University of Cincinnati’s Use of Higher Education Emergency Relief Fund Student Aid and Institutional Grants

Submitting OIG:

Report Description:

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. 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 compliance for its use of Institutional grant funds. We also found that the University did not fully comply with cash management and reporting requirements.

Date Issued:

Tuesday, January 17, 2023

Agency Reviewed / Investigated:

Department of Education

Submitting OIG-Specific Report Number:

A20US0045

Component, if applicable:

Office of Finance and Operations

Location(s):

Agency-Wide

Type of Report:

Audit

Special Projects:

Pandemic

Questioned Costs:

Funds for Better Use:

Number of Recommendations:

Report updated under NDAA 5274:

View Document:

Attachment	Size
FY23A20US0045012324SECUREDv100.pdf	3.03 MB

Additional Details Link:

https://www2.ed.gov/about/offices/list/oig/auditrpts/universityofcincinnati-repo…

Recommendation Number	Recommendation Status	Significant Recommendation
1.1	Open	Yes
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	Open	Yes
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	Open	Yes
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.
2.1	Open	Yes
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	Open	Yes
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.
2.3	Open	Yes
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	Open	Yes
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.
3.1	Open	No
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	Open	No
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).
4.1	Open	Yes
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.

Recommendation Number

Recommendation Status

Significant Recommendation

Additional Details

1.1

Open

Yes

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

Open

Yes

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).