COVID-19 Resources for Institutes of Higher Education
May 18, 2020
As the landscape continues to evolve and shift amid the COVID-19 global pandemic daily, it is important for internal audit departments to stay abreast of emerging and elevated risks, as well as known and prospective impacts and opportunities for institutes of higher education. Internal auditors can serve as an even more valuable asset to their institutions during a time of such uncertainty; therefore, they must be aware of information and guidance available to continue to be fluid and serve the needs of their stakeholders.
ACUA (and ACUA-Sponsored) Resources
ACUA created a COVID-19 Guidance and Resources page as a starting point for members. This page includes a link to ACUA’s statement on the coronavirus, specific ACUA resources available, such as relevant Kick Starters, webinars, documents available in the Resource Library, as well as keywords to search in the Risk Dictionary. The page also highlights organizations that provide relevant and timely resources for understanding and mitigating key risks that may impact (or opportunities to enhance) an institution’s ability to achieve its mission:
- Baker Tilly – ACUA’s strategic partner has a multitude of guidance available for institutes of higher education and new articles and webinars related to the pandemic are put out consistently. Topics include business continuity (academics, administration, and operations), pandemic preparedness and communications, regulatory compliance, and so much more. These resources empower internal audit departments to focus their efforts on adding value during such uncertainty.
These resources empower internal audit departments to focus their efforts on adding value during such uncertainty.
- NACUBO – The National Association of College and University Business Officers provides the latest information on how to navigate the COVID-19 crisis. They offer resources based on guidance provided by the United States Department of Education, webcasts, updates on advocacy efforts, checklists on how to prepare for different campus scenarios, and more. NACUBO’s professional magazine, Business Officer, also includes a special section on how higher education is responding to the challenges associated with the pandemic.
- EDUCAUSE – EDUCAUSE closely monitors the COVID-19 situation and provides resources to help the higher education community manage campus disruption and assists with planning for the upcoming academic year. EDUCAUSE includes a list of resources for members about continuity planning and emergency preparedness, as well as webinars and videos addressing how institutions are responding to the crisis, best practices, and information on remote learning designs.
Other Professional Resources
Other than those highlighted above, there are several other associations/organizations that are pushing out tons of information to increase awareness about the overall pandemic environment and its impact on a variety of areas:
- The Chronicle of Higher Education – Review special reports and collections of articles related to the pandemic from a higher education-specific perspective. You can also sign-up for virtual forums about the coronavirus to help you adapt and plan. To get the latest developments, sign up for daily emails from the Academe Today newsletter. If your institution has premium access, you will get institution-specific news on a specialized page.
- Inside Higher Ed – For live, up-to-the-moment updates on the latest news available surrounding campuses and the coronavirus, visit this page frequently. Round-ups from each day are accessible and you can sign-up for daily emails here so you do not miss a beat.
- Institute of Internal Auditors – Providing general across-all-industries guidance, visit this page for resources on business continuity, risk assessment/audit plan, governance, internal audit’s role in crisis management, as well as other insights and advice. There is also an additional COVID-19 Resources Exchange equipped with articles and blogs.
- EAB – EAB supports campuses through the coronavirus crisis by providing resources on seven topic areas: enrollment, success, instruction, advancement, administration, finance, and strategy. A listing of peer policies and guidelines shows examples of what colleges/universities have in place to support institutions (e.g., long-term planning, wider community needs, research); faculty and staff (e.g., human resources, at-risk individuals, remote instruction/development); and students (e.g., grading and pass/fail, study abroad, basic student needs); as well as communication guidance (e.g., websites, social media).
Higher education will undergo three phases during this pandemic: triage, stabilize, and transform.
- Huron – Huron identified that higher education will undergo three phases during this pandemic: triage, stabilize, and transform. Daily reports are produced about the latest trends across the industry, how these trends translate to each of these phases, as well as articles and links of interest. Information is constantly updated for key impact areas: institutional finances; strategic planning; enrollment management, retention, and student experience; academic programs; operational efficiency and effectiveness; merger and acquisitions; athletics program assessment; research; and others.
Internal auditors should look holistically at their organizations and determine where they can add the most value. Some areas to specifically look at and review are:
Academics and Operations
COVID-19 completely changed the student experience for current and prospective students across the globe and uncertainties remain as to how long the impacts of transitioning to a virtual learning environment will last. Internal auditors should be thinking about the future impacts arising from these changes. For example, how will student life (e.g., academics, on-campus living, and athletics) and research handle the re-opening of campuses? Residence halls may now only have single dorm rooms and have to restrict gathering in lounges. Classrooms, research labs, dining halls, university buses, and athletic facilities might have to limit the number of students inside. Campuses might have to allow for more time between classes to accommodate for the longer commute students will have if institutions do not fill bus capacities (more students might walk now). If more students walk, will there be increased public safety issues? Will classes/labs be offered as a hybrid option (e.g., online and in-person) or will course offerings change?
