The following is the Management's Response to Auditor's Findings, Summary Schedule of Prior Audit Findings and Corrective Action Plan. This document was prepared by management of the University of Oklahoma.
2024-001 Student Financial Assistance Cluster, ALN 84.063 Federal Pell Grant Program and ALN ...
The following is the Management's Response to Auditor's Findings, Summary Schedule of Prior Audit Findings and Corrective Action Plan. This document was prepared by management of the University of Oklahoma.
2024-001 Student Financial Assistance Cluster, ALN 84.063 Federal Pell Grant Program and ALN 84.268 Federal Direct Student Loans, Department of Education, Award Year 2024
Criteria or Specific Requirement - Cash Management, 34 CFR 668.162(b)(3)
Finding Summary: For institutions on the Advance Payment Method, Title IV funds not disbursed to recipients by the end of the third business day are considered excess cash. The Department of Education (ED) allows an institution to retain, for up to seven days, excess cash that does not exceed one percent of the total amount of funds drawn by the institution in the prior year. The institution must return to ED any excess cash over the tolerable amount (one percent) and any amount remaining after the tolerance period (seven days). From February 20, 2024 to April 9, 2024, total cash drawdowns for student financial aid consistently exceeded aid disbursements to recipients (expenditures) by an amount less than one percent of prior year drawdowns. The excess cash during this period was not returned to ED within seven days.
Explanation of Agreement/Disagreement: Management concurs with the finding and has implemented additional controls within the drawdown process that includes a secondary review and approval of the amount and timing of each drawdown.
Officials Responsible for Ensuring Corrective Action: Karen Smith, Assistant Vice President for Administration and Finance and Controller
Planned Completion for Corrective Action: Excess cash was no longer on hand as of June 30, 2024. Corrective internal controls have been implemented as of October 1, 2024 to prevent further instances of noncompliance.
Plan to Monitor Completion of Corrective Action: Management has implemented controls within the drawdown process that includes a secondary review and approval of the amount and timing of each drawdown. This will ensure that limits are not exceeded and, if there are instances that require a return of funds, provide oversight to ensure the timely return of those funds.