Report 2021-611 All Recommendation 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 for Legislative Action

If the CSU Chancellor's Office and UCOP do not ensure that their respective campuses submit eligible expenses incurred in response to the pandemic to FEMA for reimbursement, the Legislature should direct the CSU Chancellor's Office and UCOP to do so or explain why submitting these claims was not feasible.

Description of Legislative Action

As of October 27, 2022, the Legislature has not taken action to address this specific recommendation.

California State Auditor's Assessment of Status: No Action Taken

Recommendation #2 To: University of California

To encourage campuses to obtain additional federal funds that allow them to maximize student services and aid, UCOP should direct each of its respective campuses to submit a report summarizing all expenses incurred in response to the pandemic between January 2020 and December 31, 2021 and identifying any expenses that are eligible for FEMA reimbursement.

On January 11, 2022, UCOP asked each campus to provide a summary report of total COVID cost impacts incurred since the start of the pandemic, and to provide details of how it used HEER funds and any claims submitted, pending, or proposed to FEMA for reimbursement. As part of this report, campuses were further asked to identify any additional FEMA-eligible expenses that they used HEERF or other funds to cover.

California State Auditor's Assessment of Status: Fully Implemented

The UCOP requested that its campuses submit summary reports describing their total general campus (excluding medical centers) COVID-related lost revenue and cost impacts for the period of January 2020 to December 31, 2021.

Recommendation #3 To: University of California

To encourage campuses to obtain additional federal funds that allow them to maximize student services and aid, UCOP should review and evaluate the campuses' reports described in recommendation #2 to ensure that they are consistently identifying expenses eligible for FEMA reimbursement.

UCOP reviewed the information submitted by campuses, and identified instances where there appeared to be variation in FEMA claims submitted by campuses in certain categories of expenses. Campuses were asked to review those areas to determine if there were additional FEMA-eligible claims to be submitted.

California State Auditor's Assessment of Status: Fully Implemented

UCOP obtained information on the UC campuses' COVID expenses and FEMA claims, and provided documentation showing that it followed up with some campuses regarding their FEMA-eligible expenses.

In the template provided to campuses, UCOP provided a list of FEMA-eligible cost categories for campuses to use in reporting of any FEMA claims and/or eligible costs. UCOP received campus submissions on February 11, 2022, and is currently in the process of reviewing and evaluating the reports. As part of its review, UCOP will share information about each campus location's claims by FEMA cost categories to ensure that there is consistency in both identifying and submitting claims to FEMA.

California State Auditor's Assessment of Status: Pending

As described in its response to Recommendation 2, UCOP requested that its campuses submit reports of COVID-related lost revenue and cost impacts. UCOP states that it is in the process of evaluating those reports. We look forward to reviewing the results of that evaluation in UCOP's next response to these recommendations.

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.

Recommendation #5 To: University of California

In the event of a future emergency federal student aid program that lacks detailed criteria regarding how funds are to be awarded, such as an allocation of additional pandemic-related funds under current requirements, UCOP should provide guidance on the priorities and processes for distributing student aid so that its campuses can consistently distribute funds to students in similar situations.

Effective February 9, 2022, a new process has been established for review and approval of any campus emergency grant spending plans. The process has four steps: 1) systemwide Education Financing Model Steering Committee defines the criteria for spending plans, including target populations for additional support, 2) UCOP releases a template for reporting campus spending plans, 3) review by the Executive Director for Student Financial Support, and 4) final approval by the Vice President of Graduate, Undergraduate and Equity Affairs at UCOP.

California State Auditor's Assessment of Status: Fully Implemented

The University of California Office of the President established a process for the review and approval of campuses' spending plans in the event of future emergency grant funding.

Recommendation #6 To: University of California

UCOP should assist campuses with obtaining federal funds intended to support the success of minority students by creating an initiative to promote obtaining U.S. Department of Education status as Asian American and Native American Pacific Islander-serving institutions at those UC campuses that meet the demographic requirement.

