. LESC did not state whether it
              agreed or disagreed with the recommendations.

              LESC disagreed with the sub-finding, Crediting Student Accounts for Rent Students Paid
              to Third-Party Landlords, stating its belief that the OIG interpreted the Department’s
              guidance language too narrowly when reporting that the account credit is not
              equivalent to a cash payment to a student. LESC said that Lincoln routinely and
              repeatedly sought and received direct guidance from the Department, as it did on this
              topic, regarding the proper use of HEERF funds. LESC also stated its belief, contrary to
              the sub-finding, that issuing account credits was consistent with the Department’s
              guidance.



U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                        20
              LESC agreed with the sub-finding, Subscriptions that Extended beyond the Grant
              Performance Period. LESC agreed that Lincoln purchased four annual software
              subscriptions, a portion of which continued beyond the end of the grant performance
              period on May 13, 2021.

              LESC stated that Lincoln reallocated the costs we questioned regarding the rent credits
              and subscriptions for other uses even though it contends that using Institutional grant
              funds to reimburse itself for the student account credits was permissible. Specifically,
              LESC said that Lincoln used $710,274 (slightly more than the total amounts questioned
              in this finding) to write off student account balances, which it believes is a permissible
              use in accordance with the Department’s guidance on lost revenue. LESC also stated
              that, in addition to Lincoln’s action, its other schools have completed a similar
              reallocation of Institutional grant funds.

              OIG Response
              We disagree with LESC’s statement that Lincoln’s use of Institutional grant funds to
              reimburse itself for crediting student accounts for rent students paid to third-party
              landlords was consistent with the Department’s guidance. As noted in our finding,
              crediting student accounts reduced student debt without students’ permission.
              Moreover, the rent credits were not the equivalent of a cash payment because students
              could not readily convert the credits to cash and did not have discretion to use the funds
              for other eligible expenses.
              We did not make any changes to the finding and recommendations based on LESC’s
              comments. The finding acknowledges that LESC reallocated the amounts we questioned
              to other expenditures it believed were eligible to be charged to the grant and
              recommends that the Assistant Secretary for the Office of Postsecondary Education
              review the reallocated funds for allowability.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                       21
              Finding 3. LESC Did Not Follow Federal Cash
                Management Requirements
              LESC did not minimize the time between drawing down and disbursing Lincoln’s Student
              Aid and Institutional grant funds nor deposit its excess HEERF funds in an interest-
              bearing account, as required by Federal cash management requirements. LESC officials
              did not demonstrate an understanding of, and lacked policies and procedures to ensure
              compliance with, the requirements.

              Federal regulations at 2 C.F.R. § 200.305(b) state that non-Federal entities, such as
              Lincoln, “must minimize the time elapsing between the transfer of funds from [the
              Department] and the disbursement by the non-Federal entity ….” The regulations
              further address the timing of Federal payments, the need for an interest-bearing
              account, and remitting interest earnings to the Federal government:

                      (1) Advance payments to a non-Federal entity must be limited to the
                      minimum amounts needed and be timed to be in accordance with the
                      actual immediate cash requirements of the non-federal entity in
                      carrying out the purpose of the approved program or project. The
                      timing and amount of advance payments must be as close as is
                      administratively feasible to the actual disbursements by the non-Federal
                      entity …

                      (8) The non-Federal entity must maintain advance payments of Federal
                      awards in interest-bearing accounts …

                      (9) Interest earned amounts up to $500 per year may be retained by the
                      non-Federal entity for administrative expense. Any additional interest
                      earned on Federal advance payments deposited in interest-bearing
                      accounts must be remitted annually to the Department of Health and
                      Human Services Payment Management System …

              LESC did not follow Federal cash management requirements set forth in 2 C.F.R.
              § 200.305(b) because senior executives stated that they were not aware of the
              requirements until the Department issued guidance in October 2020. 17 However, when
              signing the respective Recipient’s Funding Certification and Agreement in April 2020 to
              access Lincoln’s Student Aid and Institutional grant funds, LESC certified that it would
              comply with 2 C.F.R. part 200. Further, Enclosure 4 of the Grant Award Notification for


17
  FAQ Rollup Document, October 14, 2020. Question 9 addressed the cash management requirements
set forth in 2 C.F.R. § 200.305(b).


U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                      22
              the Student Aid and Institutional grants, respectively dated in April and May 2020, also
              reminded grantees of existing cash management requirements in 2 C.F.R. part 200 and
              described the requirements in detail. Additionally, Lincoln has been a long-time
              participant in Title IV Federal student aid programs, which are subject to similar cash
              management requirements. Even though LESC officials had limited experience
              administering Federal grants, they were made aware of, agreed to comply with, and
              should have ensured compliance with Federal cash management requirements.

              Nevertheless, LESC’s cash management policies and procedures did not incorporate
              Federal cash management requirements related to minimizing the time between
              drawing down and disbursing Federal grant funds, maintaining the funds in an interest-
              bearing account, or remitting interest earned in excess of $500 to the Federal
              government. Recognizing its noncompliance with cash management requirements, LESC
              subsequently deposited Lincoln’s HEERF funds in interest-bearing accounts, returned
              unspent funds to the Department, and calculated and remitted interest to the
              Department.

