Federal Agency: U.S. Department of Education Federal Program Name: Education Research, Development and Dissemination Assistance Listing Number: 84.305A Federal Award Identification Number and Year: R305A210286 - 2025 Pass-through Agency: N/A Pass-through Number: N/A Award Period: July 1, 2021 - June 30, 2026 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria: 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires recipients to comply with federal cash management standards. These standards require that federal funds be drawn only for immediate cash needs and that recipients maintain adequate internal controls, including documented review and approval, to support and authorize each drawdown request. Condition: During our testing of cash management procedures, we noted that the Organization did not maintain documentation evidencing review or approval of federal fund drawdowns. The drawdown files tested did not include evidence demonstrating that an authorized individual reviewed and approved the request prior to submission. Questioned Costs: None Context: This condition was identified during testing of drawdown transactions for the federal program. For all items selected, documentation of review or approval was not available. Cause: The Organization experienced turnover within the finance department and was operating with limited staffing resources. As a result, responsibilities were not consistently allocated, and the approval step in the drawdown process was not documented. Effect: The absence of documented review and approval for federal fund drawdowns increases the risk that draw requests may be inaccurate, unsupported, or not compliant with federal cash management requirements. Without evidence of appropriate oversight, errors or improper draws could occur and remain undetected, potentially resulting in noncompliance with federal regulations and increasing the risk of future questioned costs or enforcement actions. Repeat Finding: N/A Not a repeat finding. Recommendation: We recommend that the Organization establish and implement a formalized approval process for all federal fund drawdowns. This process should include documented review and approval by an authorized individual prior to the submission of each draw request. The Organization should also ensure adequate staffing and clear assignment of responsibilities within the finance department to maintain proper segregation of duties and consistent oversight. Implementing these procedures will strengthen internal controls, reduce the risk of inaccuracies or unauthorized draws, and promote full compliance with federal cash management requirements. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to Research For Action, Inc.'s Corrective Action Plan