A UC-wide initiative to support campuses in their efforts to attain federal AANAPISI status has been established by UCOP. The systemwide AANAPISI committee comprised of campus representatives has been meeting since February to exchange information about current AANAPISI designation applications and funding opportunities. Thus far, the Initiative has sponsored two high-level discussions between UC campus representatives and leaders in the federal administration to help inform us on AANAPISI and other MSI criteria, funding status, and future directions for the programs. These include:

1) On April 13, 2022, the initiative hosted a webinar for the campuses that featured two lead administrators in the US Department of Education on Minority-Serving Institutions and experts on AANAPISI issues - Beatriz Ceja, HSI Division Director, US Department of Education, and James Laws, Title III Part A Programs - Strengthening Institutions, U.S. Department of Education.

2) In collaboration with the UC HSI Initiative, the UC AANAPISI initiative participated in an April 20, 2022, discussion with Melody Gonzalez and Emmanuel Caudillo, of the White House Initiative on Advancing Educational Equity, Excellence, and Economic Opportunity for Hispanics. Minority-serving institutions initiatives, including AANAPISI efforts. The meeting was joined by Undersecretary James Kvaal who requested to address the group.

An all-UC, systemwide AANAPISI-focused retreat is being planned for fall 2022.

California State Auditor's Assessment of Status: Fully Implemented

UCOP has developed a system-wide AANAPISI committee and held various meetings related to obtaining MSI status.

Planning for a UC-wide initiative to assist eligible UC campuses with applying for AANAPISI status commenced in February 2022. Launched by UCOP's Graduate, Undergraduate and Equity Affairs (GUEA) and modeled after UCOP's Hispanic-Serving Institutions initiative, the UC AANAPISI Initiative will be tailored to the specific criteria and goals of the U.S. Department of Education's administered ANNAPISI program. It will be led by UC scholars, administrators and students with expertise and knowledge of best practices for supporting Asian American and Native American Pacific-Islander student success. GUEA will host a systemwide workshop for all UC campuses on the requirements and process for seeking AANAPISI status in April 2022.

California State Auditor's Assessment of Status: Pending

UCOP states that it has begun planning for the initiative described in our recommendation, but has not completed the process. We look forward to reviewing supporting documentation regarding this initiative when the UCOP provides its next response regarding this recommendation.

Recommendation #7 To: University, California State

To encourage campuses to obtain additional federal funds that allow them to maximize student services and aid, the CSU Chancellor's Office should direct each of its campuses to submit a report summarizing all expenses incurred in response to the pandemic between January 2020 and December 31, 2021 and identifying any expenses that are eligible for FEMA reimbursement.

The Chancellor's Office has recommended that campuses review all expenses incurred in response to the pandemic between January 2020 and December 31, 2021 and identify any expenses that are eligible for FEMA reimbursement. To ensure transparency regarding the California State University's (CSU's) use of federal funds, the CSU publishes the status of HEERF and FEMA reimbursement claims on its transparency site at https://stories.opengov.com/csu/published/Hcw9zYmBD. The status of these reimbursement requests is updated weekly.

California State Auditor's Assessment of Status: Will Not Implement

We stand by our recommendation. We identified roughly $6 million in potential FEMA-reimbursable costs through a review of HEERF expenses at only three of the 23 CSU campuses. There are likely additional pandemic related expenses at other CSU campuses that are eligible for FEMA reimbursement, as well as pandemic related expenses that were not reimbursed through HEERF. The millions of dollars in potential FEMA reimbursements that campuses have not claimed suggests that the CSU Chancellor's Office should take a more proactive role in ensuring that its campuses obtain these federal funds. Further, the Chancellor's Office's reference to the status of HEERF and FEMA claims is not relevant. Our concern lies with those expenses that have not been submitted for FEMA reimbursement.

Recommendation #8 To: University, California State

To encourage campuses to obtain additional federal funds that allow them to maximize student services and aid, the CSU Chancellor's Office should review and evaluate the campuses' reports described in recommendation #7 to ensure that they are consistently identifying expenses eligible for FEMA reimbursement.

Each campus has the responsibility and authority to identify expenses eligible for reimbursement from HEERF and FEMA. An additional review as recommended is not cost effective.

