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University of Cincinnati's Use of Higher Education Emergency Relief Fund Student Aid and Institutional Grants (ED-OIG/A20US0045)

Summary

Final audit report ED-OIG/A20US0045 of the U.S. Department of Education Office of Inspector General, dated January 17, 2023, addressed to Dr. Neville Pinto, President of the University of Cincinnati, on the University's use of Higher Education Emergency Relief Fund (HEERF) Student Aid and Institutional grants. It reports that the University spent $109.9 million (83 percent) of its total HEERF allocation of $132.8 million as of September 30, 2021, and generally used the funds for allowable and intended purposes. It reports that the University overstated the lost revenue charged to its Institutional grant by $797,965, did not fully comply with requirements for $1,916,041 (3 percent) of its noncompetitive procurements, and did not fully comply with cash management requirements. The University agreed with all recommendations except Recommendation 3.2.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Issuer
U.S. Department of Education, Office of Inspector General
Document type
Report
Date
2023-01-17

Cite this document

“University of Cincinnati's Use of Higher Education Emergency Relief Fund Student Aid and Institutional Grants (ED-OIG/A20US0045).” U.S. Department of Education, Office of Inspector General, dated 2023-01-17. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/university-cincinnati-heerf/, SHA-256 58b6ec3074bb420d8e4d9126763644a12a9393dac4f033d040db8f5a351da9f8.

Full text

                 U.S. Department of Education
                 Office of Inspector General




University of Cincinnati’s
Use of Higher Education
Emergency Relief Fund
Student Aid and
Institutional Grants
January 17, 2023
ED-OIG/A20US0045

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




January 17, 2023


Dr. Neville Pinto, President
University of Cincinnati
2600 Clifton Avenue
Cincinnati, OH 45221


Dear Dr. Pinto:

Enclosed is our final audit report, “University of Cincinnati’s Use of Higher Education Emergency Relief
Fund Student Aid and Institutional Grants,” Control Number ED-OIG/A20US0045. 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. Nasser Paydar
        Assistant Secretary
        U.S. Department of Education
        400 Maryland Avenue, S.W.
        Washington, D.C. 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. University of Cincinnati Generally Used Student Aid Grant Funds for Allowable
and Intended Purposes but Needs to Strengthen its Review and Documentation
Processes .......................................................................................................................... 11
Finding 2. University of Cincinnati Generally Used Institutional Grant Funds for Allowable
and Intended Purposes but Needs to Strengthen Certain Processes to Ensure
Compliance with Grant Requirements ............................................................................. 23
Finding 3. University of Cincinnati Did Not Fully Comply with Federal Cash Management
Requirements.................................................................................................................... 31
Finding 4. University of Cincinnati’s HEERF Quarterly Reporting Was Not Always
Accurate and Publicly Available ........................................................................................ 37
Appendix A. Scope and Methodology............................................................................... 41
Appendix B. Acronyms and Abbreviations........................................................................ 53
University of Cincinnati Comments .................................................................................. 54
               Results in Brief
               What We Did
               Our objective was to determine whether the University of Cincinnati (University) 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 the University’s cash management
               practices and the timeliness and quality of the data the University reported on its use of
               HEERF funds. 1 Our audit covered the University’s HEERF expenditures, cash flows, and
               reporting under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act),
               Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), and
               American Rescue Plan (ARP), from March 13, 2020, through September 30, 2021.

               To achieve our audit objective, we interviewed University officials who were responsible
               for drawing down, managing, awarding, spending, and reporting on the University of
               Cincinnati’s HEERF grant funds. We also reviewed the University’s policies, 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 the University used the Student
               Aid and Institutional portions of its HEERF funds for allowable and intended purposes.
               Further, we compared the timing and amounts of drawdowns of HEERF funds with the
               University ’s accounting records (expenditure information) to determine whether the
               University minimized the time between drawdown and disbursement of the funds.
               Lastly, we reviewed the reports that the University posted on its website covering its
               use of HEERF funds for the quarterly periods that ended September 30, 2020, through
               September 30, 2021; and its first annual performance report covering HEERF grant
               activities under the CARES Act from March 13, 2020, through December 31, 2020.

               What We Found
               The University spent $109.9 million (83 percent) of its total HEERF allocation of
               $132.8 million as of September 30, 2021. The University generally used the Student Aid
               ($42.1 million) and Institutional ($67.8 million) portions of its HEERF grant funds for
               allowable and intended purposes but needs to strengthen its review and documentation
               processes for its use of Student Aid grant funds and certain other processes to ensure


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.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                        1
               compliance for its use of Institutional grant funds. We also found that the University did
               not fully comply with cash management and reporting requirements.

               The University needs to strengthen these processes because it

                   •   did not have an effective review process to detect or prevent payment errors
                       for a small number of students who applied for emergency financial aid grants
                       under the CARES Act;
                   •   did not fully document its Student Aid award determinations, eligibility criteria,
                       and related management decisions;

                   •   overstated the amount of lost revenue charged to its Institutional grant by
                       $797,965 (1 percent of total Institutional grant expenditures) due to improper
                       revenue recognition and inclusion of a duplicate charge, and did not fully
                       comply with Uniform Administrative Requirements, Cost Principles, and Audit
                       Requirements for Federal Awards for $1,916,041 (3 percent) of its
                       noncompetitive procurements;

                   •   did not minimize the time between drawing down and disbursing CARES Act
                       Student Aid grant funds, and remitted imputed interest based on $1,450 in
                       estimated earnings rather than remitting the $36,889 in earnings based on the
                       pool of accounts average rate of return allocable to CARES Act Student Aid grant
                       funds’ balances;

                   •   reported $4.1 million of scholarships awarded to students in the wrong
                       expenditure category and did not post all required HEERF quarterly reports on
                       its public website.
               We also determined that the information in the University’s first HEERF annual
               performance report was generally accurate, complete, and timely. After we discussed
               our audit results with University officials, they informed us that they repurposed the
               $797,965 we questioned for other expenditures that were charged to the Institutional
               grant in June 2022. We did not review these expenditures. If the repurposed
               expenditures are allowable and supported, this would be an acceptable remedy to our
               finding. The University also revised its quarterly HEERF Institutional expenditure report
               to properly identify the $4.1 million as scholarships rather than emergency financial aid
               grants to students and posted missing reports to its website.

               What We Recommend
               We provide detailed recommendations addressed to the Assistant Secretary for the
               Office of Postsecondary Education in each finding section in this report.



U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                            2
               In summary, we recommend that the Assistant Secretary for the Office of Postsecondary
               Education—

                   •   Require the University to develop and implement a review process to prevent or
                       detect payment errors when awarding emergency financial aid grants to
                       students, and to develop and implement policies and procedures to ensure that
                       its award determinations, eligibility criteria, and management decisions related
                       to eligibility for its emergency financial aid grants to students are adequately
                       documented and supported at the time award decisions are made.

                   •   Require the University to carefully document how its CRRSAA and ARP student
                       aid eligibility criteria prioritized and continue to prioritize students with
                       exceptional need.

                   •   Review the allowability of the repurposed Institutional expenditures and the
                       reasonableness of the noncompetitive procurements, and if unallowable or
                       inappropriate, require the University to either return to the Department or
                       reallocate for allowable expenditures the unsupported costs charged to the
                       grant of $797,965 in lost revenue and $1,916,041 in noncompetitive
                       procurements.
                   •   Require the University to develop and implement policies and procedures to
                       ensure that (1) calculations for charging lost revenue to its HEERF Institutional
                       grant are reviewed for accuracy and consistency with its financial reporting
                       policies and procedures, (2) procurements charged to the grant comply with
                       Federal and University requirements, and (3) expenditures in its quarterly
                       HEERF Institutional expenditure reports are accurate and reported properly.
                   •   Require the University to incorporate in its policies and procedures certain
                       Federal cash management requirements, and to remit $35,439 in earnings
                       ($36,889 minus the $1,450 in imputed interest) on the advance of the CARES Act
                       Student Aid grant funds.

               University of Cincinnati Comments and Our Response
               We provided a draft of this report to the University for comment. We summarize the
               University’s comments at the end of each finding and provide the full text of the
               comments at the end of the report (see “University of Cincinnati Comments”).

               University Comments
               In its response to our draft report, the University did not state whether it agreed or
               disagreed with the findings, but agreed with all recommendations, except for
               Recommendation 3.2. The University described its specific plans for developing and
               implementing written policies and procedures consistent with applicable program


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                           3
               requirements and other corrective actions as specified by our recommendations. The
               University did not agree with Recommendation 3.2 requiring it to remit $35,439 in
               earnings on the advance of CARES Act Student Aid grant funds. In its response, the
               University stated that the funds were invested in a secure money market fund, which
               was not earning the long-term rate that the $35,439 calculation is based on.

               Office of Inspector General Response
               The University’s proposed corrective actions, if effectively implemented, are generally
               responsive to our recommendations, with the exception of Recommendation 3.2. As
               summarized at the end of the findings, for a few of our recommendations, the
               University either did not specify any corrective actions or proposed corrective actions
               that were only partially responsive to the recommendations. It will be important for the
               University to work with the Department to ensure that all recommendations are
               appropriately and sufficiently resolved and that corrective actions are fully
               implemented.

               We disagree with the University’s statement that the funds were invested in a secure
               money market fund in its response to Recommendation 3.2. We acknowledge that the
               University’s Temporary Investment Pool (TIP) the funds were deposited in included a
               money market fund among many other investment options. However, the University did
               not provide sufficient evidence to demonstrate that the funds were deposited into this
               specific money market fund within the TIP. Instead, the funds were commingled with
               other Federal and non-Federal funds held in the TIP. Therefore, we did not change our
               recommendation.

               We did not make any changes to the findings or recommendations based on the
               University’s comments.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                      4
               Introduction
               On March 13, 2020, the President declared a national emergency due to the
               coronavirus. In response, Congress passed three coronavirus relief acts within a 1-year
               period that included Higher Education Emergency Relief Funds.

                   •   The Coronavirus Aid, Relief, and Economic Security Act (CARES Act), enacted on
                       March 27, 2020 (Public Law 116-136), provided about $14 billion for the Higher
                       Education Emergency Relief Fund (HEERF) program to mitigate the impact of the
                       coronavirus on students and schools.
                   •   The Coronavirus Response and Relief Supplemental Appropriations Act
                       (CRRSAA) was signed into law on December 27, 2020 (Public Law 116-260),
                       authorizing an additional $22.7 billion for the HEERF program.

                   •   The American Rescue Plan (ARP) was signed into law on March 11, 2021 (Public
                       Law 117-2), authorizing $39.6 billion in additional HEERF funding.
               These HEERF funds were to be used to defray expenses associated with the coronavirus,
               carry out student support activities, and provide emergency financial aid grants to
               students.

               Collectively, more than $76 billion was provided for the HEERF program through the
               CARES Act, CRRSAA, and ARP. The U.S. Department of Education’s (Department) Office
               of Postsecondary Education is responsible for administering and overseeing the HEERF
               grants, which were awarded to more than 4,500 schools.

               HEERF Program
               The HEERF program provides direct grants to schools to prevent, prepare for, and
               respond to the coronavirus. 2 The Department divided the primary HEERF funding stream
               between two subprograms—the Student Aid portion under Assistance Listing Number
               (ALN) 84.425E, and the Institutional portion under ALN 84.425F. 3 Schools had to use the




2
 The CARES Act, CRRSAA, and ARP each authorized about 90 percent of the HEERF funds for direct
grants to schools, based on a statutory formula. The remaining funds were for other formula grants to
schools to address needs directly related to coronavirus and for schools that the Department
determined had the greatest unmet needs related to the coronavirus.
3
 The Department also awarded the University of Cincinnati a $928,302 grant from another HEERF
funding stream under the Strengthening Institutions Program (ALN 84.425M), which we did not review.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                         5
               Student Aid portion only for emergency financial aid grants to students and could use
               some or all of the Institutional portion for emergency financial aid grants to students.