              As we reviewed LESC’s documentation related to Lincoln and school information in the
              Department’s G5 system, we noted that the cash management issues we identified at
              Lincoln were also applicable at LESC’s other three schools. LESC returned unspent funds
              and remitted interest to the Department for Lincoln and its other schools at the same
              time.

              LESC Did Not Minimize the Time Between Drawing Down and
              Disbursing Institutional and Student Aid Grant Funds
              LESC drew down all of Lincoln’s HEERF grant funds in advance of immediate cash needs
              and, thus, did not minimize the time between drawing down and disbursing the funds.
              The Department authorized $6,670,527 in Student Aid grant funds for Lincoln on
              April 28, 2020, and LESC drew down all the funds on May 1, 2020. Further, the
              Department authorized $6,670,527 in Institutional grant funds for Lincoln on May 14,
              2020, and LESC drew down all those funds on June 29, 2020. Lincoln did not have an
              immediate cash need for all the drawn funds, as discussed below; thus, LESC did not
              comply with 2 C.F.R. § 200.305(b)(1).

              As shown in Table 3 on the following page, LESC did not begin to disburse Lincoln’s
              Institutional grant funds until 2 months (67 days) after drawing down the funds. By
              September 30, 2020, LESC had disbursed only 33 percent of Lincoln’s Institutional grant
              funds and made no further disbursements the rest of the year. LESC returned
              $3,528,466 (53 percent) to the Department 176 days after drawing down the funds.
              LESC did not return the remaining $963,243 because senior executives planned to and
              did disburse the funds in early January 2021, more than 185 days after the funds were



U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                     23
              drawn. LESC officials attributed delays in spending Institutional grant funds to delays in
              receiving guidance from outside sources, such as external auditors and the Department,
              about whether anticipated disbursements were allowable under the CARES Act and
              HEERF. However, as noted above, LESC officials were made aware of, and agreed to
              comply with, Federal cash management requirements and should not have drawn down
              the funds until they were prepared to spend them.

              Table 3. Draw Down and Disbursement Activity for Lincoln’s Institutional Grant Funds,
              June 29 through December 31, 2020
                                                                            Percent of      Number of
                                  Draw Down and          Remaining
                                                                           Drawn Funds    Days Elapsed
                   Date           (Disbursement)     Institutional Grant
                                                                             Disbursed    from June 29,
                                      Amount                Funds
                                                                           (Cumulative)       2020

               June 29, 2020         $6,670,527           $6,670,527               0%           0

                Sept. 4, 2020         (538,209)           6,132,318                8%           67

               Sept. 30, 2020        (1,640,609)          4,491,709            33%              93

               Dec. 22, 2020 a       (3,528,466)           963,243             86%             176

               Dec. 31, 2020              0                963,243                 -           185
              SOURCE: OIG Analysis of LESC’s Bank Activity for CARES Act Account
              a
                LESC returned $3,528,466 to the Department on December 22, 2020.

              As shown in Table 4 on the following page, LESC began disbursing Lincoln’s Student Aid
              grant funds within 15 days of drawing down the funds. However, LESC inappropriately
              held onto the remaining funds as it continued to disburse grant funds on generally a
              monthly basis through November 2020. By the time LESC returned the remaining
              $325,027 (5 percent) to the Department, 235 days had elapsed since drawing down the
              funds.

              It is important that schools not draw Federal funds before they have immediate needs
              for the funds. The U.S. Treasury incurs additional borrowing costs when a school draws
              Federal funds in advance of its immediate cash needs because the U.S. Treasury often
              borrows the cash needed to fund Federal programs and, as a result, incurs interest
              costs.

              LESC returned a total of $3,853,493 of Lincoln’s unspent funds to the Department on
              December 22, 2020, during our audit. LESC stated they expected to spend all the funds




U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                     24
                by the end of each grant’s 1-year performance period—April 27, 2021, for the Student
                Aid grant, and May 13, 2021, for the Institutional grant. 18

                Table 4. Draw Down and Disbursement Activity for Lincoln’s Student Aid Grant Funds,
                May 1 through December 31, 2020
                                                                              Percent of      Number of
                                   Draw Down and          Remaining
                                                                             Drawn Funds     Days Elapsed
                     Date          (Disbursement)      Student Aid Grant
                                                                               Disbursed     from May 1,
                                       Amount               Funds
                                                                             (Cumulative)       2020

                  May 1, 2020         $6,670,527           $6,670,527                0%             0

                 May 13, 2020         (4,955,000)           1,715,527                74%           12

                 May 28, 2020          (61,250)             1,654,277                75%           27

                 June 15, 2020          (5,250)             1,649,027                75%           45

                  July 6, 2020         (98,000)             1,551,027                77%           66

                 July 27, 2020          (7,250)             1,543,777                77%           87

                 Aug. 19, 2020         (553,000)             990,777                 85%           110

                 Sept. 10, 2020        (160,500)             830,277                 88%           132

                 Oct. 13, 2020          (1,500)              828,777                 88%           165

                 Nov. 20, 2020         (503,750)             325,027                 95%           203

                 Dec. 22, 2020a        (325,027)                0                     -            235

                 Dec. 31, 2020             0                    0                     -             -
                SOURCE: OIG Analysis of LESC’s Bank Activity for CARES Act Account
                a
                  LESC returned $325,027 to the Department on December 22, 2020.




