Corrective Action Plan – The Chicago School
Identifying Number: 2024-001
Finding: Excess Cash – Student Financial Aid
Applicable Regulation:
According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federa...
Corrective Action Plan – The Chicago School
Identifying Number: 2024-001
Finding: Excess Cash – Student Financial Aid
Applicable Regulation:
According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period.
Finding:
The College had excess cash for the Federal Direct Student Loan program, ranging from $528,450 to $1,238,306, from November 13, 2023, to December 18, 2023. While the excess cash did not exceed the one-percent tolerance of prior year drawdowns, the amounts were not returned within the seven-day period as required.
Summary:
The College draws a portion of funds for student stipends while award reconciliation is in progress to ensure timely disbursement. An administrative oversight led to excess cash being held longer than allowed. Specifically, the prior stipend drawdown was not netted out when calculating subsequent fund requests, resulting in excess cash being held for 24 business days.
Corrective Action Planned or Taken:
1. Procedure Update: The College has updated its cash management procedures to ensure compliance with the seven-day return requirement.
2. Process Change: Going forward, the College will refrain from drawing funds for student stipends until reconciliations have been fully completed. This will ensure that funds are drawn in alignment with actual disbursement needs, reducing the risk of excess cash.
3. Internal Control Strengthening: The College will enhance internal controls around cash management to ensure that excess cash instances are identified and corrected promptly.
4. Staff Training: All relevant staff will undergo training on revised cash management procedures and the importance of timely reconciliation and returns.
5. Improved Monitoring: The College will implement a more robust monitoring process to track excess cash and ensure compliance with Federal regulations, including daily checks during peak disbursement periods.
Contact Person:
Theresa Cowan, Associate Vice President, Compliance and Student Finance
tcowan@tcsedsystem.edu
Anticipated Completion Date:
December 16, 2024