               The Student Aid and Institutional portions of HEERF funding 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.

               CARES Act
               For the direct grants, the CARES 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 to students, or to
               cover any costs associated with significant changes to the delivery of instruction due to
               the coronavirus.

               In April 2020, the Department allocated the HEERF funds as two separate grants—
               50 percent of each school’s total authorization for emergency financial aid grants to
               students (Student Aid portion), and 50 percent for institutional costs (Institutional
               portion). In addition to submitting an application, the Department required schools to
               sign separate certification and agreement forms to access their Student Aid and
               Institutional grant funds. The Department also required schools to report publicly on
               their use of HEERF funds by posting the required information on the school’s primary
               website each quarter and to submit their first HEERF annual performance report
               (covering their use of CARES Act funding from March 13, 2020, through December 31,
               2020) to the Department by February 8, 2021.

               CRRSAA and ARP
               CRRSAA and ARP provided supplemental funding for existing private nonprofit and
               public HEERF grantees. 4 Under these acts, Congress expanded the allowable uses of
               grant funds under section 314(a)(1) of CRRSAA and section 2003(1) of ARP for unspent
               HEERF funds. Unlike the CARES Act, CRRSAA and ARP provide that students exclusively


4
 CRRSAA created a separate program for proprietary schools, which continued under ARP, that only
supports emergency financial aid grants to students. The Department generally distributed CRRSAA and
ARP funding as supplements to existing CARES Act grant awards, which did not require the school to
submit another application. Schools that did not receive HEERF funding under the CARES Act were
subject to the application process to receive CRRSAA funding. Schools that did not receive HEERF
funding under the CARES Act or CRRSAA were subject to the application process to receive ARP funding.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                          6
               enrolled in distance education may receive emergency financial aid grants. Further,
               CRRSAA and ARP require schools to prioritize students with exceptional need when
               awarding emergency financial aid grants to students.

               CRRSAA and ARP also expanded the allowable uses of Institutional grant funds to
               include defraying expenses associated with the coronavirus such as lost revenue,
               reimbursement for expenses already incurred, technology costs associated with a
               transition to distance education, faculty and staff trainings, and payroll. The two acts
               also allow schools to use Institutional grant funds to provide student support activities
               authorized by the Higher Education Act of 1965 (HEA) that address needs related to the
               coronavirus. Additionally, section 2003(5) of ARP provides that schools that do not use
               the Institutional portion of their ARP grant funds entirely for emergency financial aid
               grants to students must use a portion of these funds to implement evidence-based
               practices to monitor and suppress the coronavirus according to public health guidelines
               and conduct direct outreach to financial aid applicants about the opportunity to receive
               a financial aid adjustment due to the recent unemployment of a family member or
               independent student, or other circumstances, as described in section 479A of the HEA.

               In January 2021, the Department allocated CRRSAA HEERF funds to schools by
               establishing the minimum amount of funding available for emergency financial aid
               grants to students (Student Aid portion) as the amounts provided by the CARES Act
               HEERF allocation and establishing the maximum amount schools could use for
               institutional costs (Institutional portion) as the remaining amount of the total award. In
               May 2021, the Department allocated ARP HEERF funds to schools in amounts such that
               at least half of a school’s total award was to be used to make emergency financial aid
               grants to students (Student Aid portion) and the remainder could be used for
               institutional purposes (Institutional portion).

               Under CRRSAA and ARP, schools were required to continue reporting publicly on their
               use of HEERF funds by posting the required information on the school’s primary website
               each quarter. Additionally, the Department required schools to submit a second annual
               performance report by May 6, 2022, covering their use of HEERF funds under the CARES
               Act, CRRSAA, and ARP from January 1, 2021, through December 31, 2021. The
               Department will also require schools to submit a third annual performance report
               covering January 1, 2022, through December 31, 2022.

               University of Cincinnati
               The University of Cincinnati (University) is a public research university with its main
               campus located in Cincinnati and satellite campuses located in Blue Ash and Clermont,
               Ohio. The University’s fiscal year 2022 operating budget was $1.6 billion and, as of



U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                            7
               June 30, 2021, its endowment was $1.8 billion. The University has 14 colleges and offers
               more than 400 degree programs in a variety of disciplines, including medicine, nursing,
               business, engineering, and law. About 48,000 students are enrolled at the University,
               including students from all 50 States and more than 100 countries (international
               students). About 85 percent of students are enrolled in on-campus classes and the other
               15 percent are enrolled in online classes (distance education).

               Various Federal agencies have awarded education and research grants and contracts to
               the University in recent years. According to the University’s single audit report covering
               fiscal year 2021, the University expended more than $538 million in Federal funding
               from a variety of agencies including the Departments of Education, Defense, and Health
               and Human Services, National Science Foundation, and National Institutes of Health.

               The Department awarded the University of Cincinnati a total of $132.8 million in HEERF
               funds (including $58.9 million for its Student Aid portion and $73.9 million for its
               Institutional portion) under the CARES Act and as supplemental funds under CRRSAA
               and ARP, as shown in Table 1 on the next page. The Department allowed the University
               1 year to spend its CARES Act HEERF funding and, after CRRSAA and ARP were enacted,
               extended the grant period by an additional 2 years. On April 4, 2022, the Department
               automatically extended the grant period for all HEERF funds to June 30, 2023. 5
               According to University officials, the University plans to spend all of its HEERF funding by
               the end of June 2023. The University expended $109.9 million (83 percent) of its total
               HEERF funds as of September 30, 2021, which includes all of its CARES Act
               ($23.5 million) and CRRSAA ($39.3 million) HEERF funds and $47.1 million of its ARP
               HEERF funds.

               Table 1. University of Cincinnati’s HEERF Funding
                                                                         Student Aid        Institutional
                Funding Source      Award Date         Total Award         Portion            Portion
                                                                        (ALN 84.425E)      (ALN 84.425F)

                                      April 2020
                                     Student Aid
                   CARES Act                          $23.52 million     $11.76 million     $11.76 million
                                      May 2020
                                     Institutional

                    CRRSAA          February 2021      $39.29 million    $11.76 million     $27.53 million




5
 Schools are allowed to request a one-time extension of up to 1 year to spend HEERF funding, which
would extend the performance period for their HEERF grants through June 30, 2024.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                             8
                                                                               Student Aid         Institutional
                   Funding Source       Award Date         Total Award           Portion             Portion
                                                                              (ALN 84.425E)       (ALN 84.425F)

                         ARP              May 2021         $70.00 million      $35.42 million     $34.58 million

                         Total                –           $132.81 million      $58.94 million     $73.87 million
                  Source: Office of Inspector General (OIG) summary of the Department’s allocation tables and the
                  University of Cincinnati’s Grant Award Notification documents.


                  Impact of Coronavirus
                  On March 13, 2020, the University of Cincinnati announced that most on-campus classes
                  and operations would be curtailed or shut down for the remainder of the spring 2020
                  school term. According to University officials, the University’s robust distance education
                  capabilities enabled it to quickly transition on-campus classes to online instruction with
                  the existing faculty and staff. Students living in University housing were asked to return
                  home and by the end of March 2020, the University had closed its student housing and
                  dining facilities. 6 Essential campus operations, such as the library and administrative
                  offices, remained open. However, faculty and staff were given the option of working
                  remotely from home whenever possible to help mitigate the spread of the coronavirus.

                  Most campus activities began to return to normal by the fall 2020 school term when the
                  dorms reopened. However, many students did not return to on-campus housing until
                  August 2021 for the start of the new academic year. While the University’s revenue and
                  enrollment had been growing for several years prior to the coronavirus, the University
                  experienced declining revenue following the onset of the coronavirus—primarily due to
                  limiting on-campus activities, which impacted housing, dining, and parking revenues, as
                  discussed in Finding 2. However, at the time of our audit, University officials stated their
                  belief that the negative impacts on revenue are subsiding and they did not expect
                  longer-term impacts.

                  After the declaration of a national emergency, the University’s online enrollment
                  increased slightly while on-campus enrollment remained relatively stable with normal
                  term-to-term fluctuations and within-term decreases through the fall 2021 term, as
                  shown in Figure 1. According to University officials, enrollments are returning to the
                  growth trend experienced before the coronavirus with more than 48,300 students




6
    The University assisted students who could not return home to find alternative housing arrangements.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                                   9
                  projected to enroll in the fall 2022 term, a 3-percent increase over the previous year’s
                  enrollment and the University's highest enrollment ever. 7

                  Figure 1. University of Cincinnati Student Enrollment by School Term, Spring 2019
                  through Fall 2021




                  Source: University of Cincinnati’s Office of the Bursar.




7
    Enrollment increased almost 9 percent from 42,656 students in 2013 to 46,388 students in 2019.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                             10
               Finding 1. University of Cincinnati Generally
                 Used Student Aid Grant Funds for Allowable
                 and Intended Purposes but Needs to
                 Strengthen its Review and Documentation
                 Processes
               As of September 30, 2021, the University of Cincinnati had awarded 56,079 emergency
               financial aid grants to 33,924 students, totaling $42.1 million (71 percent) of the
               $58.9 million in Student Aid grant funds awarded to the University under the CARES Act,
               CRRSAA, and ARP. We reviewed 155 CARES Act, CRRSAA, and ARP emergency financial
               aid awards and identified a small percentage of CARES Act awards that were made to
               ineligible students under Federal eligibility requirements existing at that time, but who
               would have been eligible for the awards under CRRSAA and ARP due to changes in the
               eligibility requirements. Because subsequent changes in Federal eligibility requirements
               largely mitigated the effects of these CARES Act payment errors, we concluded that the
               University generally used its Student Aid grant funds to award emergency financial aid
               grants to students in accordance with applicable Federal requirements. However, as
               discussed later in this finding, the University did not have an effective review process to
               detect or prevent CARES Act application payment errors or fully document its student
               aid award determinations, eligibility criteria, and related management decisions.

               Award Process and Distribution Method
               The University of Cincinnati used two processes—an automated process and an
               application process—to award 56,079 emergency financial aid grants to students
               (totaling $42.1 million) under the CARES Act, CRRSAA, and ARP through September 30,
               2021. The awards and distributions were processed through the University’s student
               information system, as illustrated in Figure 2.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                       11
                 Figure 2. University of Cincinnati’s Process for Awarding and Distributing Student Aid
                 Grant Awards to Students




                 Source: OIG-created graphic.


                 Automated Process
                 The University automatically awarded 51,831 or 92 percent of 56,079 emergency
                 financial aid grants to students (totaling $38.7 million), in amounts ranging from $250 to
                 $2,000 per term, which did not require students to take any action or complete an
                 application. 8 Under the automated process, the University developed computer queries
                 of student enrollment and financial data contained in its student information system.
                 These queries identified the students who met the eligibility criteria, such as Title IV of
                 the Higher Education Act of 1965 (Title IV) eligibility, enrollment status, and Expected
                 Family Contribution (EFC), in effect on the dates of the query. 9



8
 The University set CARES Act Student Aid grant awards amounts low to assist as many students as
possible. The University increased award amounts for the CRRSAA and ARP in response to the increased
Student Aid funding provided by these acts coupled with fewer students being eligible for awards under
the requirement to prioritize students with exceptional need.
9
  Title IV eligibility criteria include but are not limited to U.S. citizenship or eligible noncitizen; a valid
Social Security Number; and a high school diploma or equivalent. Students who filed a Free Application
for Federal Student Aid (FAFSA), which includes information for determining a student’s Title IV
eligibility, also received an EFC. This number is used to determine the type and amount of financial aid a
student is eligible to receive. Under Title IV, Federal student aid programs can be either based on
financial need (Pell grant, Federal Work Study, direct subsidized loans) or not based on financial need
(direct unsubsidized loans, direct PLUS loans).