18
  According to the CARES Act HEERF reports that were posted on LESC’s website, it appears Lincoln
spent all of its $6.7 million in Student Aid grant funds as of the quarter ending March 31, 2021, and
spent almost all (99 percent) of its $6.7 million in Institutional grant funds as of the quarter ending
June 30, 2021.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                          25
              LESC Did Not Maintain Institutional and Student Aid Grant
              Funds in Interest-Bearing Accounts at First
              Upon drawing down Lincoln’s Student Aid and Institutional grant funds from the
              Department, LESC maintained the funds in a noninterest-bearing bank account. LESC
              converted the account to an interest-bearing account in early November 2020, shortly
              after the Department issued the guidance addressing cash management requirements
              in 2 C.F.R. § 200.305(b).

              LESC Calculated and Remitted Interest
              In January 2021, LESC calculated the amount of interest Lincoln’s Student Aid and
              Institutional grant funds might have earned had the funds been deposited in an interest-
              bearing account from the start. LESC applied an interest rate of 0.3 percent to the
              remaining balance of unspent Student Aid and Institutional grant funds, respectively,
              from the date of the initial draw to December 22, 2020, when nearly all of Lincoln’s
              remaining funds were remitted to the Department. Based on Lincoln’s Student Aid and
              Institutional remaining grant funds (as shown in Table 3 and Table 4 above), LESC
              calculated a total of $10,826 in interest and remitted this amount to the Department on
              January 29, 2021.

              We did not assess the reasonableness of LESC’s method for calculating interest.
              However, we noted that its method did not consider imputed interest for the period
              when the HEERF funds were maintained in noninterest-bearing accounts (from grant
              draw down dates through October 2020) nor the actual interest earned (in November
              and December 2020). Instead LESC used an interest rate of 0.3 percent, which was the
              rate on its December 2020 bank statement, for the entire period.

              We also noted that LESC similarly calculated and remitted interest for its other three
              schools in the same manner. For the three schools and Lincoln combined, LESC
              calculated a total of $23,400 in interest as shown in Table 5 on the following page,
              which was sent to the Department on January 29, 2021.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                       26
              Table 5. LESC Summary of Calculated Interest by School and HEERF Grant through
              December 22, 2020
                                   OPEID a           Student Aid          Institutional
              School                                                                         Total Interest
                                   Number             (84.425E)            (84.425F)

               Lincoln             00793800           $2,707.03             $8,119.28          $10,826.31

              Iselin, NJ           01246100             536.45              5,207.97            5,744.42

           New Britain, CT         00730300             708.40              5,379.57            6,087.97

            Columbia, MD           00793600             99.11                642.37              741.48

            Total Interest             -              $4,050.99            $19,349.19          $23,400.18
              SOURCE: LESC
              a
                The Department uses the OPE Identification (OPEID) number to identify a school for student
              financial aid eligibility purposes.

              Recommendations
              We recommend that the Assistant Secretary for the Office of Postsecondary
              Education—

                   3.1     Require LESC to incorporate in its policies and procedures the cash
                           management requirements for minimizing the time between drawing down
                           and disbursing Federal grant funds, including HEERF funds, maintaining the
                           funds in an interest-bearing account, and remitting interest earned more than
                           $500 in accordance with 2 C.F.R. § 200.305(b).

                   3.2     Determine whether LESC accurately calculated interest and properly remitted
                           the interest returned in January 2021, in accordance with 2 C.F.R.
                           § 200.305(b)(9).

              LESC Comments
              LESC agreed with the finding. LESC stated that Lincoln did not have prior experience
              with the cash management requirements of 2 C.F.R. part 200 and did not initially
              establish all the appropriate procedures. LESC said that, after the Department
              highlighted the cash management requirements in guidance published in October 2020,
              Lincoln deposited its HEERF funds in an interest-bearing account, returned the HEERF
              funds not needed immediately to its account in the Department’s G5 system, and
              calculated and remitted interest to the Department.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                              27
              LESC did not explicitly state whether it agreed or disagreed with the recommendations,
              but did state that it took corrective action in response to the recommendation to
              incorporate the cash management requirements in its policies and procedures
              (Recommendation 3.1). Specifically, LESC stated that Lincoln has revised its cash
              management policy in accordance with 2 C.F.R. § 200.305(b). LESC provided
              documentation of this corrective action. Additionally, LESC stated Lincoln’s belief that its
              interest calculation was consistent with prevailing interest rates during the April through
              December 2020 timeframe.

              OIG Response

              We acknowledge the corrective actions LESC stated that it took to deposit HEERF funds
              in an interest-bearing account, return unspent funds, and calculate and remit interest
              after the Department published guidance highlighting the cash management
              requirements in October 2020. We reviewed the documentation LESC provided and
              found that the corrective action was responsive to Recommendation 3.1.

