Reports

Department of Education OIG

Remington College’s Use of Higher Education Emergency Relief Fund Student Aid and Institutional Grants

The objective of our audit was to determine if Remington College used the Student Aid (Assistance Listing Number (ALN) 84.425E) and Institutional (ALN 84.425F) portions of its Higher Education Emergency Relief Fund (HEERF) grant funds for allowable and intended purposes. Remington College generally used the Student Aid portion of its HEERF grant funds for allowable and intended purposes but did not always use the Institutional portion of its funds in accordance with Federal requirements. We found that Remington College spent Institutional funds for several unallowable purposes and did not...

Full Details: Oversight.gov Report Page

Audit | 9/28/2021

2.1 - Open

Require Remington College to return to the Department the $80,121 in Institutional grant funds spent beyond the supplemental Institutional grant period or reallocate the funds to other allowable costs.

2.2 - Open

Clarify whether the costs that Remington College initially charged to its Institutional grant for student computers were allowable under the law and existing guidance, and determine whether Remington College’s subsequent reallocation of costs for other expenses in the amount of $64,985 (corrective actions) was appropriate.

2.3 - Open

Determine whether the $639,400 that Remington College charged to its Institutional grant for contracts awarded without a competitive procurement process was reasonable when compared to the quality and costs of suitable alternatives, and if not, require appropriate corrective actions.

2.4 - Open

Require Remington College to incorporate in its policies and procedures for managing HEERF grant funds the Federal requirements related to charging only allowable costs during the grant performance period, using competitive processes for selecting vendors when purchases are over $10,000, obtaining price or rate quotations from an adequate number of qualified vendors for purchases between $10,000 and $250,000, and using formal procurement methods for purchases over $250,000.

2.5 - Open

Require Remington College to ensure that school officials responsible for making purchasing decisions receive sufficient training on Federal rules and regulations related to grant administration and management.

3.1 - Open

Require Remington College to incorporate in its policies and procedures for managing Institutional grant funds the Federal cash management requirements related to minimizing the time between drawing down and spending Federal grant funds, including HEERF funds; maintaining the funds in an interest-bearing account; and remitting interest earned in excess of $500 in accordance with 2 C.F.R. § 200.305(b).

3.2 - Open

Require Remington College to incorporate in its policies and procedures for managing Student Aid grant funds the Federal cash management requirements related to maintaining the funds in an interest-bearing account and remitting interest earned in excess of $500 in accordance with 2 C.F.R. § 200.305(b).

3.3 - Open

Determine whether Remington College accurately calculated interest and ensure that the correct amount of interest is returned to the Federal government in accordance with 2 C.F.R. § 200.305(b)(9).

Department of Education OIG

Lincoln College of Technology’s Use of Higher Education Emergency Relief Fund Student Aid and Institutional Grants

The objective of our audit was to determine whether Lincoln College of Technology (Lincoln) used the Student Aid (Assistance Listing Number (ALN) 84.425E) and Institutional (ALN 84.425F) portions of its Higher Education Emergency Relief Fund (HEERF) funds for allowable and intended purposes. We also reviewed Lincoln’s cash management practices and the timeliness and quality of the data Lincoln reported on its use of HEERF funds. LESC generally used the Student Aid portion of Lincoln’s HEERF funds for allowable and intended purposes but did not always use the Institutional portion of its funds...

Full Details: Oversight.gov Report Page

Audit | 9/24/2021

1.1 - Closed

We recommend that the Assistant Secretary for the Office of Postsecondary Education require LESC to update its written policies and procedures to contain sufficient detail to ensure that (1) all the steps necessary to verify student eligibility and distribute funds to students under the CARES Act and subsequent coronavirus legislations are addressed and completed, (2) funding determinations are adequately documented and supported in accordance with 2 C.F.R. § 200.302, and (3) students with exceptional need are prioritized in accordance with CRRSAA and ARP.

2.1 - Closed

Regarding LESC’s decision to reallocate the amounts we questioned in this finding, we recommend that the Assistant Secretary for the Office of Postsecondary Education review the reallocated funds and determine whether LESC’s use of $710,274 of Lincoln’s Institutional grant funds to write off unpaid accounts receivable for students, who withdrew from the school due to coronavirus, was allowable and for the intended purposes of applicable coronavirus relief legislation.