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                             12
               Application Process
               The University awarded 4,248 or 8 percent of the 56,079 emergency financial aid grants
               to students (totaling $3.4 million) through an application process. A portion of Student
               Aid grant funds were set aside to provide an opportunity for students to apply for
               emergency financial aid grants of up to $1,000 per term when they either were
               financially impacted by the coronavirus but did not receive an emergency financial aid
               grant under the automated process or received an automated award but needed
               additional financial support. Students completed the application online through the
               student information system.

               Award Distribution Method
               The University distributed HEERF funds to students for the CARES Act and CRRSAA
               emergency financial aid grant awards by crediting the student’s account in the student
               information system. These HEERF credits were cleared by either a direct deposit into the
               student’s linked bank account or issuance of a paper check. For the ARP awards, the
               University gave students the option to use their emergency financial aid grant funds to
               reduce their outstanding University debt. Students had 21 days to exercise this option
               through the student information system and, if they did not exercise this option, would
               automatically receive cash payments as described above.

               Eligibility Criteria and Award Amounts
               The University of Cincinnati awarded emergency financial aid grants to students using
               eligibility criteria and award amounts that varied from term to term based on changing
               Federal requirements and University policy, as summarized in Table 2.

               Table 2. University of Cincinnati’s Student Eligibility Criteria and Award Amounts by
               Funding Source, Award Process, and School Term through September 30, 2021
   Funding Source,                        Distance      Additional
   Award Process,                                                     Exceptional Need    Student Aid
                     Title IV-Eligible   Education      University                       Award Amount
     and School                                                           Criteria
                                          Student        Criteria
      Term(s)

      CARES Act                                                                             $250 plus
                                                        Enrolled at                        $250 if EFC is
      Automated
                         Required        Not eligible    least half     Not applicable    $10,000 or less
      Spring 2020                                          time                               ($500
     Summer 2020                                                                            maximum)

      CARES Act                                         Enrolled at                       $275 if enrolled
                                                         least half                          full time;
      Automated          Required        Not eligible                   Not applicable
                                                         time and                         $200 if enrolled
       Fall 2020                                          EFC = $0                           part time




U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                       13
     Funding Source,                        Distance      Additional
     Award Process,                                                      Exceptional Need          Student Aid
                       Title IV-Eligible   Education      University                              Award Amount
       and School                                                            Criteria
                                            Student        Criteria
        Term(s)

        CARES Act
       Application                                                                                  Up to $500
                           Required        Not eligible    Enrolled        Not applicable
       Spring 2020                                                                                  maximum
      Summer 2020

                                                                                                   $1,000 if Pell
         CRRSAA                                                          Federal Pell Grant 10    recipient; $750
                                                          Enrolled at
                                                                        (Pell) recipient or not      if not Pell
       Automated           Required          Eligible      least half
                                                                          Pell recipient with      recipient and
       Spring 2021                                           time
                                                                        EFC = $12,000 or less     EFC is $12,000
                                                                                                       or less

         CRRSAA                                           Enrolled at
       Automated           Required          Eligible      least half      Title IV-eligible          $2,000
         Fall 2021                                           time


         CRRSAA
                                                          Enrolled at
       Application                                                                                  Up to $500
                           Required          Eligible      least half      Not applicable
       Spring 2021                                                                                  maximum
                                                             time
      Summer 2021

           ARP                                                                                    $2,000 if debt is
                                                                                                  $2,000–$4,300;
       Automated                                                            Student has
                         Not required        Eligible      Enrolled                                up to $2,000 if
       Spring 2021                                                         University debt
                                                                                                  debt is less than
      Summer 2021                                                                                      $2,000

                                                                        EFC is $1,400 or less
           ARP                                                           for undergraduate
                                                          Enrolled at         students;
       Automated         Not required        Eligible      least half                                 $2,000
                                                             time           EFC is $0 for
         Fall 2021                                                       graduate, medical,
                                                                          and law students




10
  The Federal Pell Grant Program provides need-based grants to low-income undergraduate and certain
postbaccalaureate students to promote access to postsecondary education.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                               14
     Funding Source,                        Distance     Additional
     Award Process,                                                       Exceptional Need      Student Aid
                       Title IV-Eligible   Education     University                            Award Amount
       and School                                                             Criteria
                                            Student       Criteria
        Term(s)

           ARP
       Application                                                                               Up to $1,000
       Spring 2021       Not required       Eligible      Enrolled          Not applicable        maximum
      Summer 2021                                                                                 each term
        Fall 2021
                 Source: University of Cincinnati’s Enrollment Management Unit.

                 University of Cincinnati Generally Made Student Aid Awards to
                 Eligible Students for the Correct Amount Under the CARES Act,
                 CRRSAA, and ARP
                 We reviewed enrollment and financial records in the University’s student system for
                 155 CARES Act, CRRSAA, and ARP automated and application awards and determined
                 that, except for CARES Act application awards as discussed below, the awards were
                 generally made to eligible students for the correct amounts. As of December 31, 2020,
                 the University had distributed $11,136,325 in CARES Act Student Aid grant funds
                 through 30,273 automated awards to students. We reviewed 30 CARES Act automated
                 awards (totaling $9,525) and identified 3 payment errors (totaling $1,075). Two awards
                 of $500 each ($1,000 total) were made to a student who was ineligible due to being
                 enrolled in a distance learning program and one award was an underpayment of
                 $75 made to a full-time student. 11 While University officials could not identify a specific
                 cause for these payment errors, our review indicated they were isolated instances that
                 were not the result of systemic processing issues. Based on our review results, we
                 concluded that CARES Act automated awards were generally made to eligible students
                 for the correct amount.

                 As of September 30, 2021, the University distributed 13,390 CRRSAA awards
                 (totaling $11,683,656) and another 11,160 ARP awards (totaling $18,627,169) to
                 students. Our review of 92 CRRSAA and ARP automated and application awards



11
   The University created a CARES Act payment file listing all 30,273 automated awards that contained
specific data elements to support the automated awards were made in compliance with eligibility
requirements in the awarding term. Because our review of the entire payment file identified only two
awards with data elements indicating they were improperly made to a student enrolled in a distance
learning program, we concluded that the payment errors were not caused by a systemic processing
issue.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                           15
               identified only one application payment error of $500 that was made to a student who
               was ineligible because they were not enrolled in the term the award was made. Because
               our review did not identify any other payment errors or systemic processing issues, we
               concluded that CRRSAA and ARP awards were also generally made to eligible students
               for the correct amount.

               The University’s policy was to distribute emergency financial aid grants to these
               students as determined by eligibility data in the student information system and, for
               application awards, information that students provided on their applications requesting
               emergency financial aid grant funds. The application asked students to indicate if they
               had completed a Free Application for Federal Student Aid (FAFSA) form for the current
               and upcoming school terms; provide information related to establishing Title IV
               eligibility, such as citizenship and social security number; identify the specific financial
               impacts—such as housing, food, health care, and technology—in which the student
               experienced unusual expenses due to coronavirus; and request the amount of
               emergency funds needed. In addition to Title IV eligibility, the University considered
               students’ enrollment status and EFC when determining students’ eligibility and award
               amounts for the automated awards.

               Department guidance stated that students who were enrolled exclusively in a distance
               learning (online) program on March 13, 2020, were not eligible for CARES Act
               emergency financial aid grants. Further, in June 2020, 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). However, the Department rescinded
               this requirement in May 2021, so students no longer had to be Title IV-eligible to receive
               an emergency financial aid grant.

               Under CRRSAA and ARP, schools could award emergency financial aid grants to students
               exclusively enrolled in distance education (distance learners) and were required to
               prioritize students with exceptional need. Department guidance provided examples of
               conditions indicating exceptional need such as Pell Grant recipients or undergraduates
               with extraordinary financial circumstances. Further, the guidance stated that beyond
               Pell eligibility, other types of exceptional need could include students eligible for Federal
               or State need-based aid or faced significant unexpected expenses, such as loss of
               employment (either for themselves or their families), reduced income, or food or
               housing insecurity. The Department required schools to carefully document their
               Student Aid grant eligibility criteria.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                         16
               University of Cincinnati Did Not Have an Effective Review
               Process for the CARES Act Application Awards
               The University’s review process for CARES Act application awards was not effective at
               preventing or detecting certain types of payment errors. Our review of 33 (totaling
               $15,831) of the 1,256 CARES Act application awards (totaling $627,331) identified
               payment errors for 23 awards (totaling $11,250), of which 20 awards ($10,000) did not
               meet Federal requirements regarding student eligibility in effect at the time of the
               award, and 3 awards ($1,250) did not meet the University’s policy for award amounts. 12
               Of the 20 awards made to ineligible students based on Federal eligibility requirements,
               10 awards went to students who were not Title IV-eligible, 6 awards went to distance
               learners, and 4 awards went to students who were not enrolled in the awarding school
               term (summer 2020). 13 The remaining three awards went to students who met Federal
               eligibility requirements but received multiple awards that exceeded the University’s
               policy limiting the application award to a cumulative maximum of $500. It is important
               to note that some Federal eligibility requirements changed under CRRSAA and ARP that,
               unlike the requirements under the CARES Act, allowed awards to distance learning
               students and non-Title IV eligible students. 14

               Uniform Guidance at 2 C.F.R. section 200.303 requires schools to establish and maintain
               effective internal control that provides reasonable assurance that Federal awards are
               managed in compliance with Federal statues, regulations, and grant terms and
               conditions. Written policies and procedures facilitate management review and support
               quality assurance by clearly defining the roles and responsibilities to maintain
               compliance with program requirements and requiring adequate documentation of grant
               administration activities.

               University officials stated that staff reviewed student applications to ensure they were
               complete and indicated a need for financial assistance and reviewed the student



12
   The 1,256 CARES Act application awards comprised 4 percent of the 31,529 awards (both application
and automated) distributed under the CARES Act and 2 percent of the 56,079 awards distributed under
all 3 laws.
13
  The four students who were not enrolled during the summer 2020 school term received CARES Act
automated awards during the spring 2020 term when they were enrolled at the University.
14
  Under CRRSAA and ARP, schools could provide emergency financial aid grants to students who were
exclusively enrolled in distance education (distance learners). Furthermore, on May 14, 2021, the
Department clarified in 86 FR 26608 that student eligibility was not limited to students who were or
could be Title IV-eligible.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                       17
                information system to ensure the student met Federal and University criteria to receive
                an emergency financial aid grant under the CARES Act. 15 However, we could not verify
                the review activities due to a lack of documentation, as discussed later in this finding.
                The officials also stated that the University had not developed written policies and
                procedures detailing how such reviews should be conducted or the results documented.
                Further, the officials said they did not design or implement controls, such as
                management reviews, to prevent or detect payment errors after award decisions were
                made. Awarding emergency financial aid grants to ineligible students or in amounts that
                exceed University policy reduces the amount of Student Aid funding available for other
                students seeking emergency assistance.

                University of Cincinnati Did Not Fully Document Certain
                Student Aid Award Determinations, Eligibility Criteria, and
                Related Management Decisions
                The University did not provide complete and accurate student eligibility and financial
                data to support 3,297 (totaling $3.4 million), or 6 percent, of its award determinations
                under the CARES Act, CRRSAA, and ARP. In addition, we found that the University lacked
                complete documentation to support its Student Aid awards eligibility criteria and
                management decisions related to changes in student eligibility. As part of our audit, we
                requested the University to provide documentation and explanations for its award
                determinations, eligibility criteria, and management decisions related to compliance
                with applicable Federal requirements and University policies.