              We did not change the recommendation for the Department to determine whether
              LESC calculated interest accurately and remitted the interest properly. As noted in the
              finding, LESC’s method for calculating interest did not consider imputed interest nor the
              actual interest earned. Additionally, LESC returned the interest to the Department
              instead of to the Department of Health and Human Services in accordance with 2 C.F.R.
              § 200.305(b)(9).




U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                       28
                Other Matter. Student Aid and Institutional
                  Reporting
                Schools must report publicly on their use of HEERF funds by posting the required
                information on the school’s primary website on a quarterly basis. The Department
                prescribed the contents and due dates for schools’ quarterly Student Aid and
                Institutional reports. We determined that the information in Lincoln’s initial and 45-day
                Student Aid reports, and Student Aid and Institutional reports for the periods ending
                September 30 and December 31, 2020, was generally accurate, complete, and timely. 19
                However, after posting updated reports LESC did not keep previous Student Aid reports
                posted on its website, contrary to Department guidance.

                In October 2020, the Department offered a webinar on the quarterly reporting
                requirements for HEERF grantees. Following the webinar, the Department issued
                guidance about maintaining all the quarterly reports on the school’s public website.
                Technical FAQ Question 2 in the guidance states: “We ask that institutions separately
                maintain each quarterly report on their website, which adds transparency and
                accountability as to when and how institutions expended funds.” 20

                Because schools were not required to submit the quarterly reports to the Department,
                the reports appearing on school websites provided an important means to ensure
                transparency and accountability. In April 2021, we noted that LESC did not keep the
                previous Student Aid reports posted on its website for any of its schools. When we
                brought this matter to their attention, LESC officials stated that it was an oversight and
                promptly uploaded the missing reports to their website.

                We suggest that the Assistant Secretary for the Office for Postsecondary Education take
                steps to ensure and confirm LESC maintains previous Student Aid reports for all of its
                schools on its public website, as required.

                LESC Comments
                LESC did not state whether it agreed or disagreed with this matter or suggestion.
                However, LESC stated that Lincoln immediately restored the earlier reports to its
                website when the OIG brought this matter to its attention. LESC said that a section of



19
  We did not determine the impact of our findings on the quality of the data in Lincoln’s quarterly
Student Aid and Institutional reports.
20
  In a letter to HEERF project directors dated October 19, 2020, the Department provided a summary of
the webinar, resources, and Technical FAQs on the quarterly public reporting requirements.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                         29
              Lincoln’s public website for information regarding COVID-19 and the CARES Act will also
              include the required quarterly reports for both the Student Aid and Institutional HEERF
              funds received under the CRRSAA and ARP. LESC also stated that all of these reports will
              be maintained for a minimum of 3 years after the submission of the final report in
              accordance with 2 C.F.R. § 200.333 (record retention).

              OIG Response
              We appreciate LESC taking prompt corrective action when we brought the matter to its
              attention in April 2021. LESC’s proposed action, if implemented as described for all its
              schools, is responsive to our suggestion.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                    30
                  Other Matter. Incorrect Data Universal Number
                    System Number
                  During our audit we noted that the Department awarded Lincoln’s Institutional grant
                  under the Data Universal Number System (DUNS) number 21 assigned to LESC’s
                  Columbia, Maryland school (Columbia), as shown in Table 6. As a result, LESC had to
                  draw down Lincoln’s Institutional grant funds ($6,670,527) under Columbia’s DUNS
                  number. We noted that Lincoln’s application for Federal Assistance (SF-424) for the
                  Institutional grant funds reflected the incorrect DUNS. It was not clear what review
                  processes were in place at the school or at the Department that would allow this error
                  to go unnoticed. We determined that LESC appropriately treated Lincoln’s Institutional
                  grant funds as being awarded to Lincoln and spent the funds only for the benefit of
                  Lincoln’s eight campuses.

                  Table 6. Lincoln and Columbia HEERF Grant Awards by DUNS Number
                                                              Student Aid           Institutional
                        School         DUNS Number
                                                               (84.425E)              (84.425F)

                        Lincoln           150600344            $6,670,527                 -

                                                                                      $6,670,527
                       Columbia           064857808              574,773              + 574,773
                                                                                      $7,425,300
                  SOURCE: Department’s G5 grants management system

                  LESC officials said that they had to submit the annual report 22 for Lincoln’s Institutional
                  grant funds under Columbia’s DUNS number. LESC advised the Department of the
                  incorrect DUNS number for Lincoln’s Institutional grant funds and was informed the
                  error could not be corrected. Thus, LESC had to combine Lincoln’s and Columbia’s
                  Institutional grant funds ($7,425,300) in the Columbia annual report. We are making the
                  Department aware of this matter because it affects the quality of the Institutional data
                  in the annual reports for Lincoln and Columbia. In its review of grant applications, we
                  suggest that the Department ensure that the DUNS number is accurately reflected in
                  both the grant application and award documents.