California State Auditor's Assessment of Status: Will Not Implement

We stand by our recommendation. The millions of dollars in potential FEMA reimbursements that campuses have not claimed suggests that the CSU Chancellor's Office should take a more proactive role in ensuring that its campuses obtain these federal funds. Further, it is not clear how the Chancellor's Office has determined that an additional review is not cost effective. The Chancellor's Office has not provided a cost estimate for such a review; however, we identified roughly $6 million in potential FEMA-reimbursable costs at only three of the 23 CSU campuses, and there are likely additional pandemic related expenses at the other CSU campuses that are eligible for FEMA reimbursement.

Recommendation #9 To: University, California State

To encourage campuses to obtain additional federal funds that allow them to maximize student services and aid, the CSU Chancellor's Office 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.

Each campus has the responsibility and authority to identify expenses eligible for reimbursement from HEERF and FEMA. In addition, the business and finance team at the Chancellor's Office provides administrative leadership, updates, and advice to campuses who have questions about these funds. Finally, to ensure transparency regarding the California State University's (CSU's) use of federal funds, the CSU publishes the status of HEERF and FEMA reimbursement claims on its transparency site at https://stories.opengov.com/csu/published/Hcw9zYmBD. The status of these reimbursement requests is updated weekly.

California State Auditor's Assessment of Status: Will Not Implement

The Chancellor's Office notes that it provides administrative leadership and advice to the campuses. Thus, it is unclear why it objects to steps intended to encourage campuses to obtain additional funds and maximize student services. Further, the Chancellor's Office's reference to the status of HEERF and FEMA claims is not relevant. Our concern lies with those expenses that have not been submitted for FEMA reimbursement. Therefore, we stand by our recommendation.

Recommendation #10 To: University, California State

In the event of a future emergency federal student aid program that lacks detailed criteria regarding how funds are to be awarded, such as an allocation of additional pandemic-related funds under current requirements, the CSU Chancellor's Office should provide guidance on the priorities and processes for distributing student aid so that its campuses can consistently distribute funds to students in similar situations.

If the hypothetical event suggested in the recommendation should occur, the Chancellor's Office (CO) will provide guidance to the campuses on the priorities and processes for distributing student aid. In addition, we will incorporate any further requirements from the awarding agency to ensure compliance.

With regard to the subject matter of this audit, the campuses have fully complied with the terms and conditions laid out by the granting agency, as well as the guidance on the priorities and processes provided by the CO. The State Auditor recommends a different approach to managing the CSU. The CO will continue to support the campuses' ability to make the decisions that are in the best interest of their campus and student population.

California State Auditor's Assessment of Status: Will Not Implement

We observed wide variations in how campuses distributed HEERF student-aid, and question whether these inconsistencies were in the best interests of the respective campuses' student populations. Had the CSU Chancellor's Office provided more detailed guidance on how campuses should distribute the student-aid, the campuses might have prioritized students in similar situations more consistently. Because it is the systemwide office's role to coordinate activities among its respective campuses, we stand by our recommendation. Finally, as detailed in our report, in some cases CSU campuses did not fully comply with the terms and conditions laid out by the granting agency.

Recommendation #11 To: Chico, California State University

To maximize the available HEERF funds, CSU Chico should review expenses it incurred in response to the pandemic since January 2020 and submit all eligible expenses to FEMA for reimbursement. The campus should reallocate any HEERF funds initially spent for these expenses to other purposes, such as replacing lost revenue or providing additional student aid.

CSU, Chico continues to monitor all COVID-related expenses and assess whether eligible expenses should be submitted for reimbursement under FEMA or HEERF. The campus will continue to consult with the Chancellor's Office and subject matter experts as needed and weigh decisions based on the information available and the costs/benefits of each option, including the need for prompt and reliable financial relief.

California State Auditor's Assessment of Status: Will Not Implement

We stand by our recommendation that the campus should review its pandemic related expenses and submit all eligible expenses to FEMA for reimbursement. FEMA expanded its criteria for reimbursable expenses and the campus should take advantage of this opportunity to maximize the federal funds it receives for responding to the COVID-19 pandemic. This would allow the campus to reallocate HEERF funds to other purposes, such as replacing lost revenue or providing additional student aid.