                To support the University’s award determinations, the University created electronic
                spreadsheets several months after the awards were distributed that listed the students
                who received emergency financial aid grants along with student enrollment and
                financial information extracted from the University’s student information system. These
                spreadsheets were intended to support that the awards were made to eligible students
                for the correct amount. However, we identified 3,297 awards on the spreadsheets that
                had missing or inaccurate student information (data quality issues) that made
                compliance with eligibility criteria unclear. For example, we identified data quality issues
                for most of the 1,256 awards listed on the spreadsheet documenting the application
                awards made under the CARES Act, including issues related to students’ enrollment
                status (563 awards), enrollment in distance education programs (419 awards), and




15
   University officials also stated that the staff assigned to review students’ applications for emergency
financial aid grants under the CARES Act was not assigned to review applications under CRRSAA and
ARP.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                         18
                Title IV eligibility (268 awards). While University officials attempted to correct the data
                quality issues we identified on the spreadsheets, their efforts were not successful. 16

                University officials stated that they used the student enrollment and financial data that
                were in the student information system (for automated and application awards) and, for
                application awards, the student’s application on the dates that awards were processed
                to make the award decisions but did not document the student information that they
                used to make these determinations at the time the awards were made. Moreover, they
                did not generate or keep documentation of the computer queries of the student
                information system that were used under the automated process or record the results
                of their manual reviews under the application process.

                University officials stated that they could not generate complete and accurate electronic
                spreadsheets after award decisions were made because the student information system
                did not maintain a complete historical record of student enrollment and financial
                information and that the University did not have a separate data warehouse that
                preserved historical data. The officials further stated that student information that was
                used to determine eligibility for emergency financial aid grants in one school term can
                change as students’ circumstances change over time. For example, the University relied
                on students’ enrollment status to ensure only students who were enrolled at least half-
                time received automated awards for the applicable school terms. However, enrollment
                information is dynamic and can change as students add or drop classes, whereby
                students could appear eligible on the day awards were processed but later appear
                ineligible due to changes in enrollment status.

                The University also lacked complete documentation to support its management
                decisions related to the numerous changes in student eligibility requirements. Unlike
                the CARES Act, CRRSAA and ARP require schools to prioritize students with exceptional
                need. The Department requires schools to carefully document how they prioritize
                students with exceptional need in distributing financial aid grants to students. The
                University used criteria to prioritize students with exceptional need that varied from
                term to term for CRRSAA and ARP automated awards. While the University posted a
                general description of the student aid eligibility requirements for each term on its public
                website, it did not create any additional documentation supporting why it changed its
                criteria each term or how revising the criteria each term continued to prioritize students
                with exceptional need. For application awards, students indicated their exceptional



16
  We also reviewed awards that we identified as having data quality issues on the University’s electronic
spreadsheets for automated awards made under the CARES Act and automated and application awards
made under CRRSAA and ARP, as described in Appendix A (Sampling Methodology).


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                          19
               need through completing an online application that included identifying the specific
               financial impact related to the coronavirus.

               The University’s CRRSAA and ARP automated award eligibility criteria were changed
               each term. For CRRSAA automated awards in the spring 2021 term, the University
               awarded emergency financial aid grants to students who either received a Pell grant or
               had an EFC of $12,000 or less if they were not Pell recipients. Similarly, for ARP
               automated awards in the fall 2021, the University made awards to students with EFCs of
               $1,400 or less, and graduate, medical and law students with EFCs of zero. In
               comparison, for CRRSAA automated awards in the fall 2021 term, the University
               awarded emergency financial aid grants to Title IV-eligible students. Then, for ARP
               automated awards in the spring and summer 2021 terms, the University made awards
               based on students’ outstanding debt owed to the University.

               The University established an executive coronavirus committee tasked with overseeing
               its use of HEERF grant funds that included establishing the eligibility criteria for
               awarding automated and application emergency financial aid grants to students each
               term. While this policy setting committee met periodically, it did not create a record of
               meeting discussions or policy decisions. As a result, the University did not provide
               documentation on how the criteria used each term prioritized students with exceptional
               need or how changing the criteria each term continued to achieve that purpose.
               Because Department guidance and applicable regulations provide schools discretion to
               determine who should receive Student Aid funds based on their own circumstances, we
               did not assess whether other eligibility requirements would have more effectively
               prioritized students with exceptional need.

               As stated in the finding above, Uniform Guidance at 2 C.F.R. section 200.303 requires
               schools to establish and maintain effective internal control, and written policies and
               procedures are a necessary component of effective internal controls. Furthermore,
               Uniform Guidance at 2 C.F.R. section 200.302(b)(3) and (4) requires schools receiving
               Federal grant funds, including HEERF, to maintain source documentation that supports
               federally funded expenditures and to have effective controls over Federal funds to
               assure they are used solely for authorized purposes. The Department’s HEERF guidance
               further 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. section 200.334).” The
               University is responsible for preparing and maintaining documentation that supports its
               responses to grant reporting requirements as well as compliance with program
               requirements.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                      20
               Without accurate and complete supporting documentation, the University’s existing
               processes provide limited assurance that funding decisions for awarding emergency
               financial aid grants to students complied with applicable Federal requirements. The
               University should carefully document its award determinations, eligibility criteria, and
               management decisions, including maintaining a record of the key information it relied
               on to qualify students for automated and application awards. It is also important that
               such information be available for management to review to ensure emergency financial
               aid grants are made to eligible students for the correct amount.

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

               1.1     Require the University of Cincinnati to develop and implement a review process
                       to prevent or detect payment errors when awarding emergency financial aid
                       grants to students, including written policies and procedures detailing how the
                       reviews shall be conducted and the results documented, in accordance with
                       2 C.F.R. section 200.303.
               1.2     Require the University of Cincinnati to develop and implement written policies,
                       procedures, and management review to ensure that its award determinations,
                       eligibility criteria, and management decisions related to eligibility for its
                       emergency financial aid grants to students are adequately documented and
                       supported at the time award decisions are made, in accordance with 2 C.F.R.
                       section 200.302(b)(3).
               1.3     Require the University of Cincinnati to carefully document how its student aid
                       eligibility criteria prioritized and continues to prioritize students with
                       exceptional need throughout the HEERF grant performance period.

               University of Cincinnati Comments
               The University did not state whether it agreed or disagreed with the finding, but agreed
               with the recommendations. The University’s proposed corrective actions included the
               development and implementation of a review process to prevent or detect payment
               errors and written policies, procedures, and management reviews consistent with the
               grant award administration requirements specified in Recommendation 1.1 and
               Recommendation 1.2. The University also stated that when awarding future emergency
               financial aid grants to students, it will document how its student aid eligibility criteria
               prioritizes students with exceptional need.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                        21
               OIG Response
               The University’s proposed corrective actions, if effectively implemented, are generally
               responsive to our recommendations. However, the University’s corrective actions
               should also include steps to document how its past student aid eligibility criteria
               prioritized students with exceptional need.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                         22
               Finding 2. University of Cincinnati Generally
                 Used Institutional Grant Funds for Allowable
                 and Intended Purposes but Needs to
                 Strengthen Certain Processes to Ensure
                 Compliance with Grant Requirements
               As of September 30, 2021, the University of Cincinnati had spent $67.8 million
               (92 percent) of the $73.9 million in HEERF Institutional grant funds awarded to the
               University, including all of its CARES Act and CRRSAA and 83 percent of its ARP
               Institutional funding. The University generally used its Institutional grant funds in
               accordance with applicable Federal requirements. However, as discussed later in this
               finding, we found that the University overestimated the amount of lost revenue charged
               to its HEERF Institutional grant by $797,965 and did not fully comply with Uniform
               Guidance for its noncompetitive procurements.

               After discussing our audit results with University officials, they informed us that the
               University repurposed the $797,965 we questioned to reimburse itself for other
               expenditures it deemed as allowable uses of Institutional grant funds.

               How University of Cincinnati Used Institutional Grant Funds
               Under the CARES Act, Congress intended for schools to use HEERF Institutional grant
               funds to cover any costs associated with significant changes to the delivery of
               instruction due to coronavirus. CRRSAA and ARP expanded the allowable uses of HEERF
               Institutional grant funds to include defraying expenses associated with coronavirus, such
               as lost revenue, reimbursement for expenses already incurred, and payroll. In deciding
               how to use the HEERF Institutional grant funds, University officials stated that they
               reviewed expenditures already incurred to keep the school operating when its
               campuses closed on March 23, 2020, reopened in August 2020 with hybrid instruction,
               and continued to operate during the coronavirus pandemic. They also reviewed
               Department guidance to help in their decision-making on what expenditures might be
               allowable for reimbursement under the grant.

               Of the $67.8 million spent as of September 30, 2021, the University reported using
               $45.4 million (67 percent) to replace lost revenue and $22.4 million (33 percent) for
               student refunds and scholarships, expenses related to managing the University’s
               coronavirus response, and salaries and benefits, as shown in Table 3 on the next page.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                         23
               Table 3. University of Cincinnati’s Institutional Grant Expenditures through
               September 30, 2021

                             Category of Expenditure                          Amount             Percent of Total


                Lost revenue from academic and auxiliary-services
                sources, including academic program fees, student
                                                                            $45,423,455                 67%
                housing, food services, parking, and other campus
                services fees

                Refunds of housing, campus life and general fees
                issued in the form of a student account credit to
                40,435 students who had to leave campus when                $11,083,224                 16%
                dormitories were closed, and classes moved to
                remote instruction

                Operational costs associated with response to
                coronavirus (testing, contact tracing, safety                $6,241,868                  9%
                measures, telework costs, canceled study-abroad)

                Scholarships in the form of student account credit
                covering their non-resident surcharge fees and
                                                                             $4,094,545                  6%
                cooperative education fees for 911 students for
                coronavirus-related attendance disruptions

                Salaries and benefits for 226 employees (faculty,
                staff, and students) performing functions
                supporting the University's response to the                   $992,942                   2%
                coronavirus, such as coronavirus testing and
                contact tracing

                                        Total                               $67,836,034                100%
               Source: OIG analysis of the University of Cincinnati’s quarterly HEERF Institutional expenditure
               reports posted on the University’s website through September 30, 2021, and Institutional
               expenditures detail reports provided by the University.


               Required Uses of ARP Institutional Grant Funds
               The University of Cincinnati used $400,277 of its ARP Institutional grant funds to
               purchase and offer masks, coronavirus testing, and a contact tracing app, and for
               services to implement evidence-based practices to monitor and suppress coronavirus in




U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                                  24
                accordance with public health guidelines, as required by ARP. 17 As of September 30,
                2021, the University had not yet used ARP Institutional grant funds to conduct direct
                outreach to financial aid applicants about the opportunity to receive a financial aid
                adjustment due to special financial circumstances, which ARP also required. A University
                official stated that the University later used its ARP Institutional grant funds for this
                purpose when it mailed outreach postcards to students in November 2021.

                University of Cincinnati Charged Unsupported Lost Revenue
                Costs to its HEERF Institutional Grant
                The University of Cincinnati overestimated the amount of lost revenue charged to its
                HEERF Institutional grant by $797,965 (2 percent). This amount consisted of $519,804 in
                faculty and staff parking revenue that was not recognized and recorded in the
                appropriate period and $278,161 in duplicate charges for parking refunds that the
                University had previously charged to another Federal grant—the U.S. Department of
                Treasury’s Coronavirus Relief Fund (CRF). We determined that the University’s lost
                revenue calculation was overestimated by $797,965 because the University did not have
                adequate internal control procedures in place to review and approve the lost revenue
                data used in the calculation to ensure it was accurate and supported by appropriate
                source documentation.