21
     The Department uses the DUNS number to allocate and track grant awards.
22
  Schools’ first annual report on HEERF funds was due to the Department on February 8, 2021. We did
not assess the timeliness or quality of the annual report during our audit.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                           31
              LESC Comments
              LESC did not state whether it agreed or disagreed with this matter or suggestion.
              However, LESC stated that the incorrect DUNS number appeared to result from an error
              on Lincoln’s application that inadvertently listed Columbia’s DUNS number instead of
              Lincoln’s number. LESC also said that it contacted the Department when Lincoln
              received the Institutional grant funds in the incorrect account in the Department’s G5
              system. LESC stated that the Department and Lincoln determined that a solution was
              not readily available. LESC also stated that the DUNS number error has not recurred,
              and each of its schools has received their CRRSAA and ARP funds in the correct account
              and will be able to prepare quarterly reports on the use of these funds accurately.

              OIG Response
              LESC’s statement that the DUNS number error has not recurred, if accurate, is
              responsive to this matter. We note, however, that our suggestion for the Department to
              ensure the accuracy of DUNS numbers during its review of grant applications relates to
              LESC’s schools in addition to all other recipients of HEERF funds.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                  32
              Appendix A. Scope and Methodology
              We initially planned for our audit to cover Lincoln College of Technology’s use of HEERF
              funds from the grant award date through September 30, 2020. The award date for
              Lincoln’s Student Aid grant was April 28, 2020, and the award date for its Institutional
              grant was May 14, 2020. Because LESC drew down but did not expend all of Lincoln’s
              Student Aid and Institutional grant funds by September 30, 2020, we expanded our
              audit period to December 31, 2020. Our audit also covered LESC’s cash management
              practices and reporting of HEERF expenditures.

              To achieve our audit objective, we gained an understanding of the following laws,
              regulations, Department guidance, and grant documents relevant to HEERF:

                  •   Section 18004 of the CARES Act, Higher Education Emergency Relief Fund;

                  •   Section 314 of CRRSAA, Higher Education Emergency Relief Fund;

                  •   Section 2003 of ARP, Higher Education Emergency Relief Fund;

                  •   2 C.F.R. part 200 (Uniform Guidance, January 1, 2020, volume), including
                      § 200.305(b) (cash management for non-Federal entities), § 200.309 (period of
                      performance), and § 200.318-.320 (general procurement standards,
                      competition, and methods of procurement);
                  •   Department’s Interim Final Rule (June 17, 2020) and Final Regulation (May 14,
                      2021) regarding student eligibility; Secretary of Education letters (April 9 and
                      April 21, 2020) addressing school access to HEERF grants; and five HEERF
                      Frequently Asked Questions documents issued from April through October
                      2020, including Student Portion FAQs (April 9, 2020) and FAQ Rollup Document
                      (October 14, 2020); and

                  •   Lincoln’s Student Aid and Institutional grant documents, including its signed
                      Certification and Agreement and the Grant Award Notification documents.
              We also reviewed the following prior OIG and Government Accountability Office (GAO)
              reports to gain an understanding of common risks associated with managing emergency
              financial relief grants, such as HEERF:

                  •   OIG Reports—Challenges for Consideration in Implementing and Overseeing the
                      CARES Act, ED-OIG/X20DC0003 (September 2020); and Lessons from
                      Implementing the American Recovery and Reinvestment Act of 2009,
                      ED-OIG/X09M0002, September 2014; and

                  •   GAO Report—COVID-19: Opportunities to Improve Federal Response Efforts,
                      GAO-20-625, June 2020.



U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                      33
              Through interviews, we gained an understanding of LESC’s processes for drawing down
              and managing Lincoln’s HEERF grant funds, awarding and distributing emergency
              financial aid grants to students, spending Institutional grant funds, and preparing
              required HEERF expenditure reports. We interviewed senior officials from LESC’s
              Executive, Finance/Accounting, Compliance/Regulatory, and Information Technology
              departments who had a significant role in administering Lincoln’s HEERF grants. To
              assess the reliability of the testimonial evidence, we compared and corroborated
              information obtained through corporate-level interviews by reviewing LESC documents
              and records and interviewing school officials from the Student Administration
              department at Lincoln’s Nashville and Grand Prairie campuses. We concluded that the
              testimonial evidence we obtained was sufficiently reliable within the context of our
              audit objective.

              We reviewed LESC’s written policies and procedures for managing, authorizing, and
              accounting for HEERF-related transactions and expenditures. We also reviewed LESC’s
              written policies and procedures for HEERF-related cash management and reviewed
              Lincoln’s drawdown and refund information from the Department’s G5 system. We also
              reviewed relevant information from LESC’s bank statements; accounting and student
              management systems; and electronic spreadsheets documenting HEERF distribution and
              expenditure data. We describe how we used this information to review Lincoln’s (1) use
              of Student Aid and Institutional grant funds in the Sample Methodology section on the
              next page and (2) cash management practices and HEERF reports below.

              Cash Management. We compared the dates and amounts of Lincoln’s drawdowns of
              Student Aid and Institutional grant funds (obtained from the Department’s G5 system)
              to its expenditure records to determine whether LESC minimized the time between
              drawdown and disbursement of those funds. We also traced drawdown information
              from the Department’s G5 system to LESC’s bank statements and accounting records to
              verify that the information reconciled. Lastly, we reviewed the type of accounts that
              LESC used to deposit Lincoln’s HEERF funds to determine whether the accounts earned
              interest.