Recommendation #12 To: Chico, California State University

To ensure that CSU Chico complies with the U.S. Department of Education guidance, it should compile a specific list of housing and dining refunds reimbursed with HEERF funds and review the transactions to ensure that they were eligible for reimbursement.

CSU, Chico reviewed housing and dining refunds reimbursed with HEERF funds and verified they were eligible for reimbursement.

California State Auditor's Assessment of Status: Fully Implemented

CSU Chico provided a list of the specific housing and dining refunds it paid for with HEERF funds and asserted that it ensured the refunds were eligible for reimbursement with these funds.

Recommendation #13 To: Long Beach, California State University

To maximize the available HEERF funds, CSU Long Beach should review expenses it incurred in response to the pandemic since January 2020 and submit all eligible expenses to FEMA for reimbursement. The campus should reallocate any HEERF funds initially spent for these expenses to other purposes, such as replacing lost revenue or providing additional student aid.

CSU Long Beach continues to monitor all COVID-related expenses and assess whether eligible expenses should be submitted for reimbursement under FEMA or HEERF. The campus will continue to consult with the Chancellor's Office and subject matter experts as needed and weigh decisions based on the information available and the costs/benefits of each option, including the need for prompt and reliable financial relief.

California State Auditor's Assessment of Status: Will Not Implement

We stand by our recommendation that the campus should review its pandemic related expenses and submit all eligible expenses to FEMA for reimbursement. FEMA expanded its criteria for reimbursable expenses and the campus should take advantage of this opportunity to maximize the federal funds it receives for responding to the COVID-19 pandemic. This would allow the campus to reallocate HEERF funds to other purposes, such as replacing lost revenue or providing additional student aid.

CSU Long Beach continues to monitor all COVID-related expenses and assess whether eligible expenses should be submitted for reimbursement under FEMA or HEERF. The campus will continue to consult with the Chancellor's Office and subject matter experts as needed and weigh decisions based on the information available and the costs/benefits of each option, including the need for prompt and reliable financial relief.

California State Auditor's Assessment of Status: Will Not Implement

We stand by our recommendation that the campus should review its pandemic related expenses and submit all eligible expenses to FEMA for reimbursement. FEMA expanded its criteria for reimbursable expenses and the campus should take advantage of this opportunity to maximize the federal funds it receives for responding to the COVID-19 pandemic. This would allow the campus to reallocate HEERF funds to other purposes, such as replacing lost revenue or providing additional student aid.

Recommendation #14 To: University of California, Merced

To maximize the available HEERF funds, UC Merced should review expenses it incurred in response to the pandemic since January 2020 and submit all eligible expenses to FEMA for reimbursement. The campus should reallocate any HEERF funds initially spent for these expenses to other purposes, such as replacing lost revenue or providing additional student aid.

We have submitted FEMA claim for Jan 2020 -December 2020. During that annual year we only had $11K of potential FEMA eligible cost on HEERF. At this point the $11K will not be submitted for FEMA as the cost of submitting new claim for this period exceed the benefit for campus. We are in the process of reviewing expenses for Jan 2021 to December 2021 and within next 90 days will determine next steps and resources needed to increase claim with FEMA.

California State Auditor's Assessment of Status: Pending

We look forward to reviewing UC Merced's analysis of its pandemic-related expenses and how it determined which costs are eligible for FEMA reimbursement.

We have removed the FMMA eligible cost such as testing from Heerf for expenses incurred in FY21/22 and beyond.

California State Auditor's Assessment of Status: No Action Taken

UC Merced's response relates to expenses incurred since July 2021. Further, it did not provide its analysis of past costs. We look forward to reviewing its analysis of its past pandemic-related expenses, its determination of which costs are eligible for FEMA reimbursement, or an explanation for why it is not feasible to submit some or all of these eligible costs.

We have removed the FMMA eligible cost such as testing from Heerf for expenses incurred in FY21/22 and beyond.