                The University of Cincinnati calculated $43.7 million, or 96 percent of the $45.4 million
                in lost revenue charged to HEERF (as shown in Table 3), as a variance between revenue
                from academic and auxiliary-services sources for the 9 months that ended March 31,
                2020, and the 9 months that ended March 31, 2021. 18 To calculate the variance, the
                University identified cost centers 19 within its general ledger accounting records that
                experienced losses as a result of coronavirus. When the University used this period-
                over-period method to calculate $6.9 million in lost revenue from faculty, staff, and



17
  These expenditures were included in the expenditure category for Operational Costs Associated with
Response to Coronavirus ($6.2 million), as shown in Table 3. The $6.2 million included $4.2 million in
Campus Safety costs, which included the $400,277 to implement evidence-based practices to monitor
and suppress coronavirus and was reimbursed with ARP Institutional grant funds.
18
  The University calculated the remaining 4 percent ($1.7 million) in lost revenue as an estimate of
waived faculty and staff parking fees for the period March 25, 2020, through November 30, 2020, when
the University operated remotely ($1.6 million), and revenues that were eliminated when the College-
Conservatory of Music cancelled art lessons and performances due to coronavirus ($142,000).
19
  The University defines a cost center as a financial activity segregated based on the type of operation
at the University. Several cost centers often pertained to one revenue general ledger account.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                        25
               student parking fees, it overstated lost revenue by $797,965 due to the improper
               revenue recognition and duplicate charges.

               The University did not have procedures in place to ensure that its calculation of lost
               revenue was consistent with its revenue recognition policies for all of the revenue
               sources included in the calculation. The University relied on the revenue balances as
               generated from its accounting records but did not review the underlying accounting
               data to ensure revenue was properly recognized and did not include duplicate lost
               revenue charges. Consistent with the cost principles of the Uniform Guidance (2 C.F.R.
               part 200 subpart E), the Department’s lost revenue guidance requires that the
               calculation of lost revenue must be accorded consistent treatment and be consistent
               with policies and procedures that apply uniformly to federally financed and other
               activities of the institution. 20

               Uniform Guidance at 2 C.F.R. section 200.303 further requires schools to establish and
               maintain effective internal control that provides reasonable assurance that Federal
               awards are managed in compliance with Federal statues, regulations, and grant terms
               and conditions. The University of Cincinnati did not establish adequate internal control
               procedures, such as transaction and activity review and approval requirements, for
               charging lost revenue to the grant that would identify and prevent underlying data
               issues and duplicate charges.

               As a result, the University of Cincinnati improperly used $797,965 of its HEERF
               Institutional grant funds to reimburse itself for lost revenue that was not supported by
               its accounting records. Proper management reviews and documentation supporting
               charges to Federal grants help to protect taxpayer dollars; minimize the risk of fraud,
               waste, and abuse; and ensure Federal funds are used for allowable and intended
               purposes.

               University of Cincinnati Repurposed Questioned Costs
               After we discussed our audit results with University officials, they informed us that in
               June 2022 they repurposed the $797,965 that we questioned in this finding. University
               officials stated that they did not return the funds to the Department because the
               University’s HEERF Institutional grant expenditures for June 2022 exceeded the amount
               that we questioned. Instead, the University reduced its June 2022 drawdown by
               $797,965 to use this amount to reimburse itself for that month’s Institutional



20
  Question 9 in “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 ARP.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                      26
                  expenditures that were charged to the HEERF grant. We did not review the repurposed
                  expenditures because this activity occurred outside our audit period.

                  University of Cincinnati Did Not Fully Comply with Uniform
                  Guidance for Its Noncompetitive Procurements
                  Of the $6.2 million in expenditures that the University of Cincinnati incurred for
                  operational costs associated with its response to the coronavirus (as shown in Table 3),
                  it did not provide adequate documentation supporting a noncompetitive procurement
                  process for Institutional grant purchases of $1,916,041 involving 11 vendors (as shown
                  in Table 4) each exceeding the University’s micro-purchase threshold of $15,000. 21
                  Uniform Guidance general procurement standards require a competitive process for
                  such purchases, unless specific circumstances apply and the school has sufficient
                  records to support its rationale for the noncompetitive method of procurement. The
                  University did not maintain adequate documentation to support its rationale for these
                  noncompetitive procurements. Moreover, the University did not document its
                  determination of the reasonableness of these costs and did not perform price analyses
                  for purchases from 3 of the 11 vendors that exceeded the simplified acquisition
                  threshold (SAT) of $250,000, which is also required by Uniform Guidance. 22

                  Table 4. University of Cincinnati’s Unsupported Noncompetitive Procurements

                                                     Number of                          Percent of Total
                      Expenditure Description                           Amount              Amount
                                                      Vendors

                        Coronavirus Testing 23            3             $1,645,364            86%

                    Personal Protective Equipment         3              146,860               8%



21
  In a letter dated October 18, 2019, the U.S. Department of Health and Human Services approved the
University’s micro-purchase threshold of $15,000 for goods and $30,000 for professional,
noncompetitive services. Uniform Guidance at 2 C.F.R. section 200.320 defines “micro-purchase
threshold” as the dollar amount at or below which a non-Federal entity may purchase property or
services using micro-purchase procedures, including noncompetitive procurement.
22
  Uniform Guidance at 2 C.F.R. section 200.320 defines SAT as the dollar amount below which a non-
Federal entity may purchase property or services using small purchase methods where price or rate
quotations must be obtained from an adequate number of qualified sources as determined appropriate
by the school. Purchases below SAT do not require formal procurement methods such as sealed bids or
proposals.
23
     Purchases from each of the three coronavirus testing vendors also exceeded the SAT of $250,000.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                           27
                                                      Number of                             Percent of Total
                   Expenditure Description                                  Amount              Amount
                                                       Vendors

                            Software                        2                 99,380               5%

                              Other                         3                 24,437               1%

                              Total                        11              $1,916,041            100%
               Source: OIG’s analysis of the University of Cincinnati’s expenditure data.

               Uniform Guidance sets procurement standards and cost principles for Federal awards,
               including the following requirements:

                   •    2 C.F.R. section 200.318(i) requires the University to maintain sufficient records
                        to detail the history of procurement, including the rationale for the method of
                        procurement and the basis for the contract price.
                   •    2 C.F.R. sections 200.403 and 200.404 provide that costs must be adequately
                        documented and determined reasonable.

                   •    2 C.F.R. section 200.324 requires cost or price analysis in connection with every
                        procurement action in excess of the SAT.
               Uniform Guidance also defines specific circumstances in which noncompetitive
               procurement can be used, such as when the item is available from a single source, the
               public exigency will not permit delay resulting from a competitive process, or under
               express authorization by the Federal awarding agency. The University’s written
               procurement policies require bid-waiver letters or letters of justification to document
               circumstances for noncompetitive procurements. According to University policy, such
               waiver requests must be in writing, submitted to the appropriate Central Purchasing
               buyer, and approved. However, for 10 of the 11 vendors with noncompetitive
               procurements totaling $1,915,036, either the University did not prepare bid-waiver
               letters ($1,665,075 of expenditures) or the letters were missing approval by Central
               Purchasing ($249,961 of expenditures). The University did not document its justification
               for using the alternative procedures. Moreover, the University did not document the
               reasonableness of the contracted prices or rates and did not perform price analyses for
               purchases from the three vendors that exceeded the SAT of $250,000.

               The University contracted with three vendors totaling $156,960 in March and April 2020
               and with eight vendors totaling $1,759,081 during the period August 2020 through
               January 2021. University officials stated that they followed the University’s procurement
               policies and procedures applicable to non-Federal grants because they were not
               expecting Federal funding, such as HEERF Institutional grant funds, to cover the
               purchases. University officials also stated that they authorized and followed expedited


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                               28
               acquisition processes needed to quickly put life-safety measures in place during the
               coronavirus emergency. 24 The officials further stated that at times, the acquisitions
               were made under intense pressure where blanket and verbal approvals were accepted.
               We recognize the challenging circumstances under which officials were operating early
               in the pandemic; however, before the University decided to charge the $1,916,041 to its
               HEERF Institutional grant in June 2021, it should have ensured that the associated
               procurements were documented in accordance with Federal requirements.

               With noncompetitive procurements that did not consider reasonableness of cost, the
               University might be paying more for the same goods and services, or receiving goods
               and services of inferior quality, when compared to other vendors. Lack of approval for
               noncompetitive procurements improperly precludes the cost and quality benefits of a
               competitive procurement process. Further, it is important that Federal grantees, such as
               the University of Cincinnati, perform a price analysis for purchases over the SAT to
               ensure that they do not overpay for large purchases.

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

               2.1     Require the University of Cincinnati to develop and implement written policies
                       and procedures, including procedures that would identify and prevent improper
                       revenue recognition and duplicate charges, to ensure that future calculations
                       for charging lost revenue to its HEERF Institutional grant are reviewed for
                       accuracy and consistency with its financial reporting policies and procedures.

               2.2     Determine whether the University of Cincinnati implemented appropriate
                       corrective actions to resolve the $797,965 in unsupported lost revenue costs it
                       charged to its HEERF Institutional grant; and, if the corrective actions are
                       inappropriate, require the University to either return the funds to the
                       Department or reallocate the funds for allowable expenditures.




24
  On March 9, 2020, the State of Ohio’s governor declared a State emergency regarding the
coronavirus. In response, on March 25, 2020, the Ohio Department of Administrative Services issued a
notice suspending competitive procurement requirements for State agencies for purchases of
“resources and supplies necessary to protect the health, safety, and welfare of Ohioans and resolve the
COVID-19 emergency.” The University’s Purchasing Director stated that the University is not a State
agency and follows its own or Federal procurement rules for Federal grants; however, the State’s notice
added support to the University treating the coronavirus as a life-safety issue.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                     29
               2.3     Determine whether the $1,916,041 that the University of Cincinnati charged to
                       its HEERF Institutional grant for noncompetitive procurements was reasonable
                       when compared to the costs of suitable alternatives; and, if the charges were
                       inappropriate, require the University to either return the funds to the
                       Department or reallocate the funds for allowable expenditures.

               2.4     Require the University of Cincinnati to develop and implement written policies
                       and procedures to ensure that procurements charged to its HEERF Institutional
                       grant are in accordance with applicable Federal requirements; and it
                       consistently follows its procurement policies and procedures, including
                       maintaining sufficient documentation to support its rationale for
                       noncompetitive procurements and the basis for and reasonableness of the
                       contract price.

               University of Cincinnati Comments
               The University did not state whether it agreed or disagreed with the finding, but agreed
               with the recommendations. The University’s proposed corrective actions included the
               development and implementation of written policies and procedures consistent with
               the applicable lost revenue and procurement requirements specified in
               Recommendation 2.1 and Recommendation 2.4. The University also stated that it has
               repurposed the funds associated with the lost revenue costs identified in
               Recommendation 2.2 for purposes it believes are allowable and believes the
               noncompetitive procurements identified in Recommendation 2.3 were reasonable when
               compared to the costs of suitable alternatives.

               OIG Response
               The University’s proposed corrective actions for Recommendations 2.1 and 2.4, if
               effectively implemented, are responsive to our recommendations. For
               Recommendations 2.2 and 2.3, the University will need to work with Department
               officials who are responsible for determining the appropriateness of corrective actions
               already taken to resolve the unsupported lost revenue costs and the reasonableness of
               costs associated with noncompetitive procurements.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                     30
                Finding 3. University of Cincinnati Did Not Fully
                  Comply with Federal Cash Management
                  Requirements
                The University’s administration of HEERF Student Aid grant funds did not fulfill certain
                Federal cash management requirements. Specifically, the University did not minimize
                the time between drawing down and disbursing its CARES Act Student Aid grant funds
                and remitted imputed interest on unspent CARES Act Student Aid grant funds rather
                than earned interest.

