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We recommend that the Assistant Secretary for the Office of Postsecondary Education require LESC to update its written policies and procedures to contain sufficient detail to ensure that (1) all the steps necessary to verify student eligibility and distribute funds to students under the CARES Act and subsequent coronavirus legislations are addressed and completed, (2) funding determinations are adequately documented and supported in accordance with 2 C.F.R. § 200.302, and (3) students with exceptional need are prioritized in accordance with CRRSAA and ARP.

Regarding LESC’s decision to reallocate the amounts we questioned in this finding, we recommend that the Assistant Secretary for the Office of Postsecondary Education review the reallocated funds and determine whether LESC’s use of $710,274 of Lincoln’s Institutional grant funds to write off unpaid accounts receivable for students, who withdrew from the school due to coronavirus, was allowable and for the intended purposes of applicable coronavirus relief legislation.

If LESC’s reallocation of Lincoln’s Institutional grant funds is deemed unallowable, we recommend that the Assistant Secretary for the Office of Postsecondary require LESC to return to the Department the $700,155 of Lincoln’s Institutional grant funds that LESC improperly applied to credit student accounts for rent students paid to third-party landlords and the $9,838 that LESC improperly spent for subscriptions extending beyond the grant performance period and determine if these issues occurred at LESC’s other schools and take corrective action as appropriate.

We recommend that the Assistant Secretary for the Office of Postsecondary Education require LESC to incorporate in its policies and procedures the cash management requirements for minimizing the time between drawing down and disbursing Federal grant funds, including HEERF funds, maintaining the funds in an interest-bearing account, and remitting interest earned more than $500 in accordance with 2 C.F.R. § 200.305(b).

We recommend that the Assistant Secretary for the Office of Postsecondary Education determine whether LESC accurately calculated interest and properly remitted the interest returned in January 2021, in accordance with 2 C.F.R. § 200.305(b)(9).