California State Auditor's Assessment of Status: Pending

UC Merced did not provide its analysis of its pandemic-related expenses, its determination of which costs are eligible for FEMA reimbursement, or documentation of its claims for reimbursement or an explanation for why it is not feasible to submit them. Nor did it provide adequate justification for why it is not addressing costs incurred before fiscal year 2021-22. We have requested this information from the campus.

We have submitted FEMA claim for Jan 2020 -December 2020. During that annual year we only had $11K of potential FEMA eligible cost on HEERF. At this point the $11K will not be submitted for FEMA as the cost of submitting new claim for this period exceed the benefit for campus. We are in the process of reviewing expenses for Jan 2021 to December 2021 and within next 90 days will determine next steps and resources needed to increase claim with FEMA.

California State Auditor's Assessment of Status: Pending

We look forward to reviewing UC Merced's analysis of calendar year 2021 pandemic-related expenses, its determination of which costs are eligible for FEMA reimbursement, and documentation of its claims for reimbursement or an explanation for why it is not feasible to submit them.

Recommendation #15 To: University of California, Merced

To ensure that UC Merced receives all available federal funds, its office of student affairs should monitor its emails for grant award notifications and develop policies and procedures to review all federal award announcements to determine whether it is named as a recipient.

The Procedure memo regarding the Government funding opportunity that outlined the process was shared on 11.6.2023.

California State Auditor's Assessment of Status: Fully Implemented

UC Merced has since reviewed the internal process and we have in place the process that our government relations lead will notify campus partners on the availability of federal grants and funding.

California State Auditor's Assessment of Status: Pending

We requested a copy of the policy manual that the document UC Merced provided us is a part of, but have not yet received the requested evidence.

UC Merced has since reviewed the internal process and we have in place the process that our government relations lead will notify campus partners on the availability of federal grants and funding.

California State Auditor's Assessment of Status: Pending

We requested UC Merced provide documents and policies that support its assertion; however, the campus did not provide this documentation. We look forward to reviewing supporting documentation when the campus provides its next response regarding this recommendation.

Recommendation #16 To: University of California, Merced

To comply with federal regulation, UC Merced should promptly spend the remainder of its CARES MSI funds and return the interest earned on those funds in excess of $500 to the federal government.

On December19,2022, the payment #96158 was issued to US for $1908.75

California State Auditor's Assessment of Status: Partially Implemented

As the report describes, in November 2020 UC Merced transferred $967,000 in CARES MSI funds into its account, but at the time of our audit it had not yet spent $265,000 of those funds. According to federal regulation, UC Merced must pay to the federal government the interest in excess of $500 that it earned on those funds. The documents UC Merced provided suggest that it still has not spent $258,000 of those funds. Although it has paid interest to the federal government of $1,908.75, it needs to promptly spend the remainder of the funds it was granted and remit to the federal government any additional interest it has earned.

The grant is still not fully expended. We will calculate the actual amount of interest in excess of $500 at the end of the grant and will provide the interest based on process outlined in the link : https://www2.ed.gov/documents/funding-101/g5-returning-interest.pdf.

California State Auditor's Assessment of Status: Pending

UC Merced stated that it has not yet fully spent this grant. We will review its calculation of the interest owed to the U.S. Department of Education and obtain verification that this amount was repaid when the grant has been fully expended or the grant period ends.

We will calculate the actual amount of interest in excess of $500 at the end of the grant and will provide the interest based on process outlined in the link : https://www2.ed.gov/documents/funding-101/g5-returning-interest.pdf.

California State Auditor's Assessment of Status: Pending

We look forward to reviewing the campus calculation of interest owed to the U.S. Department of Education and verification that this amount was submitted. UC Merced did not identify the end of the grant period in this response.

Recommendation #17 To: University of California, Merced

To ensure that UC Merced complies with the U.S. Department of Education guidance, it should compile a specific list of housing and dining refunds reimbursed with HEERF funds and review the transactions to ensure that they were eligible for reimbursement.

This file has been provided and we consider this item completed.