                When the Department made CARES Act Student Aid grant funds available, the University
                of Cincinnati deviated from its existing cash management process of reimbursement and
                instead drew down the funds as advance payments. Senior University officials stated
                that they drew down all of the University’s CARES Act Student Aid grant funds as soon as
                the funds were awarded because they understood that it was allowable under the terms
                of the award notice since the funds were provided under emergency measures and the
                University had an immediate need. However, the University did not update its policies
                and procedures to incorporate the Federal cash management requirements for advance
                payments. Instead, the University maintained the unspent CARES Act Student Aid grant
                funds in its temporary investment pool (TIP) and imputed an interest amount, as
                described later in this finding, using the same processes as for all other reimbursed
                Federal funds. 25

                Federal regulations at 2 C.F.R. section 200.305(b) state that non-Federal entities, such as
                the University, “must minimize the time elapsing between the transfer of funds from
                [the Department] and the disbursement by the non-Federal entity ….” The regulations
                further state that advance payments must be limited to actual cash requirements for
                approved purposes, that these payments must be held in interest-bearing accounts, and
                that up to $500 earned interest per year may be retained by the non-Federal entity for
                administrative expenses. Any additional interest earned on Federal advance payments
                deposited in interest-bearing accounts must be remitted to the Department of Health
                and Human Services Payment Management System. Non-Federal entities that draw
                down funds in advance of immediate cash needs must maintain written procedures that
                minimize the time between drawing down and disbursing Federal funds.




25
  The University drew down the Institutional portion of its CARES Act grant funds to reimburse itself for
program expenditures, and similarly reimbursed itself for Student Aid and Institutional expenditures
under CRRSAA and ARP.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                           31
               In accordance with its cash management policies and procedures, the University
               typically uses its own funds first before drawing down Federal funds to reimburse itself
               for program expenditures. Its policy is to draw down Federal funds after program costs
               are incurred and not as an advance. The University’s existing cash management policies
               and procedures did not address advance payments or the Federal requirement to
               minimize the time between drawing down and disbursing Federal funds.

               When signing the Recipient’s Funding Certification and Agreement in April 2020 to
               access the University’s CARES Act Student Aid grant funds, the University certified that it
               would comply with 2 C.F.R. part 200. Further, Enclosure 4 of the Grant Award
               Notification for the Student Aid grant, dated in April 2020, also reminded grantees of
               existing cash management requirements in 2 C.F.R. part 200 and described the
               requirements in detail. Therefore, the University officials were made aware of, agreed
               to comply with, and should have ensured compliance with Federal cash management
               requirements.

               University of Cincinnati Did Not Minimize the Time Between
               Drawing Down and Disbursing CARES Act Student Aid Grant
               Funds
               The University of Cincinnati drew down its CARES Act Student Aid grant funds in
               advance of immediate cash needs instead of properly minimizing the time between
               drawing down and disbursing these funds. The Department authorized $11,763,656 in
               CARES Act Student Aid grant funds for the University on April 25, 2020, and the
               University drew down all of the funds on May 5, 2020. The University did not have an
               immediate cash need for all of the drawn funds, as discussed below; thus, the University
               did not comply with 2 C.F.R. section 200.305(b).

               As shown in Table 5, the University disbursed most (71 percent) of its CARES Act Student
               Aid grant funds within 15 days of drawing down the funds and had disbursed nearly all
               of the funds (91 percent) by the end of May 2020. However, the University of Cincinnati
               inappropriately held onto the remaining funds, ranging from about $500 to $1 million,
               as it continued to periodically disburse grant funds up through December 2020, more
               than 225 days after drawing down the funds.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                       32
               Table 5. Draw Down and Disbursement Activity for University of Cincinnati's CARES
               Act Student Aid Grant Funds, May 5, 2020, through December 18, 2020
                                                             Remaining        Percent of
                                      Draw Down and
                                                             CARES Act       Drawn Funds      Number of
                      Date 26         (Disbursement)
                                                            Student Aid        Disbursed     Days Elapsed
                                          Amount
                                                            Grant Funds      (Cumulative)

                    May 5, 2020          $11,763,656        $11,763,656            0%               0


                   May 18, 2020           (8,347,000)         3,416,656           71%              13


                   May 28, 2020           (2,364,250)         1,052,406           91%              23


                   June 10, 2020           (41,500)           1,010,906           91%              36


                   June 16, 2020             (500)            1,010,406           91%              42


                    July 2, 2020           (389,000)          621,406             95%              58


                    July 31, 2020          (237,000)          384,406             97%              87


                 September 1, 2020           (250)            384,156             97%              119


                 November 16, 2020           (500)            383,656             97%              195


                 December 4, 2020            (500)            383,156             97%              213


                 December 17, 2020         (382,650)             506              100%             226


                 December 18, 2020           (506)                –               100%             227

               Source: OIG’s Analysis of the University of Cincinnati’s CARES Act Emergency Financial Aid
               Payments report.

               University officials stated that they drew down all of the CARES Act Student Aid grant
               funds as soon as the funds were available because they understood that the grant



26
  The CARES Act Student Aid disbursements made from May through November 2020 were for
emergency financial aid grants to students enrolled at the University for the spring and summer 2020
school terms. The disbursements made in December 2020 were generally for the fall 2020 school term.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                            33
                allowed for an emergency advance of funds. The grant did allow for funds to be drawn
                down in advance of actual needs but, as noted above, University officials were also
                made aware of and agreed to comply with the Federal cash requirements to minimize
                the time between drawing down and disbursing the funds. Thus, the officials should not
                have drawn down the funds until they were prepared to disburse them.

                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.

                University of Cincinnati Remitted Imputed Rather Than Earned
                Interest on Its CARES Act Student Aid Grant Funds
                The University of Cincinnati maintained its CARES Act Student Aid grant funds in a TIP, 27
                and calculated and remitted an imputed amount of interest based on a lower Treasury
                bill rate rather than the amount of earnings the unspent CARES Act Student Aid grant
                funds generated based on the TIP’s average rate of return. Specifically, using
                information on the CARES Act Student Aid grant fund balances from its accounting
                system for May through December 2020, the University’s Treasury Department imputed
                interest monthly on the grant funds’ daily average balances using 3-month Treasury bill
                rates. Using the Treasury bill rates, total imputed interest amounted to $1,450. The
                University remitted $1,270 of this amount to the Department of Health and Human
                Services in September 2020 and retained $180 for administrative expense. 28

                Further, University officials stated that using 3-month Treasury bill rates to impute
                interest was comparable to the interest rate of the University’s cash deposits. However,
                we determined that the TIP’s average rate of return was generally higher than the
                3-month Treasury bill rates for the period May through December 2020. We also
                determined that the TIP’s average rate of return would provide an accurate accounting
                of interest earned if used in the University’s calculation than the 3-month Treasury bill



27
  The TIP includes cash, bank depositories, money market funds, and fixed income securities of
relatively short duration. The University manages the TIP based on cash flow needs and within the
constraints of its TIP investment policy statement.
28
  The $1,270 in imputed interest that the University remitted in September 2020 was for May and
June 2020, when the average outstanding balances for the CARES Act Student Aid grant funds were
more than $1 million. University officials stated that they retained the $180 in imputed interest for July
through December 2020 as administrative expense since it was less than $500.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                         34
               rates. If the University had used the TIP’s average rate of return for those months, the
               earnings attributable to the unspent CARES Act Student Aid grant funds would have
               amounted to $36,889, which was $35,439 more than the $1,450 in imputed interest.

               The University of Cincinnati did not have policies and procedures to determine and
               remit actual earnings on Federal advance payments and remitted imputed interest
               amounts instead. If Federal advances are maintained and commingled with other
               Federal and non-Federal funds in a diversified portfolio of accounts like the TIP, the
               University’s policies and procedures should ensure that it accurately accounts for the
               interest earned on the unspent Federal funds. It is important that the University have
               effective control and accountability of Federal cash advances to safeguard them and to
               ensure compliance with Federal regulations.

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

               3.1     Require the University of Cincinnati to incorporate in its policies and procedures
                       and implement the cash management requirements for minimizing the time
                       between drawing down and disbursing Federal grant funds, and remitting
                       interest earned in excess of $500 in accordance with 2 C.F.R. section 200.305(b).

               3.2     Require the University of Cincinnati to remit $35,439 based on the TIP’s average
                       rate of return, less no more than $320 ($500 minus the $180 already retained)
                       for administrative expenses if applicable; and remit the actual amount of earned
                       interest on any future advances of Federal funds, in accordance with 2 C.F.R.
                       section 200.305(b)(9).

               University of Cincinnati Comments
               The University did not state whether it agreed or disagreed with the finding. It agreed
               with Recommendation 3.1 but disagreed with Recommendation 3.2. In response to
               Recommendation 3.1, the University stated that its existing policy is to draw down funds
               for reimbursement of expenditures and not to receive funds in advance. However, the
               University believed that the Department permitted HEERF funds to be drawn down
               when they became available due to the emergency nature of the funding. Regarding
               Recommendation 3.2, the University stated that the funds were invested in a secure
               money market fund which was not earning the long-term rate that the $35,439
               calculation is based on.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                          35
               OIG Response
               For Recommendation 3.1, the University’s existing policy appears to incorporate the
               applicable cash management requirements, and if followed for HEERF funding in the
               future, would be responsive to Recommendation 3.1. However, we disagree with the
               University’s statement in response to Recommendation 3.2 that the funds were
               invested in a secure money market fund. We acknowledge that the University’s TIP,
               where the funds were deposited, included a money market fund among many other
               investment options. However, the University did not provide sufficient evidence to
               demonstrate that the funds were deposited and held in this specific money market fund
               within the TIP. The funds were commingled with other Federal and non-Federal funds
               held in the TIP and yielded $35,439 of earnings based on the TIP’s average rate of
               return. Therefore, we did not make any changes to the finding or Recommendation 3.2.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                  36
               Finding 4. University of Cincinnati’s HEERF
                 Quarterly Reporting Was Not Always Accurate
                 and Publicly Available
               The University of Cincinnati’s Student Aid and Institutional reporting was generally
               complete and timely but was not always accurate. Specifically, the University improperly
               reported $4.1 million of scholarships awarded to students in the form of student
               account credit as additional emergency financial aid grants to students in a quarterly
               report of HEERF Institutional expenditures. In addition, the University did not keep
               previous Student Aid and Institutional quarterly reports posted on its public website after
               posting updated reports.

               Schools must report publicly on their use of HEERF funds by posting the required
               information on the school’s primary website each quarter. The Department prescribed
               the contents and due dates for the quarterly Student Aid and Institutional reports. The
               Department also required schools to submit an annual performance report by completing
               an online data collection form. We determined that the information in the University of
               Cincinnati’s Student Aid and Institutional quarterly reports for the reporting periods
               through the quarter ending September 30, 2021, was generally complete and timely, but
               not always accurate as discussed below. In addition, the information in the University’s
               first HEERF annual performance report for the period ending December 31, 2020, was
               generally accurate, complete, and timely.

               After we discussed our audit results with University officials, the University revised its
               quarterly HEERF Institutional expenditure report for the quarter that ended June 30,
               2021, to properly identify the $4.1 million as scholarships and uploaded the missing
               reports to its website.

               University of Cincinnati Did Not Properly Report $4.1 Million of
               Institutional Expenditures
               The University of Cincinnati used HEERF Institutional grant funds to reimburse itself for
               $4.1 million in scholarships provided to 911 students whose attendance was disrupted
               by the coronavirus pandemic in the summer and fall 2020 school terms and spring 2021
               term. However, we found that the University incorrectly reported these scholarships as
               additional emergency financial aid grant payments to students in its quarterly HEERF
               Institutional expenditure report for the quarter that ended June 30, 2021. The
               University had distributed the scholarships as credits that were posted to student
               accounts, which reduced student account balances and generally were not paid to




U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                            37
                students. 29 The University also did not obtain students’ written consent to apply the
                award funds to student accounts, which would be required for the account credits to
                qualify as emergency financial aid payments to students under criteria applicable to the
                HEERF Student Aid grant.

                The University’s HEERF Institutional Portion Certification and Agreement provides that
                HEERF Institutional grant funds can be used to provide additional emergency financial
                aid grants to students, and Department guidance clarified that institutions may not use
                the financial aid grants to satisfy a student’s account balance without the student’s
                written affirmative consent. 30 Uniform Guidance at 2 C.F.R. section 200.403(b)
                additionally provides that costs must conform to any limitations or exclusions set forth
                in the Federal award as to their types and amount in order to be allowable under
                Federal awards.

