Overview
During our audit testing of institutional funding related to Section 18004(a)(1) of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, we found that 2 of 27 expense transactions were not allowable under the guidance issued by the United States Department of Education (US DOE). The 2 transactions were used for revenue recovery, which is an unallowable expense for CARES 18004(a)(1) institutional funds. Upon discussion with management at Greenfield Community College (GCC), we noted that both transactions were identified by management and subsequently transferred to CARES 18004(a)(2) Title III funding. We further noted that US DOE had issued modified guidance on March 19, 2021, reinterpreting how grantees may calculate “lost revenue” and charge it to their Higher Education Emergency Relief Fund awards. The modified guidance provides reimbursement for lost revenue from CARES 18004(a)(1) institutional funding that may be applied retroactively to March 13, 2020, the date a national emergency was declared. Although we identified the 2 transactions mentioned above as exceptions during our testing, we subsequently determined that disclosing them as findings would not be appropriate because of the modified guidance.
| Date published: | July 12, 2021 |
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