Report 2021-611 Recommendation 4 Responses

Report 2021-611: Higher Education Emergency Relief Fund: Some University Campuses Did Not Maximize Available Federal Pandemic Funds, and They Prioritized Students Differently When Awarding Relief Funds (Release Date: November 2021)

Recommendation #4 To: University of California

To encourage campuses to obtain additional federal funds that allow them to maximize student services and aid, UCOP should monitor its campuses' FEMA claims to ensure that eligible expenses are submitted to FEMA and, for any expenses not submitted, obtain the campuses' explanation for why it is not feasible to submit them.

UCOP has completed its review of campus uses of HEERF for FEMA-eligible expenses. Two of the campuses are in the process of reviewing some or all of the eligible expenses that they identified to UCOP for submission to FEMA. The other campuses have indicated that they would not seek FEMA reimbursement for costs claimed under HEERF because 1) new HEERF III requirements require that some portion of funds be used for COVID monitoring and suppression measures (see link below), 2) FEMA-eligibility guidelines are as of yet still unclear for the costs they identified, and 3) PwC auditors advised campuses to be very cautious about moving expenses already claimed using HEERF to new FEMA projects.

UCOP continues to monitor and review FEMA claim submissions monthly. As of August 3, 2022, campuses have submitted $59.6 million of FEMA projects (an increase of $41.3 million from November, 2021) and have recovered $10.4 million (as compared to $247,000 in November '21).

https://www2.ed.gov/about/offices/list/ope/arpheerfiiicaa1institution.pdf

California State Auditor's Assessment of Status: Fully Implemented

UCOP provided evidence that it monitored its campuses' FEMA claims and, for eligible expenses that were not submitted, it obtained the campuses' explanations for why they did not submit claims. The campuses had submitted $18.3 million in FEMA reimbursement requests according to November 2021 UCOP data. As of August 2022, the campuses had submitted another $41.3 million in FEMA reimbursement requests for a total of $59.6 million requested to date.

UCOP has been monitoring and continues to review FEMA claim submissions on a monthly basis. Campuses were asked about whether or not they planned to revise any previously submitted HEERF claims for FEMA-eligible costs, and submit these claims to FEMA for reimbursement. We are currently following up with campuses to confirm the extent to which the FEMA-eligible costs identified by campuses will actually be submitted to FEMA for reimbursement. The Department of Education recently extended the deadline for campuses to spend remaining HEERF grants to June 30, 2023, so campuses may not be done submitting all FEMA claims until sometime closer to the final HEERF deadline.

California State Auditor's Assessment of Status: Pending

We look forward to reviewing UCOP's evaluation of its campuses' FEMA claims.

UCOP has been monitoring campus FEMA claims since April 2020. Beginning in April, 2021, UCOP began reviewing campus FEMA claims, including estimated costs, active projects, and cost recovered, on a monthly basis. When the review of campus submissions is complete, UCOP will use these monthly FEMA reports to track the progress of any additional FEMA claims that campuses will submit associated with both the CSA Audit recommendation #2 and the return to campus period beginning in Fall of 2021.

California State Auditor's Assessment of Status: Pending

As described in its responses to Recommendations 2 and 3, UCOP requested that its campuses submit reports of COVID-related lost revenue and cost impacts and is in the process of evaluating those reports. We look forward to reviewing the results of UCOP's comparison of those reports to campus submitted FEMA claims in its next response to these recommendations.

All Recommendations in 2021-611

Agency responses received are posted verbatim.