                University officials incorrectly determined and reported these scholarships as
                emergency financial aid payments to students reimbursable from HEERF Institutional
                grant funds. The officials made this decision without properly considering or
                understanding all relevant attributes of the expenditure, including the nature of the
                scholarship transactions, available supporting records and documents, and
                requirements for using HEERF Institutional grant funds to provide emergency financial
                aid grants to students. The University should have reported the $4.1 million as
                scholarships instead of as additional emergency financial aid grants to students.

                Schools are required to report publicly and accurately on their use of HEERF Institutional
                grant funds on the school’s primary website each quarter to ensure transparency and
                accountability as to when and how institutions expended funds. The University of
                Cincinnati did not have written policies and procedures to ensure that the expenditures
                included in its quarterly HEERF Institutional expenditure reports are accurate and
                reported in the appropriate expenditure category. When transparency and
                accountability are not achieved in the reporting of grantees’ use of Federal grant funds,
                it negatively impacts the Department’s ability to effectively monitor Federal grants.



29
  In instances where the scholarship resulted in a credit balance in a student’s account, the credit
balance was disbursed to the student.
30
  “Higher Education Emergency Relief Fund (HEERF) II Public and Private Nonprofit Institution (a)(1)
Programs (CFDA 84.425E and 84.425F) Frequently Asked Questions, Coronavirus Response and Relief
Supplemental Appropriations Act, 2021,” published January 14, 2021. Question 8 addresses
requirements for making financial aid grants to students and Question 9 addresses how students may
use their grants.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                        38
               After we discussed our audit results with University officials, in July 2022 the University
               revised its quarterly HEERF Institutional expenditure report for the quarter that ended
               June 30, 2021. In the revised report, the University’s use of HEERF Institutional grant
               funds for the scholarships properly appears as an “Other” use (with explanatory
               information) rather than as additional emergency financial aid grants to students. We
               confirmed that the University posted the revised report on its public website in
               August 2022.

               University of Cincinnati Did Not Keep Previous Student Aid and
               Institutional Reports on Its Public Website
               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 of the quarterly reports on the school’s public website.
               Specifically, technical Frequently Asked Questions (FAQ) Question 2 in the guidance
               states that “[w]e ask that institutions separately maintain each quarterly report on their
               website, which adds transparency and accountability as to when and how institutions
               expended funds.” 31

               Because schools were not required to submit the quarterly reports to the Department,
               the availability of reports on recipients’ public facing websites provides an important
               means to ensure transparency and accountability. In April 2022, we noted that the
               University of Cincinnati did not keep links to previous versions of quarterly HEERF
               Student Aid and Institutional reports on its public website. When we brought this matter
               to their attention, University officials stated that they were not aware of the
               Department’s posting requirement and uploaded the missing reports to their website by
               June 2022.

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

               4.1     Require the University of Cincinnati to develop and implement written policies
                       and procedures that incorporate the HEERF program’s reporting requirements
                       and ensure that the expenditures in its quarterly HEERF Institutional
                       expenditure reports are accurate and reported in the appropriate expenditure
                       category.



31
  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/A20US0045                                                                                         39
               University of Cincinnati Comments
               The University did not state whether it agreed or disagreed with the finding, but agreed
               with the recommendation. The University did not state its planned corrective actions in
               response to this recommendation.

               OIG Response
               To be responsive to our recommendation, the University’s corrective actions should
               include the development and implementation of written policies and procedures that
               incorporate the HEERF program’s reporting requirements and better ensure the
               accuracy and completeness of HEERF expenditure reports.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                     40
               Appendix A. Scope and Methodology
               Our audit of the University of Cincinnati’s use of HEERF funds covered March 13, 2020,
               through September 30, 2021. Our audit also covered the University’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), including section 200.302(b)(3) and (4)
                      (financial management documentation and controls), section 200.303 (internal
                      controls), section 200.305(b) (cash management for non-Federal entities),
                      section 200.309 (period of performance), sections 200.318–320 (general
                      procurement standards, competition, and methods of procurement), section
                      200.324 (contract cost and price), section 200.334 (record retention), and
                      sections 200.403–404 (cost principles);

                  •   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 eight HEERF FAQ
                      documents issued from April 2020 through July 2021, including Student Portion
                      FAQs (April 9, 2020), “FAQ Rollup Document” (October 14, 2020), “Higher
                      Education Emergency Relief Fund (HEERF) II Public and Private Nonprofit
                      Institution (a)(1) Programs (CFDA 84.425E and 84.425F) Frequently Asked
                      Questions, Coronavirus Response and Relief Supplemental Appropriations Act,
                      2021” (January 14, 2021), “Higher Education Emergency Relief Fund (HEERF I, II,
                      and III) Lost Revenue Frequently Asked Questions” (March 19, 2021), and
                      “Higher Education Emergency Relief Fund III Frequently Asked Questions,
                      American Rescue Plan Act of 2021” (May 11, 2021); and

                  •   University of Cincinnati’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:




U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                    41
                   •   OIG Reports:

                       •   “Remington College’s Use of Higher Education Emergency Relief Fund
                           Student Aid and Institutional Grants,” ED-OIG/A20CA0017, September 28,
                           2021;
                       •   “Lincoln College of Technology’s Use of Higher Education Emergency Relief
                           Fund Student Aid and Institutional Grants,” ED-OIG/A20CA0016, September
                           24, 2021;

                       •   “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.

                   •   GAO Report—"COVID-19: Opportunities to Improve Federal Response Efforts,”
                       GAO-20-625, June 2020.
               Through interviews, we gained an understanding of the University of Cincinnati’s
               processes for drawing down and managing HEERF grant funds, awarding and
               distributing emergency financial aid grants to students, spending Institutional grant
               funds, determining lost revenue charges, and preparing required HEERF quarterly
               reports and first annual performance report. We interviewed senior officials from the
               Finance/Accounting, Controller, Treasury, Enrollment Management, Bursar and Central
               Purchasing departments who had a significant role in administering the University’s
               HEERF grants. To assess the reliability of the testimonial evidence, we compared and
               corroborated information obtained through interviews by reviewing available
               documents and records. We concluded that the testimonial evidence we obtained was
               sufficiently reliable within the context of our audit objective.

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

               Cash Management. We compared the dates and amounts of the University’s
               drawdowns of Student Aid and Institutional grant funds (obtained from the
               Department’s G5 system) to its expenditure records to determine whether the

U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                    42
               University of Cincinnati minimized the time between drawdown and disbursement of
               those funds. We also traced drawdown information from the Department’s G5 system
               to the University’s bank statements and accounting records to verify that the
               information reconciled. Lastly, we reviewed the types of accounts that were used to
               deposit the University’s HEERF funds to determine whether the accounts earned
               interest and the University remitted an appropriate amount of earned interest to the
               Federal government as required.

               Reporting. We reviewed the following Student Aid and Institutional reports to
               determine whether the information included in those reports was complete, accurate,
               and reported on time:

                   •   Student Aid and Institutional reports for the quarterly periods ending
                       September 30, 2020, through September 30, 2021.
                  •    First Annual Performance Report covering CARES Act Student Aid and
                       Institutional grant activities from March 13, 2020, through December 31, 2020.
               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, University provided Student
               Aid award files). To determine whether the reports were submitted on time, we
               compared each of the quarterly Student Aid and Institutional reports’ posting date to
               the reporting due date established by the Department. Similarly, we determined
               whether the University submitted its first annual performance report on time by
               comparing the date the University submitted the report to the Department to the
               required due date.

               Sampling Methodology
               We tested a sample of Student Aid distributions and Institutional expenditures to
               determine whether the University of Cincinnati used the Student Aid and Institutional
               portions of its HEERF funds for allowable and intended purposes.

               Student Aid Expenditure Selection and Testing
               During our audit period, the University used HEERF Student Aid grant funds to award
               56,079 emergency financial aid grants to students. We selected a sample of 155 grant
               awards using a combined 100-percent review, random nonstatistical, stratified sampling
               approach, as summarized in Table 6. We developed 11 strata and used a combination of
               a 100-percent review, a risk-based approach, and a random sampling approach to select
               awards from each stratum. To develop the strata, we conducted the following steps:




U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                       43
                    •    We analyzed the data that the University created in six stand-alone electronic
                         spreadsheets listing the universe of emergency financial aid grants awarded to
                         students through its automated and application processes under the CARES
                         Act, CRRSAA, and ARP.
                    •    From these data, we created three unique groups based on each coronavirus
                         relief law (funding source).

                    •    Within each group, we created a separate stratum based on the University’s
                         award process (automated or application) and, because we identified data
                         quality issues in its electronic spreadsheets, a separate stratum based on the
                         absence or presence of data quality issues where applicable. 32
                Once we defined the 11 strata, we stratified the awards by school term and used a
                100-percent review, risk-based approach, and random nonstatistical sampling approach
                to select the awards for review in each stratum. While our strata were representative of
                the universe of emergency financial aid grant awards, the sampling methodology was
                not designed to be projected to the universe of awards.




32
   When we assessed the reliability of the data in the University’s electronic spreadsheets, we noted that
most of the grant awards had complete data for our testing purposes. However, a significant number of
awards had missing or inaccurate data that increased the risk of payment errors stemming from
systemic processing issues or ineffective internal controls. To address this condition, our sampling
methodology included selecting 72 awards without data quality issues and 83 awards with data quality
issues (total of 155 awards selected for review).


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                          44
                Table 6. Universe and Sample of Student Aid Grant Expenditures through
                September 30, 2021

                                               Universe Award      Sample Award Sample Coverage Award
      Group           Description 33           Count and Dollar   Count and Dollar Count and Dollar Amount
     Stratum                                      Amount             Amount          (Percent by Stratum)


               CARES Act automated awards
               without data quality issues –
               randomly selected 4 awards       29,508 awards        12 awards       Less than 1% awards
       1-1
               from each school term             $10,867,625           $3,850            Less than 1%
               (spring, summer, and fall
               2020)

               CARES Act automated awards
               with data quality issues—
               randomly selected 3 awards         765 awards         18 awards           2.4% awards
       1-2
               with payment errors and 15          $268,700            $5,675               2.1%
               awards with unclear
               compliance

               CARES Act application awards
               without data quality issues—       590 awards          4 awards           0.7% awards
       1-3     randomly selected 3 awards
               from spring 2020 and 1 award        $295,000            $2,000               0.7%
               from summer 2020 terms

               CARES Act application awards
               with data quality issues—
               selected the 5 awards for          666 awards         29 awards           4.4% awards
       1-4     distance learners (potential
               payment error) and 24               $332,331           $13,831               4.2%
               awards with unclear
               compliance

               CRRSA Act automated awards
               without data quality issues—
               randomly selected 8 awards       12,850 awards        12 awards           0.1% awards
       2-5
               of varying award amounts          $11,269,750          $15,000               0.1%
               from spring 2021 and 4
               awards from fall 2021 terms



33
   As used in this table, awards “without data quality issues” means that data on the University’s
electronic spreadsheets indicated compliance with applicable award criteria. Awards “with data quality
issues” means that the spreadsheet data indicated a payment error (student eligibility or award amount)
or had other issues, such as missing data, that made compliance unclear.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                        45
                                             Universe Award      Sample Award Sample Coverage Award
    Group           Description   33
                                             Count and Dollar   Count and Dollar Count and Dollar Amount
   Stratum                                      Amount             Amount          (Percent by Stratum)


             CRRSAA automated awards
             with data quality issues—          348 awards         16 awards           4.6% awards
      2-6
             randomly selected awards            $319,156           $14,156                4.4%
             with unclear compliance

             CRRSAA application awards
             without data quality issues—       184 awards          8 awards           4.3% awards
      2-7    randomly selected 4 awards
             from each school term (spring       $90,750             $4,000                4.4%
             and summer 2021)

             CRRSAA application awards           8 awards           8 awards           100% awards
      2-8    with data quality issues—
             selected all awards                  $4,000             $4,000               100%


             ARP automated awards
             without data quality issues—
             randomly selected 10 awards       6,850 awards        24 awards           0.4% awards
      3-9
             from each school term (spring     $13,465,162          $37,892                0.3%
             and summer 2021) and 4
             awards from fall 2021 term

             ARP automated awards with
             data quality issues—randomly      1,510 awards        12 awards           0.8% awards
     3-10
             selected awards with unclear       $2,470,394          $24,000                1.0%
             compliance

             ARP application awards
             without data quality issues—
             randomly selected 3 awards        2,800 awards        12 awards           0.4% awards
     3-11
             from each school term (fall        $2,691,613          $11,291                0.4%
             2020 and spring, summer, and
             fall 2021)

                                              56,079 awards        155 awards          0.3% awards
       –                 Total
                                               $42,074,481          $135,695               0.3%



               For the 155 emergency financial aid grants selected, we reviewed student enrollment
               and financial information in the University’s student information system to confirm that
               students met eligibility requirements and were awarded the correct amount. Where
               applicable, we confirmed that the students were enrolled during the award term and
               their enrollment status (at least half time or part time) and that they met Title IV


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                     46
               eligibility requirements (including their EFC). We also confirmed students’ enrollment in
               distance education programs and Pell Grant awards, as well as the posting of awards to
               student accounts and methods used to disburse grant funds to students. We limited our
               review to student eligibility and correct award amount. We did not perform work to
               determine how students spent their grant funds or whether the students used the funds
               for intended purposes.

