Finding Text
Federal Program: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063 and 84.268 Federal Agency: Department of Education Award Year: 2024 Criteria: Under 34 CFR 668.162, institutions must limit Title IV drawdowns to the amount needed to meet immediate disbursement needs. Funds drawn in excess of actual disbursements must be returned to the U.S. Department of Education (DOE) within three business days. Additionally, institutions must reconcile drawn funds with actual disbursements reported in the Common Origination and Disbursement (COD) system. Condition: During the course of our cash management testing, we identified the University drew down Title IV funds in excess of the amounts awarded and disbursed to students. Specifically: • Pell Grant funds totaling $64,976 and $59,913 at different points in the year were drawn but not disbursed within the required timeframe. $13,626 of this remained overdrawn as of June 30, 2024. • Direct Loan funds totaling $296,282 and $121,250 at different points in the year were drawn in anticipation of disbursements that did not occur due to student ineligibility or withdrawal. All funds had been properly distributed as of June 30, 2024. Cause: The University lacked sufficient internal controls and monitoring procedures to ensure that federal funding draws did not exceed the awarded amounts. Context: Controls did not operate properly for the University to disburse funding drawn within the required timeframe. Effect: The University has not complied with certain requirements of FSA Handbook and Federal Code of Regulations to ensure federal funds drawn did not exceed awarded amounts. Questioned Costs: $13,626 Repeat Finding: No Recommendations: The University should implement and document an overall quality assurance process including adequate controls to prevent overall noncompliance. Management's Response: Management agrees with the finding. See corrective action plan.