              Reporting. We reviewed the following Student Aid and Institutional reports to
              determine whether (1) the information included in those reports was complete and
              accurate and (2) LESC posted Lincoln’s HEERF reports on time:

                  •   Student Aid reports dated June 1 (initial report) and July 15, 2020 (45-day
                      report); and

                  •   Student Aid and Institutional reports for the periods ending September 30 and
                      December 31, 2020.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                    34
              To determine whether the reports included complete and accurate information, we
              compared the information in each report to the Department’s reporting requirements
              and to the applicable underlying source data (for example, school accounting records
              and bank statements). To determine whether the reports were submitted on time, we
              compared each report's posting date to the reporting due date established by the
              Department.

              Sampling Methodology
              We tested a sample of Student Aid distributions and Institutional expenditures to
              determine whether LESC used the Student Aid and Institutional portions of Lincoln’s
              HEERF funds for allowable and intended purposes.

              Student Aid Expenditure Selection and Testing
              During our audit period, LESC used Lincoln’s Student Aid grant funds to award
              emergency financial aid grants to 8,435 students. We used stratified, random sampling
              to select 30 students for review. We developed seven strata and used a risk-based
              approach to randomly select students from each stratum. To develop the strata, we
              conducted the following steps:

                  •   We analyzed the data that LESC provided identifying the universe of students
                      who were awarded a grant.
                  •   From this data, we created three unique groups based on LESC’s process for
                      awarding the emergency financial aid grants—(1) students who had an ISIR on
                      file and received an additional $500 in their grant because they lived in the
                      school dormitory (Nashville) or third-party housing; (2) students who did not
                      have an ISIR on file; and (3) students who had an ISIR on file and did not receive
                      the additional $500 in their grant.

                  •   Within each group, we determined whether the students had a FAFSA in the
                      Department’s Central Processing System, received Title IV financial aid funds in
                      the Department’s National Student Loan Data System, or did not have a record
                      in either system.

                  •   Based on the information from the Department systems, we created a stratum
                      for each unique situation that applied.
              Once we defined the seven strata, we used a risk-based approach to determine the
              number of students to select in each stratum, as summarized in Table 7 on the following
              page. We selected a disproportionately greater number of students who did not have an
              ISIR on file because we considered them to be of higher risk for determining whether
              they could be Title IV-eligible. Because there is no assurance that the students tested



U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                      35
              were representative of the universe of students who received emergency financial aid
              grants, the results could not be projected to the untested students.

              Table 7. Universe and Sample of Student Aid Grant Expenditures through
              December 31, 2020
                                                                                    Sample Coverage
                                                   Universe Student Sample Student Student Count and
    Group-              Description                Count and Dollar   Count and
    Stratum                                                                          Dollar Amount
                                                       Amount       Dollar Amount (Percent by Stratum)


              Student had an ISIR and received
              an additional $500 in their grant;      22 students      1 student       4.5% students
      1–1
              student had a FAFSA and did not          $26,000          $1,000             3.9%
                   receive Title IV funds

              Student had an ISIR and received
              an additional $500 in their grant;     796 students      5 students      0.6% students
      1–2
                  student had a FAFSA and             $1,150,250        $7,500             0.7%
                   received Title IV funds

                Student did not have an ISIR;         56 students      1 student       1.8% students
      2–3     student had a FAFSA and did not
                    receive Title IV funds             $ 28,000          $500              1.8%


                Student did not have an ISIR;         12 students      1 student       8.3% students
      2–4         student had a FAFSA and
                   received Title IV funds              $6,000           $500              8.3%


                Student did not have an ISIR;        134 students      7 students      5.2% students
      2–5     student did not have a FAFSA and
                 did not receive Title IV funds        $67,000          $3,500             5.2%


              Student had an ISIR; student had       778 students      5 students      0.6% students
      3–6       a FAFSA and did not receive
                       Title IV funds                  $464,500         $2,750             0.6%


              Student had an ISIR; student had      6,637 students    10 students      0.2% students
      3–7          a FAFSA and received
                       Title IV funds                 $4,603,750        $7,250             0.2%


                                                    8,435 students    30 students      0.4% students
     Totals                   -
                                                      $6,347,500        $23,000            0.4%



              For the 30 emergency financial aid grants tested, we reviewed relevant information
              from LESC’s student management system to confirm the students met eligibility
              requirements. We confirmed the students were actively enrolled at the school, enrolled


U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                       36
              in an eligible program, and met other Title IV eligibility requirements. We limited our
              review to student eligibility. We did not perform work to determine how students spent
              their grant funds or whether the students used the funds for intended purposes.

              We also reviewed student information in the third-party servicer’s (debit card
              contractor) data system to determine if the grant funds had been distributed to the
              student and activated. We followed up on three debit cards that were not activated and
              received confirmation from LESC officials that the cards had been deactivated.