It is important to note that there are many behind-the-scenes operations that go into making decisions for the situations presented above and these operations have also undergone changes during this time. Internal auditors, as trusted advisors, are in a unique position to work with academia, research, and central administration in determining the best ways to accommodate changes, in a cohesive manner. Internal auditors can step in to fill in any gaps in operations or help improve business processes so that these important decisions can be made timely.
Internal auditors, as trusted advisors, are in a unique position to work with academia, research, and central administration in determining the best ways to accommodate changes in a cohesive manner.
The resources provided by the organizations listed above will provide immense insight and guidance on risks and opportunities to consider related to these academic and operational questions. Other risk areas to consider and areas to gain more insight on during this pandemic, as well as additional useful resources are listed below. The organizations above have information on these following topics as well (so search these areas in their webpages, too).
Cybersecurity and Privacy
The shift to a mainly remote setting has increased exposure to cybersecurity and privacy risks. Such increased risks relate to network security; phishing schemes; as well as vulnerabilities from personal devices and unapproved applications/file sharing sites. Potential noncompliance with privacy laws (e.g., General Data Protection Regulation [GDPR], Health Insurance Portability and Accountability Act [HIPAA]) is greater. The IIA and Wolters Kluwer discusses these areas and how internal auditors can examine cyber risks at their institutions. The US Department of Homeland Security’s Cybersecurity & Infrastructure Security Agency (CISA) provides information on how COVID-19 is being exploited by cyber criminals and ACUA highlights CISA’s coronavirus risk management insights on its resources page. Cybersecurity pitfalls contribute to increased risks for fraud, as well.
Fraud
Higher education, among all industries, are experiencing budget constraints and losses now and for the foreseeable future. Actions are being taken to implement cost-saving measures and when this happens, fraud increases. The Association of Certified Fraud Examiners (ACFE) put out a 2020 Report to the Nations discussing occupational fraud and abuse globally. The report highlights that internal audit departments rank second-highest when it comes to how fraud is initially detected because it is one of the top three parties that whistleblowers report to. Internal audit is one of the most common anti-fraud controls organizations put in place, as they are in a position to help mitigate the main reasons fraud is committed: lack of internal controls, override of existing controls, lack of management review, and poor tone at the top. Internal audit can be a catalyst for fraud prevention at their colleges/universities by supplying fraud training to employees and being on the look-out for red flags. The ACFE has an Anti-Fraud Toolkit and provides information on common fraud schemes identified during the pandemic.
Internal audit is one of the most common anti-fraud controls organizations put in place, as they are in a position to help mitigate the main reasons fraud is committed.
Large coronavirus-related payouts (e.g., stimulus payments, loans) also increased the opportunity for fraud to occur. Grant Thornton also suggests ways to control COVID-19 fraud risks. This article also links to a prior webinar held, which analyzes how COVID-19 and the stimulus package created fraud risk, potential fraud schemes, the impact that our virtual environment has on fraud, and fraud prevention techniques.
Financial Implications and Considerations
The US federal government issued legislation related to the coronavirus to help offset some of the financial burden that higher education institutes face. The Coronavirus Aid, Relief, and Economic Security (CARES) Act provides higher education funding (Education Stabilization Fund), tax relief (employee retention tax benefits, deferrals, and loans), and student aid support. With these funds comes an increase in potential noncompliance and scrutiny, as institutions develop their own system and processes for determining how to allocate funds to students and must use funds for allowable costs. Internal auditors can help develop policies, procedures, and internal controls surrounding the allocation of these funds. Refer to the US Department of Education’s Office of Postsecondary Education for more information.
As a result of the pandemic, institutions experienced severe economic losses, resulting from refunds to students for tuition, housing, dining, and parking, as well as increased costs related to COVID-19 (e.g., sanitizing spaces, moving staff and faculty to remote work, offering leave to employees) and lost revenues (e.g., decreased enrollments and auxiliary income). Institutions also experienced some unfunded mandates from the Families First Coronavirus Response Act (FFCRA). As a result of all this, an institution will have significant budget constraints in the next fiscal years and will have to identify cost-saving measures. We, as internal auditors, are in the best position to help find cost-savings throughout all areas of a university.