2.2 - Closed

If LESC’s reallocation of Lincoln’s Institutional grant funds is deemed unallowable, we recommend that the Assistant Secretary for the Office of Postsecondary require LESC to return to the Department the $700,155 of Lincoln’s Institutional grant funds that LESC improperly applied to credit student accounts for rent students paid to third-party landlords and the $9,838 that LESC improperly spent for subscriptions extending beyond the grant performance period and determine if these issues occurred at LESC’s other schools and take corrective action as appropriate.

3.1 - Closed

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

3.2 - Closed

We recommend that the Assistant Secretary for the Office of Postsecondary Education determine whether LESC accurately calculated interest and properly remitted the interest returned in January 2021, in accordance with 2 C.F.R. § 200.305(b)(9).

National Science Foundation OIG

Performance Audit of the Implementation of OMB COVID-19 Flexibilities – University of Michigan

Full Details: Oversight.gov Report Page

Audit | 8/02/2021

National Science Foundation OIG

Performance Audit of the Implementation of OMB COVID-19 Flexibilities – University of Central Florida

Full Details: Oversight.gov Report Page

Audit | 5/27/2021

Finding 1, Rec. 1 - Closed

Direct UCF to provide documentation supporting that it has repaid or otherwise credited the $134 in questioned fringe benefit costs for which it has agreed to reimburse NSF.

Finding 1, Rec. 2 - Closed

Direct UCF to notify its Federal sponsors that its personnel have not yet certified their effort for the Fall 2019, Spring 2020, Summer 2020, and Fall 2020 semesters.

Finding 1, Rec. 3 - Closed

Direct UCF to require its employees to certify their effort for the Fall 2019, Spring 2020, Summer 2020, and Fall 2020 semesters and then process any cost transfers needed to ensure that UCF charged NSF for salary costs that were consistent with the effort certified.

Finding 1, Rec. 4 - Closed

Direct UCF to review all salary earned during June 2020 to verify that its accounting system appropriately applied fringe benefits at the correct rate and, if the accounting system did not apply fringe benefits at the correct rate, process any adjustments necessary.

Finding 2, Rec. 1 - Closed

Direct UCF to provide documentation supporting that it has repaid or otherwise credited the $160 of questioned participant support costs for which it has agreed to reimburse NSF.

Finding 2, Rec. 2 - Closed

Direct UCF to establish policies and procedures to ensure that it obtains and documents proper approval for insurance costs before charging the costs to NSF awards.

Finding 2, Rec. 3 - Closed

Direct UCF to establish policies and procedures to ensure that it does not apply fringe benefit rates to participant support costs that it processes through its payroll subledger.

National Science Foundation OIG

Performance Audit of the Implementation of OMB COVID-19 Flexibilities – California Institute of Technology

Full Details: Oversight.gov Report Page

Audit | 5/26/2021

Finding 1, Rec. 1 - Closed

Resolve the $16,351 in questioned salary expenses for which Caltech has not agreed to reimburse NSF and direct Caltech to repay or otherwise remove the sustained questioned costs from its NSF awards.

Finding 1, Rec. 2 - Closed

Direct Caltech to provide documentation supporting that it has repaid or otherwise credited the $418 of questioned salary expenses for which it has agreed to reimburse NSF.

Finding 1, Rec. 3 - Closed

Direct Caltech to strengthen its policies and procedures by retroactively establishing expiration dates on its use of the Other Paid Leave Pool on Federal awards and ensuring that these expiration dates align with the expiration dates and criteria specific to Flexibility 6 of Office of Management and Budget Memorandum M-20-17.

Finding 2, Rec. 1 - Closed

Resolve the $31,856 in questioned subaward expenses for which Caltech has not agreed to reimburse NSF and direct Caltech to repay or otherwise remove the sustained questioned costs from its NSF awards.

Finding 2, Rec. 2 - Closed

Direct Caltech to strengthen its internal control processes and procedures surrounding the transfer of significant portions of NSF-funded research to other organizations. Updated processes could include: a. Establishing procedures to verify whether the scope of work for a proposed subcontract on an NSF award is programmatic in nature before issuing the subcontract. If the scope of work is programmatic in nature, Caltech should obtain the NSF Grants Officer’s approval before issuing the subcontract. Caltech could obtain this approval either as part of the initial NSF grant proposal/budget or through a formal request to transfer the research or effort, submitted through NSF’s FastLane system. b. Requiring periodic training for Caltech personnel that are permitted to subaward, issue, or subcontract out research under NSF awards, to ensure that they request the appropriate approvals. c. Establishing procedures to confirm that Caltech personnel perform pass-through entity risk assessments to identify the appropriate monitoring procedures when Caltech awards NSF research to a pass-through entity. d. Establishing periodic monitoring procedures to ensure that Caltech appropriately assesses indirect costs on the first $25,000 invoiced by each subawardee.

