The purpose of this report is to share with the Department observations made by the OIG concerning institutions of higher education (IHE) that ceased to provide educational instruction in all programs of study (closed) and received or had access to coronavirus response and relief aid through the Higher Education Emergency Relief Fund (HEERF).
We found that 17 IHEs that closed on or before December 31, 2020, applied for and were awarded more than $4.9 million of HEERF grants. Of these 17 IHEs, 14 drew down HEERF funds, and 8 of these 14 IHEs made drawdowns after the IHE closure date listed in the Department’s Postsecondary Education Participants System. The total of these post-closure drawdowns was more than $1.2 million. In addition, 1 of the 14 closed IHEs that drew down funds withdrew more than $364,700 just 1 day before closing. Neither the CARES Act nor any subsequent legislation authorizing HEERF grants expressly prohibit closed IHEs from being eligible for HEERF grants. However, the CARES Act and the Department’s related Frequently Asked Questions seem to set the expectation that HEERF funds would be used to help students continue in their programs of study and allow IHEs to adapt to providing continued instruction during the pandemic.
We made three suggestions, including that the Department review HEERF grants already made to verify that the IHEs that were allocated, awarded, or drew down funds had not closed. If awards were made to closed IHEs, determine whether those IHEs were eligible for the HEERF grants; recover any funds received by ineligible, closed IHEs; and ensure closed IHEs used HEERF grant funds in accordance with the uses outlined in their Funding Certification and Agreement.
Implementing Pandemic Relief Laws
This is one of several reports the OIG has issued involving HEERF. Find other reports on our Pandemic Relief page.