               Institutional Expenditure Selection and Testing
               During our audit period, the University used HEERF Institutional grant funds to
               reimburse itself for 48,612 transactions totaling $67.8 million—1,015 transactions
               related to lost revenue ($45.4 million) and 47,597 transactions related to the remaining
               expenditures ($22.4 million). We used a combination of 100-percent review, stratified
               random, and judgmental sampling to select transactions to review. We developed
               11 strata and either reviewed all of the expenditures (for 2 strata), used random
               sampling, or used a risk-based approach to judgmentally select transactions from each
               stratum (for 9 strata).

               To develop the strata, we analyzed the universe of expenditures from the University’s
               quarterly Institutional expenditure reports and the supporting expenditure data and
               created five unique groups based on the reports’ major expenditure categories. Within
               each group, we identified subcategories of expenditures based on the University’s
               method for determining the expenditure or the type of expenditure, where applicable.
               Based on this analysis, we created a stratum for each unique subcategory that applied.
               This resulted in a total of 11 strata from which we performed 100-percent review for
               2 of the lost revenue strata, randomly selected 58 transactions, and judgmentally
               selected 60 transactions from the remaining 9 strata, as summarized in Table 7. Because
               there is no assurance that the transactions tested were representative of the universe of
               transactions (except where 100-percent review was performed), the results could not
               be projected to the untested transactions.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                     47
               Table 7. Universe and Sample of Institutional Expenditures, as of September 30, 2021
                                                                     Sample Coverage
                                 Universe             Sample
                                                                       Transaction
  Group     Category of         Transaction         Transaction                         Selection Method
                                                                     Count and Dollar
 Stratum    Expenditure       Count and Dollar    Count and Dollar
                                                                     Amount (Percent
                                  Amount              Amount
                                                                       by Stratum)

             Lost Revenue
            from Academic
             and Auxiliary                                                 100%           Not applicable—
                               358 transactions   358 transactions
   1-1          Services                                                transactions        reviewed all
               Sources—         $43,720,062         $43,720,062                            transactions
                                                                           100%
              Period-over-
            Period Variance

            Lost Revenue
            from Auxiliary                                                 100%
                                9 transactions      9 transactions                        Not applicable—
               Services                                                 transactions
   1-2                                                                                      reviewed all
              Sources—           $1,561,418          $1,561,418
                                                                           100%            transactions
            Waived Parking
                 Fees

             Lost Revenue                                                               Selected the highest
            from Academic                                              Less than 1%     transaction, and
               Sources—        648 transactions     5 transactions                      randomly selected
   1-3                                                                 transactions
               Canceled           $141,975             $3,089                           4 transactions
              Lessons and                                                   2%          (3 Lessons and
             Performances                                                               1 Performance)

                                                                                        Selected 22 students
                                                                                        with varying housing
               Student         4,152 students        25 students        1% students     arrangements from
   2-4        Refunds—
                                 $5,330,571           $37,770               1%          different colleges,
               Housing
                                                                                        and randomly
                                                                                        selected 3 students


               Student                                                 Less than 1%      Randomly selected
            Refunds—Both       21,396 students       17 students                        17 students, at least
   2-5                                                                   students
           Campus Life and       $4,124,978            $2,659                           2 students from each
             General Fees                                              Less than 1%           campus



               Student                                                 Less than 1%      Randomly selected
              Refunds—         19,004 students       13 students                        13 students, at least
   2-6                                                                   students
             General Fees        $1,627,675            $1,040                           2 students from each
                 Only                                                  Less than 1%           campus




U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                          48
                                                                     Sample Coverage
                                 Universe             Sample
                                                                       Transaction
  Group       Category of       Transaction         Transaction                          Selection Method
                                                                     Count and Dollar
 Stratum      Expenditure     Count and Dollar    Count and Dollar
                                                                     Amount (Percent
                                  Amount              Amount
                                                                       by Stratum)

                                                                                        Selected the highest
               Operational     229 transactions     2 transactions    1% transactions   transaction, and
     3-7     Costs—Canceled
                                   $680,432           $50,552               7%          randomly selected
              Study Abroad
                                                                                        1 transaction

                                                                                              Selected the
                                                                                                4 highest
                                                                                            transactions, a
                                                                                           transaction from
                                                                                               each of the
              Operational                                                                   10 highest paid
             Costs—Campus            1,886                                                   vendors, and
                                                   23 transactions    1% transactions
     3-8       Safety and         transactions                                           4 transactions from
                Telework                             $2,028,520            36%            expenditure types
                                  $5,561,436
               Capability                                                               not yet selected; and
                                                                                          randomly selected
                                                                                           5 transactions, at
                                                                                         least 2 transactions
                                                                                        for each expenditure
                                                                                                 type 34

                                                                                        Selected 14 students
                                                                                           from different
             Scholarships—       495 students        25 students        5% students        programs with
     4-9      Nonresident                                                                varying scholarship
             Surcharge Fees       $3,894,341          $159,896              4%             amounts, and
                                                                                         randomly selected
                                                                                             11 students

                                                                                         Selected 2 students
              Scholarships—      416 students        6 students         1% students          with varying
     4-10      Co-operative                                                             scholarship amounts,
              Education Fee        $200,204            $3,434               2%              and randomly
                                                                                         selected 4 students




34
  The University’s Institutional expenditure data included the following types of expenditures:
(1) coronavirus testing and contract tracing, (2) personal protective equipment, (3) disinfecting,
(4) housing for students in isolation and quarantine, (5) meals for students in isolation and quarantine,
(6) improving telework capabilities, (7) facilitating distance learning, and (8) other services, equipment,
and supplies to prevent the spread of coronavirus.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                          49
                                                                    Sample Coverage
                                Universe             Sample
                                                                      Transaction
  Group      Category of       Transaction         Transaction                         Selection Method
                                                                    Count and Dollar
 Stratum     Expenditure     Count and Dollar    Count and Dollar
                                                                    Amount (Percent
                                 Amount              Amount
                                                                      by Stratum)

                                                                                       Randomly selected
              Salaries and     19 transactions     2 transactions   11% transactions      1 Salary and
     5-11
                Benefits         $992,942            $90,089               9%              1 Benefits
                                                                                         transaction 35

                                   48,612
                                                 485 transactions    1% transactions
      –          Total          transactions                                                   –
                                                   $47,658,529            70%
                                $67,836,034



               For the lost revenue transactions for which we performed 100-percent review (Group-
               Strata 1-1 and 1-2), we reviewed the University’s lost revenue calculations by comparing
               the revenue results to the general ledger accounting records. We determined whether
               the revenue sources used were appropriate and analyzed revenue trends to assess the
               reasonableness of the revenue amounts.

               For the other 118 transactions that we selected (Group-Strata 1-3 through 5-11), 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, CRRSAA, and ARP. Specifically, we reviewed each expenditure to
               determine whether it was valid, authorized, allowable, allocable, and reasonable under
               the CARES Act, CRRSAA, and ARP and in accordance with Uniform Guidance at 2 C.F.R.
               part 200 and applicable Department guidance (HEERF FAQs).

               Use of Computer-Processed Data
               We relied, in part, on computer-processed data from the University’s student
               information and accounting systems. We used information in its student information
               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
               and that the student received the correct award amount. To assess the reliability of the
               data in the accounting system, we compared HEERF fund deposit and disbursement



35
  Randomly selected 1 Salary and 1 Benefits transaction and tested 15 employees from each
transaction—5 highest paid employees, 5 highest paid hourly employees, 1 highest paid part-time
employee, and 4 randomly selected employees.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                      50
               information recorded in the accounting system to the Department’s G5 system, the
               University’s bank statements, and vendor invoices. We did not identify any issues and
               concluded that the data in the University’s student information and accounting systems
               were sufficiently reliable for the purposes of our audit.

               Additionally, we relied on computer-processed data from the University’s electronic
               spreadsheets documenting its use of HEERF funds. We used the data to select a sample
               of emergency financial aid grant awards and a sample of Institutional expenditures for
               testing. We used data on the number and amounts of emergency financial aid awards
               and Institutional expenditures to determine whether the University included complete
               and accurate information in its quarterly Student Aid and Institutional and annual
               performance reports. We also used data on cash receipts and disbursements to
               determine whether the University minimized the time between drawing down and
               disbursing HEERF funds.

               To assess the reliability of the data, we compared student, expenditure, and cash flow
               data to information in the University’s student information and accounting systems,
               vendor invoices, bank statements, and quarterly Student Aid and Institutional reports.
               The information reconciled and we concluded that the data in the University’s electronic
               spreadsheets were generally reliable for purposes of our audit. We identified one
               exception pertaining to the data quality issues we identified in the spreadsheets listing
               the emergency financial aid grants awarded to students, as described in the Sampling
               Methodology section above. To mitigate the risk of payment errors stemming from
               systemic processing issues or ineffective internal controls that otherwise might not be
               detected, we significantly expanded our sample to include awards with data quality
               issues.

               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 the University of Cincinnati’s processes (including 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



U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                      51
               obtained provides a reasonable basis for our findings and conclusions based on our
               audit objective.

               We performed our audit work remotely from November 2021 through August 2022. We
               discussed the results of our audit with University of Cincinnati officials on
               August 24, 2022, and provided them with a draft of this report on November 17, 2022.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                                    52
               Appendix B. Acronyms and Abbreviations
                ALN                Assistance Listing Number

                ARP                American Rescue Plan

                C.F.R.             Code of Federal Regulations

                CARES Act          Coronavirus Aid, Relief, and Economic Security Act

                CRRSAA             Coronavirus Response and Relief Supplemental Appropriations
                                   Act

                Department         U.S. Department of Education

                EFC                Expected Family Contribution

                FAFSA              Free Application for Federal Student Aid

                FAQ                Frequently Asked Questions

                GAO                Government Accountability Office

                HEA                Higher Education Act of 1965

                HEERF              Higher Education Emergency Relief Fund

                OIG                Office of Inspector General

                Pell               Federal Pell Grant

                SAT                Simplified Acquisition Threshold

                TIP                Temporary Investment Pool

                Title IV           Title IV of the Higher Education Act of 1965

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

                University         University of Cincinnati




U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                                                               53
               University of Cincinnati Comments




U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045                                   54
U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045               55
U.S. Department of Education
Office of Inspector General
ED-OIG/A20US0045               56


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