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Require the University of Cincinnati to develop and implement a review process to prevent or detect payment errors when awarding emergency financial aid grants to students, including written policies and procedures detailing how the reviews shall be conducted and the results documented, in accordance with 2 C.F.R. section 200.303.

Require the University of Cincinnati to develop and implement written policies, procedures, and management review to ensure that its award determinations, eligibility criteria, and management decisions related to eligibility for its emergency financial aid grants to students are adequately documented and supported at the time award decisions are made, in accordance with 2 C.F.R. section 200.302(b)(3).

Require the University of Cincinnati to carefully document how its student aid eligibility criteria prioritized and continues to prioritize students with exceptional need throughout the HEERF grant performance period.

Require the University of Cincinnati to develop and implement written policies and procedures, including procedures that would identify and prevent improper revenue recognition and duplicate charges, to ensure that future calculations for charging lost revenue to its HEERF Institutional grant are reviewed for accuracy and consistency with its financial reporting policies and procedures.

Determine whether the University of Cincinnati implemented appropriate corrective actions to resolve the $797,965 in unsupported lost revenue costs it charged to its HEERF Institutional grant; and, if the corrective actions are inappropriate, require the University to either return the funds to the Department or reallocate the funds for allowable expenditures.

Determine whether the $1,916,041 that the University of Cincinnati charged to its HEERF Institutional grant for noncompetitive procurements was reasonable when compared to the costs of suitable alternatives; and, if the charges were inappropriate, require the University to either return the funds to the Department or reallocate the funds for allowable expenditures.

Require the University of Cincinnati to develop and implement written policies and procedures to ensure that procurements charged to its HEERF Institutional grant are in accordance with applicable Federal requirements; and it consistently follows its procurement policies and procedures, including maintaining sufficient documentation to support its rationale for noncompetitive procurements and the basis for and reasonableness of the contract price.

Require the University of Cincinnati to incorporate in its policies and procedures and implement the cash management requirements for minimizing the time between drawing down and disbursing Federal grant funds, and remitting interest earned in excess of $500 in accordance with 2 C.F.R. section 200.305(b).

Require the University of Cincinnati to remit $35,439 based on the TIP’s average rate of return, less no more than $320 ($500 minus the $180 already retained) for administrative expenses if applicable; and remit the actual amount of earned interest on any future advances of Federal funds, in accordance with 2 C.F.R. section 200.305(b)(9).

Require the University of Cincinnati to develop and implement written policies and procedures that incorporate the HEERF program’s reporting requirements and ensure that the expenditures in its quarterly HEERF Institutional expenditure reports are accurate and reported in the appropriate expenditure category.