Finding 3, Rec. 1 - Closed

Direct Caltech to provide documentation supporting that it has repaid or otherwise credited the $1,515 of questioned indirect costs for which it has agreed to reimburse NSF.

Finding 3, Rec. 2 - Closed

Direct Caltech to strengthen its monitoring procedures and internal control processes for applying indirect costs to Federal awards. Updated procedures could include: a. Requiring that personnel review rental expenses charged to NSF awards to assess whether the expenses included indirect costs. Specifically, Caltech should ensure the general ledger account codes it establishes to account for equipment rental charges do not apply indirect costs. b. Requiring that personnel review capitalized expenses charged to an NSF award to ensure that the capitalized amount includes all applicable costs.

Finding 3, Rec. 3 - Closed

Direct Caltech to quantify the total indirect costs inappropriately applied to NSF awards as a result of its rental equipment account inappropriately applying indirect costs and to reimburse NSF for the appropriate amount.

Finding 4, Rec. 1 - Closed

Direct Caltech to provide documentation supporting that it has repaid or otherwise credited the $581 of questioned salary and fringe costs for which it has agreed to reimburse NSF.

Finding 4, Rec. 2 - Closed

Direct Caltech to strengthen its administrative and management controls and processes surrounding the charging of salary to Intergovernmental Personnel Act awards. Updated processes could include requiring departmental payroll personnel to perform additional procedures to ensure that Caltech appropriately established initial salary payments, including verifying that all payments are within the Intergovernmental Personnel Act assignment dates.

Finding 5, Rec. 1 - Closed

Direct Caltech to update its current award set-up practices to require that, when setting up accounts established for NSF awards, personnel ensure that the accounts apply indirect costs using either the rates that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date of the NSF grant award or the rates identified in the NSF award letters, as appropriate.

National Science Foundation OIG

Performance Audit of the Implementation of OMB COVID-19 Flexibilities - University of Wisconsin - Madison

Full Details: Oversight.gov Report Page

Audit | 5/25/2021

Finding 1, Rec. 1 - Closed

Resolve the $26,974 in questioned Award Cash Management $ervice drawdowns for which UW-Madison has not agreed to reimburse NSF and direct UW-Madison to repay or otherwise remove the sustained questioned drawdowns from its NSF awards.

Finding 1, Rec. 2 - Closed

Direct UW-Madison to provide documentation supporting that it has repaid or otherwise credited the $20,431 of questioned Award Cash Management $ervice drawdowns for which it has agreed to reimburse NSF.

Finding 1, Rec. 3 - Closed

Direct UW-Madison to update its administrative and management processes and internal control procedures surrounding the Award Cash Management $ervice procedures for awards with expiring appropriations. Updated processes could include validating that UW-Madison adequately documents that any Award Cash Management $ervice draws in excess of its actual expenses support immediate cash needs.

Finding 1, Rec. 4 - Closed

Direct UW-Madison to strengthen its award set-up processes and procedures to ensure it cannot charge costs to an active award if the Federal appropriations for the award have expired.

Finding 2, Rec. 1 - Closed

Direct UW-Madison to provide documentation supporting that it has repaid or otherwise credited the $1,593 in questioned costs for which it has agreed to reimburse NSF.

Finding 2, Rec. 2 - Closed

Direct UW-Madison to update its administrative and management processes and internal control procedures surrounding the Award Cash Management $ervice system to ensure that UW-Madison appropriately incorporates credits when calculating the total amount to draw down from, or return to, NSF.

Finding 3, Rec. 1 - Closed

Direct UW-Madison to update its current award set-up practices to require that, when setting up accounts established for NSF awards, personnel ensure that the accounts apply indirect costs using the rates that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date of the NSF grant award, rather than using the rates included within the original grant proposal.

Finding 4, Rec. 1 - Closed

Direct UW-Madison to strengthen its Research Experience for Undergraduate award setup procedures to ensure that personnel select the appropriate indirect cost base.