California State Auditor's Assessment of Status: Resolved

UC Merced provided a list of specific housing, parking, and dining refunds. This addresses the portion of our recommendation that pertains to compiling a list of specific refunds UC Merced reimbursed with HEERF funds. However, we do not consider the portion of the recommendation that pertains to reviewing those transactions to have been implemented. When we asked how UC Merced ensured that these transactions were eligible for reimbursement, it provided us with an explanation of how it originally identified transactions before it issued refunds. This process did not prevent an instance in which a student was refunded in excess of what they should have been, as described in our report. Further, we do not have assurance that Merced has identified other students who might have been provided refunds in excess of the amount they should have been. Nevertheless, because additional time has elapsed and we recognize the difficulty involved in requesting repayment now, we consider this recommendation to be resolved.

This file has been provided and we consider this item completed.

California State Auditor's Assessment of Status: Partially Implemented

Although UC Merced provided a list of specific refunds it paid for with HEERF funds, it did not describe how, or whether, it ensured that the refunds were eligible for reimbursement with these funds.

Recommendation #18 To: University of California, San Diego

To maximize the available HEERF funds, UC San Diego should review expenses it incurred in response to the pandemic since January 2020 and submit all eligible expenses to FEMA for reimbursement. The campus should reallocate any HEERF funds initially spent for these expenses to other purposes, such as replacing lost revenue or providing additional student aid.

UCSD has submitted to the CSA all project worksheets which have been submitted to FEMA for reimbursement, which include Wastewater Testing (Project 691680), Diagnostic Testing (Project 696380), in addition to previously provided FEMA Claims for Vaccination Administration (668425) and Quarantine Housing (670251). This documentation contains transaction-level detail of expenditures submitted to FEMA for reimbursement. We also have provided analysis of pandemic-related expenses are eligible, for FEMA reimbursement. Based on the above, UCSD considers this recommendation to be fully implemented.

California State Auditor's Assessment of Status: Fully Implemented

UC San Diego provided its worksheets and analysis of its pandemic-related expenses, and its determination of which costs are eligible for FEMA reimbursement.

UCSD has submitted to the CSA all project worksheets which have been submitted to FEMA for reimbursement, which include Wastewater Testing (Project 691680), Diagnostic Testing (Project 696380), in addition to previously provided FEMA Claims for Vaccination Administration (668425) and Quarantine Housing (670251). This documentation contains transaction-level detail of expenditures submitted to FEMA for reimbursement. We also have provided analysis of pandemic-related expenses are eligible, for FEMA reimbursement. Based on the above, UCSD considers this recommendation to be fully implemented.

California State Auditor's Assessment of Status: Fully Implemented

UC San Diego provided its worksheets and analysis of its pandemic-related expenses, and its determination of which costs are eligible for FEMA reimbursement.

UCSD has evaluated the $4,359,000 identified in the CSA Audit that was previously reimbursed against HEERF, in consultation with consultant Disaster Recovery Services (DRS), to determine if any would be eligible for submission to FEMA. These expenses were reimbursed using HEERF I grant funding. The HEERF I grant to UCSD was closed May 5, 2021 prior to the issuance of the Federal Register Notice dated April 4, 2022, which provided an automatic extension for all open grants issued under HEERF. The Federal Register Notice stated that "Accordingly, the Department is extending the performance period on all HEERF grants through June 30, 2023. This extension does not apply to grants that are closed or in the closeout process, nor does it apply to grants that have an award balance of $1,000 or less." Because the HEERF I grant to UCSD has expired and was not extended, DRS and our external auditors have advised UCSD that the $4,359,000 that was previously reimbursed against HEERF cannot be reallocated to FEMA.

Since our last update, UCSD has evaluated the spending noted in the audit that was originally planned for HEERF, and submitted to FEMA eligible expenses on Project Worksheets for Vaccine Administration (Project Worksheet 3) and Quarantine Activities (Project Worksheet 4). Further, UCSD has identified all FEMA eligible expenses related to COVID Testing and DRS is using this to complete the Project Worksheet for submittal to FEMA. Supporting documentation will be provided.