              Institutional Expenditure Selection and Testing
              During our audit period, LESC used Lincoln’s Institutional grant funds to make
              1,732 purchase transactions totaling $3.4 million. We used a combination of stratified
              random and judgmental sampling to select 30 Institutional expenditures to review. To
              define the strata, we analyzed the universe of expenditures from Lincoln’s quarterly
              Institutional expenditure reports and the supporting expenditure data and created a
              stratum for each major expenditure category. This resulted in a total of seven strata
              from which we randomly selected 3 transactions and judgmentally selected
              27 transactions, as summarized in Table 8 on the following page. Because there is no
              assurance that the transactions tested were representative of the universe of
              transactions, the results could not be projected to the untested transactions.

              For the 30 transactions tested, we reviewed supporting documentation such as invoices,
              authorizations, and justifications to determine whether the expenditures were
              allowable and used for purposes intended under the CARES Act. Specifically, we
              reviewed each expenditure to determine whether it was valid, authorized, allowable,
              allocable, and reasonable under the CARES Act and in accordance with Uniform
              Guidance at 2 C.F.R. part 200 and applicable Department guidance (HEERF FAQs).




U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                       37
               Table 8. Universe and Sample of Institutional Expenditures as of December 31, 2020
                                Universe            Sample         Sample Coverage
                               Transaction        Transaction     Transaction Count     Selection Method
    Stratum   Description
                             Count and Dollar   Count and Dollar and Dollar Amount
                                 Amount             Amount       (Percent by Stratum)

                                                                                        Stratified by
                Hotel                                                                   vendor to
              Lodging for    120 transactions     3 transactions    3% transactions     randomly select
       1        Social                                                                  2 transactions for
              Distancing         $973,567           $35,865               4%            one vendora and
              (Nashville)                                                               1 transaction for
                                                                                        the other vendor

                                                                                        Selected 8
                                                                                        students in
               Dormitory
                                                                                        different programs
                 Housing       472 students        8 students         2% students       and with varying
       2        and Meal
                                 $858,015           $15,998               2%            student account
                  Fees
                                                                                        balances (debit,
               (Nashville)
                                                                                        credit, or zero
                                                                                        balance)

                                                                                        Selected 7
                                                                                        students from
                               461 students        7 students         2% students       different campuses
              Third-Party
       3                                                                                with varying
               Housing           $700,155            $8,415               1%            account balances
                                                                                        (debit, credit, or
                                                                                        zero balance)

                                                                                        Selected the 3
                                                                                        highest
                                                                                        transactions, 1
                                                                                        highest employee
                             539 transactions     5 transactions    1% transactions     reimbursement
                Campus
       4                                                                                transaction, and
                 Safety          $427,726           $81,208               19%           1 highest
                                                                                        transaction with a
                                                                                        vendor whose
                                                                                        total purchases
                                                                                        exceeded $10,000


                              33 transactions     4 transactions    12% transactions    Selected the 4
       5      Computers                                                                 highest
                                 $350,717           $149,753              43%           transactions




U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                             38
                               Universe             Sample         Sample Coverage
                              Transaction         Transaction     Transaction Count          Selection Method
    Stratum   Description
                            Count and Dollar    Count and Dollar and Dollar Amount
                                Amount              Amount       (Percent by Stratum)

               Distance
                             48 transactions      2 transactions       4% transactions       Selected the 2
               Learning
       6                                                                                     highest
               Subscrip-         $85,629             $34,422                 40%             transactions
                 tions

               Equipment     59 transactions       1 transaction       2% transactions       Selected the 1
       7          and
                                 $25,000              $3,029                 12%             highest transaction
                Supplies

                                  1,732
                                                 30 transactions       2% transactions
       -           Total       transactions                                                           -
                                                    $328,690                 10%
                               $3,420,809c
               a
                This vendor accounted for 87 percent of the hotel lodging expenditures.
               b
                The total dollar amount is slightly different ($7) from the total expenditures reported by LESC in
               Table 1 (Finding 2) due to rounding.

               Use of Computer-Processed Data
               We relied, in part, on computer-processed data from LESC’s student management and
               accounting systems. We used information in its student management system on
               enrollment, attendance, ledger activity (account balances), and other data necessary to
               confirm a student’s eligibility to receive an emergency financial aid grant. To assess the
               reliability of Title IV information, we compared student data to information contained in
               the Department’s National Student Loan Data System and Central Processing System. To
               assess the reliability of the data in the accounting system, we compared HEERF fund
               deposit and disbursement information recorded in the accounting system to the
               Department’s G5 system, Lincoln’s monthly bank statements, and vendor invoices. We
               did not identify any issues and concluded that the data in LESC’s student management
               and accounting systems were sufficiently reliable for the purposes of our audit.