National Science Foundation OIG

Performance Audit of the Implementation of OMB COVID-19 Flexibilities - Florida State University

Full Details: Oversight.gov Report Page

Audit | 5/25/2021

Finding 1, Rec. 1 - Closed

Direct FSU to provide documentation supporting that it has repaid or otherwise credited the $4,808 of questioned Award Cash Management $ervice drawdowns for which it has agreed to reimburse NSF.

Finding 1, Rec. 2 - Closed

Direct FSU to update its administrative and management processes and internal control procedures for awards with expiring appropriations. Updated processes could include: a. Validating that FSU adequately documents that any Award Cash Management $ervice draws in excess of its actual expenses support immediate cash needs. b. Ensuring that FSU’s system prohibits personnel from posting costs to an award after the award’s appropriation expires.

Finding 2, Rec. 1 - Closed

Direct FSU to provide documentation supporting that it has repaid or otherwise credited the $3,648 in questioned publication and other direct costs for which it has agreed to reimburse NSF.

Finding 2, Rec. 2 - Closed

Direct FSU to establish clear guidance regarding the allowability of publication expenses, including the need to acknowledge NSF funding sources.

Finding 2, Rec. 3 - Closed

Direct FSU to strengthen its grant closeout procedures to ensure that it reimburses NSF for any expenses that it determines did not benefit the NSF award(s) charged. Additional procedures should ensure that FSU refunds the NSF award(s) for any materials and supplies that it was unable to use before the award’s period of performance expired.

Finding 2, Rec. 4 - Closed

Direct FSU to implement additional controls to prevent personnel from directly charging NSF awards for costs charged to accounts established to accumulate expenses that are not typically allowed on Federal awards, such as credit/debit fees, unless the personnel obtain specific prior approval.

Finding 3, Rec. 1 - Closed

Direct FSU to provide documentation supporting that it has repaid or otherwise credited the $567 of questioned indirect costs for which it has agreed to reimburse NSF.

Finding 3, Rec. 2 - Closed

Direct FSU to strengthen its administrative and management processes and internal controls for applying indirect costs to Federal awards. Updated procedures could include implementing an annual review of other direct costs charged to sponsored awards that include funding for participant support costs to ensure that FSU is appropriately segregating other direct costs incurred on behalf of participants in accounts to which it does not apply indirect costs.

National Science Foundation OIG

Performance Audit of the Implementation of OMB COVID-19 Flexibilities – Florida International University

Full Details: Oversight.gov Report Page

Audit | 5/19/2021

Finding 1, Rec. 1 - Closed

Resolve the $1,252 in questioned Award Cash Management $ervice drawdowns for which FIU has not agreed to reimburse NSF and direct FIU to repay or otherwise remove the sustained questioned costs from its NSF awards.

Finding 1, Rec. 2 - Closed

Direct FIU to provide documentation supporting that it has repaid or otherwise credited the $14,167 of questioned costs for which it has agreed to reimburse NSF.

Finding 1, Rec. 3 - Closed

Direct FIU to update its administrative and management processes and internal control procedures surrounding the Award Cash Management $ervice for awards with expiring appropriations. Updated processes should ensure FIU appropriately documents how it calculates the final draw amounts for awards with expiring appropriations, to ensure it only uses the draws to cover costs incurred before the appropriation expired.

Finding 1, Rec. 4 - Closed

Direct FIU to strengthen its award set-up processes and procedures to ensure it cannot charge costs to an active award if the Federal appropriations for the award have expired.

Finding 2, Rec. 1 - Closed

Resolve the $791 in questioned fringe benefit costs for which FIU has not agreed to reimburse NSF and direct FIU to repay or otherwise remove the sustained questioned costs from its NSF awards.

Finding 2, Rec. 2 - Open

Direct FIU to provide documentation supporting that it has repaid or otherwise credited the $5,934 of questioned promotional and salary costs for which it has agreed to reimburse NSF.

Finding 2, Rec. 3 - Open

Direct FIU to establish clear guidance regarding the 
allowable uses

An allowable use is any expenditure on which an entity can spend funding.


of participant support cost funding. This guidance should address: a. Allowable uses of participant support cost funding. b. How to verify personnel did not apply fringe benefit rates to participant stipends or other non-salary expenses.

Finding 2, Rec. 4 - Closed

Direct FIU to strengthen its monitoring procedures surrounding costs charged to its NSF Research Experiences for Undergraduates programs. Updated procedures should ensure FIU charges costs associated with promotional and/or other unallowable items to nonFederal funding sources.

