Oakland University

Assistance Listing Number, Federal Agency, and Program Name - 84.425E Higher Education Emergency Relief Fund (HEERF) - Student Portion Federal Award Identification Number and Year - P425E201974 - Year ended June 30, 2022 Pass through Entity - Not applicable Finding Type - Significant deficiency Repeat Finding - No Criteria - The U.S. Department of Education, through a notice issued on May 13, 2021, requires that quarterly reports related to HEERF are publicly posted on the University's website no later than 10 days after the end of each calendar quarter. Further, the Higher Education Emergency Relief Fund III FAQ dated May 11, 2021 requires reporting activity separately each quarter. Condition - The quarterly report for the student portion of HEERF was not posted on the University's website within the time frame and format allowed in one instance. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - The student portion report for the quarter ended September 30, 2021 was not posted on the University's website within the required time frame. Cause and Effect - Confirmation of the upload of the quarterly report for the student HEERF grant under the American Rescue Plan (ARP) was not monitored sufficiently to ensure timely posting to the University's website. Recommendation - We recommend the University implement additional monitoring controls to ensure that required reports for grants that are new, or for which the University does not have historical experience (such as HEERF), are issued according to the prescribed guidance within the allowed time frame. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding and recommendation. The University spent and accounted for $75.6 million in HEERF grants appropriately and followed all applicable guidelines. The University also adhered to the various reporting guidelines that changed multiple times during the grant period, with the exception of this one untimely report posting to the Oakland University website. This was caused by personnel turnover occurring at that time within multiple departments that were part of the process. This situation was unique and has been corrected.

CFDA Number, Federal Agency, and Program Name - 84.425F Higher Education Emergency Relief Funds (HEERF) - Institutional Portion Federal Award Identification Number and Year - P425F202929 - Year Ended June 30, 2021 Pass-through Entity - Not applicable Finding Type - Material weakness Repeat Finding - No Criteria - The Uniform Guidance Cost Principles described in 2 CFR Part 200, Subpart E, apply to the HEERF subprogram. Except where otherwise authorized by statute, costs must be determined, except, for state and local governments and Indian tribes only, or as otherwise provided for in the Code of Federal Regulations. (2 CFR ? 200.403) Condition - Lost revenue incurred for the fiscal year ended June 30, 2021 was reported as an incurred expenditure by the University subsequent to year end and initially excluded from the fiscal year 2021 Schedule of Expenditures of Federal Awards (SEFA). Additionally, housing refunds incurred for the fiscal year ended June 30, 2020 were reported as incurred expenditures by the University subsequent to the year end and included on the June 30, 2021 SEFA. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable Context - Lost revenue of $25,805,184 incurred for the fiscal year ended June 30, 2021 was intially excluded from the SEFA. Management adjusted the June 30, 2021 SEFA to include lost revenue based on the auditors indentification and proposed adjustment. Housing refunds of $3,147,023 incurred for the fiscal year ended June 30, 2020 were included on the June 30, 2021 SEFA. The nature of the costs incurred were allowable under the grant. Cause and Effect - The concept of Lost Revenue was new and unique to the HEERF grants provided by the Department of Education. The University did not follow the HEERF Lost Revenue FAQs published on March 19, 2021 which indicated that lost revenue calculated for the year ended June 30, 2021 should be reported on the fiscal year 2021 SEFA. The effective would have been reporting the Lost Revenue on the SEFA in the following year. Recommendation - We recommend that the University formalize enhanced review procedures for significant and uncommon transactions to ensure that transactions are included as incurred expenditures in the proper period. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding and corrective action as noted. The University did not determine it was going to charge the Lost Revenue to the grant until after the reporting period in both cases noted above, and initially reported the Lost Revenue in the same year it was charged to the grant. The University relied on the HEERF Lost Revenue FAQs published on March 19, 2021 for its initial recording of the Lost Revenue on the SEFA. In that guidance it states [For quarterly and annual reporting purposes, the date that an institution charges its HEERF grant award for lost revenue is the date that lost revenue cost has been ?incurred?]. There is additional guidance and interpretation on this unique transaction that indicates it should be reported in the period when the loss occurred. The corrective action plan includes the University utilizing all available resources and reviewing with the audit firm prior to recording and reporting on significant and uncommon transactions.

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