Colleges and universities have several relief opportunities, such as through their insurance carriers, CARES Act and FFCRA credits, Federal Emergency Management Agency (FEMA) funding, Small Business Administration loans, among others. Internal auditors can be involved in tracking COVID-19 costs to determine which costs can be submitted through insurance carriers and which can be submitted through FEMA (no double-dipping). CliftonLarsonAllen (CLA) provides updates on opportunities and eligibility for relief funding options in its presentation materials and compares employer credits available.
Due to the provisions set forth in the CARES Act, among other COVID-19 consequences, institutions will have to consider how to account for (i.e., recognize or disclose) certain financial reporting requirements (American Institute of Certified Public Accountants [AICPA] resource). Some disclosure requirements to consider include estimates of economic effects, loss contingencies (e.g., from class action lawsuits), and subsequent events (CLA resource), to name a few. Internal auditors can provide guidance on how to assess these reporting requirements, including if there is a going concern issue.
Depending on your organization, you will follow either GASB (Governmental Accounting Standards Board) or FASB (Financial Accounting Standards Board) requirements. Internal auditors can keep an eye on what impacts the pandemic has on implementation of new or upcoming standards. For example, public institutions were preparing to, or have started to, inventory all their leases to implement GASB Statement No. 87–Leases for this upcoming fiscal year, but GASB recently issued Statement No. 95 to postpone the effective dates of certain pronouncements, including GASB 87. Internal auditors can keep note of the new effective dates to help develop a strategy for meeting these requirements later on.
COVID-19 also had an impact on federal awards for research. The Council on Government Relations (COGR) provides resources, such as a Federal Agency Guidance Matrix, clarifying if certain pandemic-related costs are allowable, such as charging salaries of idle staff, other program costs, non-refundable travel charges, pre-award and other expenses, etc. There are also additional resources linked within the matrix. Internal auditors can help assist with understanding these impacts on funding and ensuring reporting requirements are met.
Conclusion
Typically our researchers are the ones in labs analyzing molecules under a microscope. Now, we, as internal auditors, are trying to analyze with our own 'microscopes' the impact that a molecule, unseen by the human eye, is going to have on our geographically and academically vast institutions. We are becoming the researchers by continuously studying new legislation; operational, financial, and academic challenges; lessons learned; and best practices across the higher education environment related to the coronavirus. We are using our research to implement our own testing, and unlike the tests for the virus, we are hoping to get positive results—ones that add value to our institutions.
About the Authors
Jean Cineas
Jean joined Rutgers University as an associate auditor in 2017. Prior to Rutgers, he worked for the New York State Comptroller’s Office. He holds degrees in Accounting and Criminal Justice from Kean University and is pursuing a Master of...
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Jean Cineas
Jean joined Rutgers University as an associate auditor in 2017. Prior to Rutgers, he worked for the New York State Comptroller’s Office. He holds degrees in Accounting and Criminal Justice from Kean University and is pursuing a Master of Business Administration in Finance from Rutgers. Jean also volunteers for ACUA's social media sub-committee.
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COVID-19 Resources for Institutes of Higher Education
John Makropoulos
John is a senior auditor at Rutgers University and has been providing internal audit and advisory services to the university community for almost fifteen years. Prior to Rutgers, John worked at Johnson & Johnson (J&J) in various capacities...
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John Makropoulos
John is a senior auditor at Rutgers University and has been providing internal audit and advisory services to the university community for almost fifteen years. Prior to Rutgers, John worked at Johnson & Johnson (J&J) in various capacities for almost nineteen years, including international audit assignments performed at J&J companies worldwide. He is a graduate of Rider University with a Bachelor of Science in Accounting and is a Certified Public Accountant (CPA) in NJ and Certified Internal Auditor (CIA). John also volunteers for ACUA's Risk Dictionary.
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COVID-19 Resources for Institutes of Higher Education
Marilyn Carnevale
Marilyn Carnevale is a Certified Public Accountant (CPA), Certified Internal Auditor (CIA), Certified Government Financial Manager (CGFM), and Public School Accountant (PSA). She is the editor of College and University Auditor and works...
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Odir Chavez
Odir is a senior auditor at Rutgers University, joining the team in 2015. He received a Bachelor of Science in Accounting from Rutgers University–Camden and is a Certified Internal Auditor (CIA). Odir has experience performing audits in over...
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Odir Chavez
Odir is a senior auditor at Rutgers University, joining the team in 2015. He received a Bachelor of Science in Accounting from Rutgers University–Camden and is a Certified Internal Auditor (CIA). Odir has experience performing audits in over fifteen international locations across several industries in the capacity of financial, operational, and investigative work.
Articles
COVID-19 Resources for Institutes of Higher Education