               Additionally, we relied on computer-processed data from LESC’s electronic spreadsheets
               documenting Lincoln’s use of HEERF funds. We used the data to select a sample of
               students who were awarded emergency financial aid grants and a sample of
               Institutional expenditures for testing. We used data on the number of students receiving
               emergency financial aid grants and the total dollar amounts of those grants and
               Institutional expenditures to determine whether LESC included complete and accurate
               information in Lincoln’s Student Aid and Institutional reports. We also used data on cash
               receipts and disbursements to determine whether LESC minimized the time between
               drawing down and disbursing HEERF funds. To assess the reliability of the data, we


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              compared student, expenditure, and cash flow data to information in LESC’s student
              management and accounting systems, vendor invoices, monthly bank statements, and
              Student Aid and Institutional reports. The information reconciled and we concluded that
              the data in LESC’s electronic spreadsheets were sufficiently reliable for purposes of our
              audit.

              We also relied on computer-processed data contained in LESC’s third-party servicer’s
              (debit card contractor) information system. We used debit card data to determine
              whether LESC distributed Student Aid grant funds to students and whether students had
              activated their debit cards. To assess the reliability of the data, we verified that students
              who were awarded emergency financial aid grants were included in the contractor’s
              system. We concluded that the data in the contractor’s information system were
              sufficiently reliable for purposes of our audit.

              Internal Controls
              We considered only limited aspects of internal controls over compliance with the
              applicable Federal requirements to be significant within the context of the audit
              objective. Therefore, our assessment of the design of internal controls was limited to
              gaining an understanding of LESC’s processes (controls) within the context of the
              individual transactions selected for testing and determining the underlying cause for
              identified findings and other matters.

              Compliance with Standards
              We conducted this performance audit in accordance with generally accepted
              government auditing standards. Those standards require that we plan and perform the
              audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our
              findings and conclusions based on our audit objective. We believe that the evidence
              obtained provides a reasonable basis for our findings and conclusions based on our
              audit objective.

              We performed our audit work remotely from December 2020 through May 2021. We
              held an exit conference with LESC officials on May 25, 2021, to discuss the results of our
              audit.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                        40
               Appendix B. LESC Corporate Structure, Schools,
                 and Campuses
               In April 2020, LESC owned and operated a total of 4 schools with 22 campuses located in
               14 States, as shown in Table 9. LESC centrally administered the HEERF grants for each
               school. Our audit covered the CARES Act HEERF grants awarded to one of its schools—
               Lincoln (OPEID ED007893800).

               Table 9. LESC Schools and Campus Locations and CARES Act HEERF Grants, April 2020
             OPEID             ED00793800        ED00730300          ED1246100             ED00793600

                              Indianapolis, IN   New Britain, CT                           Columbia, MD a
          Main Campus                                                  Iselin, NJ
                                 (Lincoln)        (New Britain)                              (Columbia)

            Additional          Mahwah, NJ         Shelton, CT       Paramus, NJ
            Campuses             Union, NJ        East Windsor,     Moorestown, NJ
                              Whitestone, NY           CT             Lincoln, RI
                                   South          Allentown, PA     Somerville, MA
                               Plainfield, NJ    Philadelphia, PA    Las Vegas, NV                -
                                Denver, CO       Melrose Park, IL    Marietta, GA
                               Grand Prairie,
                                    TX
                               Nashville, TN

         Student Aid Grant
                                $6,670,527         $3,247,523         $3,226,412              $574,774


        Institutional Grant
                                6,670,527 b         3,247,522         3,226,411               574,773


        Total HEERF Grants
                               $13,341,054         $6,495,045         $6,452,823             $1,149,547

               SOURCE: LESC OPEID Structure; U.S. Department of Education Student Aid and Institutional Grant
               Allocation Data
               a
                 The Columbia school became one of New Britain’s campus locations on September 10, 2020.
               LESC officials said that they continued to administer Columbia’s HEERF grants separate from the
               other New Britain campuses.
               b
                 As we noted in “Other Matter. Incorrect Data Universal Number System Number,” Lincoln’s
               Institutional grant was erroneously awarded to the Columbia school.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                                            41
              Appendix C. Acronyms and Abbreviations
               ALN             Assistance Listing Number

               ARP             American Rescue Plan

               CARES Act       Coronavirus Aid, Relief, and Economic Security Act

               C.F.R.          Code of Federal Regulations

               Columbia        Lincoln Educational Services Corporation’s Columbia, Maryland
                               school

               CRRSAA          Coronavirus Response and Relief Supplemental Appropriations Act

               Department      U.S. Department of Education

               DUNS            Data Universal Number System

               EFC             Expected Family Contribution

               FAFSA           Free Application for Federal Student Aid

               FAQ             frequently asked question

               GAO             Government Accountability Office

               HEERF           Higher Education Emergency Relief Funds

               HVAC            heating, ventilation, and air conditioning

               IFR             Interim Final Rule

               ISIR            Institutional Student Information Record

               LESC            Lincoln Educational Services Corporation

               Lincoln         Lincoln College of Technology

               OIG             Office of Inspector General

               OPE             Office of Postsecondary Education

               OPEID           Office of Postsecondary Education Identification

               Title IV        Title IV of the Higher Education Act of 1965

               Uniform         Uniform Administrative Requirements, Cost Principles, and Audit
               Guidance        Requirements for Federal Awards



U.S. Department of Education
Office of Inspector General
ED-OIG/A20CA0016                                                                               42
              LESC Comments




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