UCSD is committed to seeking reimbursement of future pandemic related expenses through the FEMA process, to the extent possible and allowable under FEMA. HEERF funding will not be used to reimbursement UCSD for future pandemic related costs that can otherwise be reimbursed by FEMA.

Based on the above, UCSD considers this recommendation to be fully implemented.

California State Auditor's Assessment of Status: Partially Implemented

UCSD identified the amounts of its pandemic-related expenses that it believes are eligible, ineligible, or of undetermined eligibility for FEMA reimbursement. However, it is not clear which of these costs it will submit for FEMA reimbursement. We look forward to reviewing UCSD's reimbursement requests after they are submitted to FEMA.

UCSD has taken a comprehensive approach to evaluating COVID related expenditures for FEMA eligibility and submitting for reimbursement when deemed appropriate and compliant. As the word of public assistance funding became available, UCSD began to identify broad categories of COVID-19 expenditures that were potentially eligible for FEMA reimbursement. Once a category was identified, the general ledger transactions were downloaded and provided to a third-party contractor, Disaster Recovery Services (DRS), for review to determine if the expenses would be eligible for FEMA reimbursement. DRS reviewed each line item of the UCSD report and, in accordance with federal regulations, applied FEMA policy and guidance. We believe that the approach was effective for identifying expenditures that were potentially reimbursable under FEMA and seeking reimbursement in a timely manner.

The audit identified $4,359,000 in HEERF funds that had been spent on expenditures that were potentially FEMA eligible, and $36,318,000 in planned HEERF spending on expenditures that were potentially FEMA eligible. UCSD has re-evaluated the $36,318,000 in planned HEERF spending and have reallocated those funds for submittal to FEMA for reimbursement, where appropriate. Specifically, UCSD has incorporated these expenditures into Project Worksheets that have been submitted to FEMA relating to quarantine housing (approximately $4 million), and will be incorporating the remaining planned expenditures into Project Worksheets relating to Vaccination Costs (approximately $1.4M) and COVID Testing and Wastewater monitoring (potentially $46M). UCSD has provided the expenditure detail supporting the $4,359,000 that was previously reimbursed against HEERF to DRS to determine if any would be eligible for reallocation to FEMA. Results of this review will be available in the next 90-day update.

California State Auditor's Assessment of Status: Pending

We look forward to reviewing UC San Diego's analysis of its pandemic-related expenses.

UCSD continues to actively work with campus departments to gather the supporting documentation (purchase orders, invoices, proof of payment) on Project Worksheets for Vaccination Costs and Quarantine Housing for students. Two additional pools of expenses are being reviewed for FEMA eligibility by the campus in consultation with Disaster Recovery Services, which will include expenses related to COVID Testing and Wastewater monitoring. The Department of Education issued an automatic extension of HEERF grantees' performance period, extending the deadline to use HEERF funding through June 30, 2023

California State Auditor's Assessment of Status: Pending

We look forward to reviewing UC San Diego's analysis of its pandemic-related expenses, its determination of which costs are eligible for FEMA reimbursement, and documentation of its claims for reimbursement or an explanation for why it is not feasible to submit them.

UCSD is actively working with campus departments to gather the supporting documentation (purchase orders, invoices, proof of payment) on two Project Worksheets for Vaccination Costs ($3.1M) and Quarantine Housing for students ($2.6M). The next two pools of expenses are being reviewed for FEMA eligibility by the campus in consultation with Disaster Recovery Services, which will include expenses related to COVID Testing and Wastewater monitoring (potentially $46M). UCOP requested a HEERF/FEMA plan update from each campus, which UCSD provided on February 11, 2022. UCOP plans to compile the information and share with campuses in March 2022.

UCSD has also contacted its HEERF Program & Management Analyst to request a No Cost Extension to extend the deadline to submit claims to May 2023. The HEERF Program & Management Analyst has instructed UCSD to submit a justification letter by the end of March 2022, and this letter is in process as of the date of this update

California State Auditor's Assessment of Status: Pending

UC San Diego describes a number of steps it has taken to identify costs incurred in response to the pandemic and its attempts to obtain FEMA reimbursement. However, it is not clear whether the campus is reviewing all pandemic-related expenses or only those related to certain projects or purposes. To ensure that it maximizes the federal funds it receives for responding to the COVID-19 pandemic, the campus should thoroughly review all of its actual and planned pandemic related expenses, determine which are eligible for FEMA reimbursement, and submit claims for those expenses. We look forward to reviewing documentation of the steps that UC San Diego takes to ensure it submits eligible HEERF expenditures to FEMA for reimbursement.