Finding 3, Rec. 1 - Closed

Direct FIU to update its current practices to ensure it only applies fringe benefits using fringe benefit rates that have been approved by its cognizant audit agency.

National Science Foundation OIG

Performance Audit of the Implementation of OMB COVID-19 Flexibilities – State University of New York at Stony Brook

Full Details: Oversight.gov Report Page

Audit | 5/18/2021

Finding 1, Rec. 1 - Closed

Direct Stony Brook to provide documentation supporting that it has repaid or otherwise credited the $20,530 of questioned Award Cash Management $ervice drawdowns associated with unspent funds.

Finding 1, Rec. 2 - Closed

Direct Stony Brook to update its administrative and management processes and internal control procedures surrounding the Award Cash Management $ervice for awards with expiring appropriations. Updated processes could include validating that Stony Brook only draws down funding based on immediate cash needs and/or adequately documents that any Award Cash Management $ervice draws in excess of its actual expenses support immediate cash needs.

Finding 2, Rec. 1 - Closed

Direct Stony Brook to provide documentation supporting that it has repaid or otherwise credited the $6,913 in questioned travel costs for which it has agreed to reimburse NSF.

Finding 2, Rec. 2 - Closed

Direct Stony Brook to provide additional guidance to ensure personnel reimburse NSF timely for cash drawn down for unused travel advances.

Finding 3, Rec. 1 - Closed

Direct Stony Brook to provide documentation supporting that it has repaid or otherwise credited the $3,898 in questioned travel costs for which it has agreed to reimburse NSF.

Finding 3, Rec. 2 - Closed

Direct Stony Brook to strengthen its monitoring procedures and internal controls surrounding the allocation of travel expenses to sponsored projects. Processes could include reviewing and assessing the allocation of all travel expenses charged to NSF awards.

Finding 4, Rec. 1 - Open

Direct Stony Brook to separately track its on-campus and off-campus activities so that it can appropriately apply the approved on-campus and off-campus indirect cost rates.

Finding 4, Rec. 2 - Open

Direct Stony Brook to update its current budget proposal process to eliminate the use of blended indirect cost rates.

Finding 5, Rec. 1 - Open

Direct Stony Brook to update its current award set-up practices to require that, when setting up accounts established for NSF awards, personnel ensure that the accounts apply indirect costs using the rates that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date of the NSF grant award, rather than using the rates included within the original grant proposal.

Finding 5, Rec. 2 - Open

Direct Stony Brook to update its current award set-up practices to remove the establishment of indirect cost budget caps.

Department of Education OIG

Risk of Closed Institutions of Higher Education Receiving Higher Education Emergency Relief Fund Grants

The purpose of this report is to share with the U.S. Department of Education (Department) observations made by the Office of Inspector General (OIG) concerning institutions of higher education (IHE) that ceased to provide educational instruction in all programs of study (closed) and received or had access to coronavirus response and relief aid through the Higher Education Emergency Relief Fund (HEERF). We found that 17 IHEs that closed on or before December 31, 2020, applied for and were awarded a total of $4,912,675 of HEERF grants by OPE. Of these 17 IHEs, 14 drew down HEERF funds and 3 did...

Full Details: Oversight.gov Report Page

Date Range

Report Type

Report Category

Submitting Agency

State/Local Agency

State (State and Local Reports)

Fraud Type

Agency Reviewed

Related Organizations

Management Challenges

Any Recommendations

Any Open Recommendations

Reports

Remington College’s Use of Higher Education Emergency Relief Fund Student Aid and Institutional Grants

Lincoln College of Technology’s Use of Higher Education Emergency Relief Fund Student Aid and Institutional Grants

Performance Audit of the Implementation of OMB COVID-19 Flexibilities – University of Michigan

Performance Audit of the Implementation of OMB COVID-19 Flexibilities – University of Central Florida

Performance Audit of the Implementation of OMB COVID-19 Flexibilities – California Institute of Technology

Performance Audit of the Implementation of OMB COVID-19 Flexibilities - University of Wisconsin - Madison

Performance Audit of the Implementation of OMB COVID-19 Flexibilities - Florida State University

Performance Audit of the Implementation of OMB COVID-19 Flexibilities – Florida International University

Performance Audit of the Implementation of OMB COVID-19 Flexibilities – State University of New York at Stony Brook

Risk of Closed Institutions of Higher Education Receiving Higher Education Emergency Relief Fund Grants

Glossary

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