Department of Education OIG releases CARES Act action plan

As part of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, the Department of Education (ED) Office of Inspector General (OIG) was provided an additional $7 million to carry out oversight activities of the $30 billion in funding provided to ED as part of the CARES Act. The OIG released its Coronavirus Relief Oversight Plan outlining the audits and reviews it anticipates performing. The focus of the plan includes:

• Spending of the relief funds
• Effectiveness of the related programs
• Investigations of any reported fraud, misuse or abuse of funds

Specific to higher education institutions, the OIG plans to conduct audits and reviews to:

• Review the schools’ use of the CARES Act flexibilities for campus-based programs – Federal Work-Study (FWS) and Federal Supplemental Education Opportunity Grant (FSEOG)
• Review the schools’ use of the Higher Education Emergency Relief Fund (HEERF) funds, particularly the 50% earmarked for emergency grants to students

Institutions should be aware that OIG and Federal Agency reviews can be narrowly focused (e.g., on one specific compliance requirement) or cover a wide range of requirements for a program. OIG audits are often significantly more detailed than an institution’s annual external financial statement or compliance audit.

In order to adequately prepare for OIG scrutiny, institutions should verify whether the following key questions have been addressed:

• Can the institution provide evidence that all students receiving emergency grant funds were eligible?
• Can the institution substantiate that eligible expenses were incurred by students? (at a minimum, in the amount distributed as emergency grants)
• Can the institution provide evidence that at least 50% of HEERF funds were paid directly to students?
• Did the institution’s distribution mechanism clearly evidence that students directly received allocated HEERF funds?

Colleges and universities preparing for OIG scrutiny should ensure that all institutional policies, procedures and distribution plans related to the CARES Act are memorialized and consistently followed. In addition, institutions should prioritize maintaining documentation to support student eligibility, disbursements of emergency grant funds, spending of the institutional portion of funds and any compliance exceptions. 

For more information on this topic, or to learn how Baker Tilly higher education specialists can help, contact our team.