Recommendation #19 To: University of California, San Diego

To allow UC San Diego to apply for funds to expand its capacity to serve its minority students, it should immediately develop an interim plan for supporting its Asian American and Native Pacific Islander student population and apply for MSI status during the next available application cycle.

UCSD has previously received an MSI designation in February 2022. UCSD has also completed an interim plan outlining the steps that are being taken to support the AANAPISI student population while the formal plan is still under review by leadership.

California State Auditor's Assessment of Status: Fully Implemented

UCSD received AANAPISI MSI designation, and it provided its interim plan to support its Asian American and Native Pacific Islander student population. Although its response indicates that it has not yet applied for federal funds to support this population, we consider this recommendation to be fully implemented, because it has applied for a waiver and obtained the MSI designation.

In January 2022, UCSD submitted an AANAPISI eligibility designation application to the Department of Education, which was approved by the DOE in February 2022. UCSD is now AANAPISI eligible. UCSD established a task force to develop a formalized plan to support the AANAPISI student population, which is anticipated to be approved by UCSD leadership near the end of calendar year 2022. In the meantime UCSD is drafting an interim plan, which should be completed by August 2022, outlining the steps that are being taken to support the AANAPISI student population while the formal plan is still under review by leadership.

California State Auditor's Assessment of Status: Pending

We look forward to reviewing UC San Diego's plan to support its its Asian American and Native Pacific Islander student population.

In January 2022, UCSD submitted an AANAPISI eligibility designation application to the Department of Education. Supporting documents to be emailed: Submitted fy22.pdf, UCSD Waiver 2 2022.pdf and UCSD Waiver 2 2022.pdf. UCSD anticipates that a response will be received by late Spring 2022.

California State Auditor's Assessment of Status: Partially Implemented

UC San Diego received an MSI designation in February 2022 based on its Asian American and Native Pacific Islander student population. However, UC San Diego did not address the portion of our recommendation suggesting that it establish a plan for supporting its Asian American and Native Pacific Islander student population, the absence of which it referenced as a rationale for its previous failure to apply for MSI funds. We look forward to reviewing that plan upon its completion.

Recommendation #20 To: University of California, San Diego

To ensure that UC San Diego complies with the U.S. Department of Education guidance, it should compile a specific list of housing and dining refunds reimbursed with HEERF funds and review the transactions to ensure that they were eligible for reimbursement.

UCSD has identified the specific set of students and housing credits for the $9.3M of housing refunds paid out in the Spring 2020 Quarter, which were determined to be eligible for reimbursement. The complete list of housing refunds will be submitted via email. UCSD will keep this set list in an Audit file for any upcoming requests for supporting documentation.

California State Auditor's Assessment of Status: Fully Implemented

UC San Diego provided a list of the specific housing and dining refunds it paid for with HEERF funds and asserted that it ensured the refunds were eligible for reimbursement with these funds.

Recommendation #21 To: University of California, Riverside

To ensure that UC Riverside complies with the U.S. Department of Education guidance, it should compile a specific list of housing and dining refunds reimbursed with HEERF funds and review the transactions to ensure that they were eligible for reimbursement.

A list of specific housing and dining refunds reimbursed with HEERF funds that occurred during the audit period was provided to the state auditors on 10/19/2021 along with the confirmation of eligibility; the documentation was resent on 10/29/2021. No other refunds have been processed or are planned to be processed.

California State Auditor's Assessment of Status: Fully Implemented

UC Riverside provided a list of the specific housing and dining refunds it paid for with HEERF funds and asserted that it ensured the refunds were eligible for reimbursement with these funds.

All Recommendations in 2021-611

Agency responses received are posted verbatim.