Finding 1191829 (2025-007)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2025
Accepted
2026-03-30
Audit: 395639
Organization: Lincoln University (MO)

AI Summary

  • Core Issue: The University is not minimizing the time between drawing down funds and using them, leading to improper fund management.
  • Impacted Requirements: Cash management practices under 2 CFR Section 200.305 are inadequate, resulting in $178,325 in questioned costs.
  • Recommended Follow-Up: The University should revise its policies to ensure timely fund utilization and proper allocation to the correct awards.

Finding Text

Higher Education Institutional Aid, ALN 84.031 U.S. Department of Education Program Year 2024 - 2025 Criteria or specific requirement - Cash Management 2 CFR Section 200.305 Condition - The time between the University's draw down of funds from the Department of Education and utilization of those funds was not minimized. The University drew funds for another Department of Education program against the Title III award. Cause - The administration and finance department does not have adequate processes and controls around cash management to ensure time elapsed between the draw down and expenditure of the grant funds is minimized. Additionally, adequate processes and controls are not in place to ensure funds are drawn from the appropriate award. Effect or potential effect - The University drew down $174,553 of funds that were not substantiated by program expenditures. The University drew down $3,772 from the Title III award for non-Title III program costs. Questioned costs - $178,325 Context - Out of a population of 15 Title III draw downs, a sample of three draws were selected for testing. Our sample was not, and was not intended to be statistically valid. For one of the draws tested, the amounts drawn exceeded the program expenditures charged to the award resulting in an excessive draw. Additionally, amounts for expenditures for a non- Title III program were drawn against the Title III award. Identification as a repeat finding - N/A Recommendation - The University should review its policies and procedures regarding draw down of grant funds to ensure they are minimizing the time between draw down and utilization of the funds and ensure draws are for the applicable award.

Corrective Action Plan

We acknowledge the auditor's finding regarding the timing of federal drawdowns and the draw down of Title III funds for expenditures related to another Department of Education program. We recognize that the drawdown of $174,553 exceeded substantiated program expenditures and that $3,772 was drawn down from the Title III award for non-Title III costs. The root cause of this issue was insufficient processes and controls within the administration and finance department related to cash management and award-specific drawdown procedures. These gaps contributed to delays between drawdown and expenditure, as well as the misallocation of drawdowns to the incorrect award. To address the findings, Lincoln has implemented the following corrective measures: • Revised Cash Management Procedures: We have updated our federal drawdown procedures to ensure compliance with the requirement to minimize the time between drawdown and disbursement of funds. Drawdowns will be calculated on a reimbursement basis and tied directly to documented, allowable, and incurred expenditures. • Award-Specific Drawdown Controls: We have implemented a mandatory pre-draw review process requiring reconciliation of expenditures to the correct award prior to any drawdown request. This includes a secondary review by the Comptroller. • Staff Training: All personnel involved in grant accounting and cash management have completed refresher training on federal cash management requirements, including the distinction between awards and the importance of accurate allocation. • Monthly Internal Reconciliations: We have instituted monthly reconciliations of drawdowns to expenditures for all federal awards to ensure accuracy and timely correction of discrepancies. The corrective measures above are designed to ensure full compliance with federal cash management regulations and to prevent future occurrences of excessive or misallocated drawdowns.

Categories

No categories assigned yet.

Other Findings in this Audit

  • 1191815 2025-001
    Material Weakness Repeat
  • 1191816 2025-001
    Material Weakness Repeat
  • 1191817 2025-002
    Material Weakness Repeat
  • 1191818 2025-002
    Material Weakness Repeat
  • 1191819 2025-003
    Material Weakness Repeat
  • 1191820 2025-003
    Material Weakness Repeat
  • 1191821 2025-004
    Material Weakness Repeat
  • 1191822 2025-004
    Material Weakness Repeat
  • 1191823 2025-005
    Material Weakness Repeat
  • 1191824 2025-005
    Material Weakness Repeat
  • 1191825 2025-006
    Material Weakness Repeat
  • 1191826 2025-006
    Material Weakness Repeat
  • 1191827 2025-007
    Material Weakness Repeat
  • 1191828 2025-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $7.47M
84.268 FEDERAL DIRECT STUDENT LOANS $6.87M
84.063 FEDERAL PELL GRANT PROGRAM $5.83M
10.512 EXTENSION SERVICES AT 1890 COLLEGES AND TUSKEGEE UNIVERSITY, WEST VIRGINIA STATE COLLEGE, AND CENTRAL STATE UNIVERSITY $4.45M
10.205 PAYMENTS TO 1890 LAND-GRANT COLLEGES AND TUSKEGEE UNIVERSITY $4.35M
84.031 HIGHER EDUCATION INSTITUTIONAL AID $3.86M
10.237 FROM LEARNING TO LEADING: CULTIVATING THE NEXT GENERATION OF DIVERSE FOOD AND AGRICULTURE PROFESSIONALS $1.28M
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $594,410
11.028 CONNECTING MINORITY COMMUNITIES PILOT PROGRAM $498,995
10.912 ENVIRONMENTAL QUALITY INCENTIVES PROGRAM $311,699
10.937 PARTNERSHIPS FOR CLIMATE-SMART COMMODITIES $269,479
84.033 FEDERAL WORK-STUDY PROGRAM $193,676
10.303 INTEGRATED PROGRAMS $149,968
10.307 ORGANIC AGRICULTURE RESEARCH AND EXTENSION INITIATIVE $116,513
10.443 OUTREACH AND ASSISTANCE FOR SOCIALLY DISADVANTAGED AND VETERAN FARMERS AND RANCHERS $111,343
10.514 EXPANDED FOOD AND NUTRITION EDUCATION PROGRAM $108,264
81.049 OFFICE OF SCIENCE FINANCIAL ASSISTANCE PROGRAM $103,350
93.569 COMMUNITY SERVICES BLOCK GRANT $97,000
10.310 AGRICULTURE AND FOOD RESEARCH INITIATIVE (AFRI) $90,038
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $86,815
47.070 COMPUTER AND INFORMATION SCIENCE AND ENGINEERING $84,327
12.431 BASIC SCIENTIFIC RESEARCH $83,340
66.436 SURVEYS, STUDIES, INVESTIGATIONS, DEMONSTRATIONS, AND TRAINING GRANTS AND COOPERATIVE AGREEMENTS - SECTION 104(B)(3) OF THE CLEAN WATER ACT $72,818
10.935 URBAN AGRICULTURE AND INNOVATIVE PRODUCTION $70,537
81.087 RENEWABLE ENERGY RESEARCH AND DEVELOPMENT $67,746
10.202 COOPERATIVE FORESTRY RESEARCH $64,765
10.210 HIGHER EDUCATION NATIONAL NEEDS GRADUATE FELLOWSHIP GRANTS $57,128
16.525 GRANTS TO REDUCE DOMESTIC VIOLENCE, DATING VIOLENCE, SEXUAL ASSAULT, AND STALKING ON CAMPUS $51,248
10.186 REGIONAL FOOD BUSINESS CENTERS $31,776
10.523 CENTERS OF EXCELLENCE AT 1890 INSTITUTIONS $30,974
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $28,712
59.037 SMALL BUSINESS DEVELOPMENT CENTERS $27,609
10.025 PLANT AND ANIMAL DISEASE, PEST CONTROL, AND ANIMAL CARE $26,638
10.971 URBAN AGRICULTURE AND URBAN COUNTY COMMITTEE OUTREACH, TECHNICAL ASSISTANCE, AND EDUCATION $25,936
10.520 AGRICULTURE RISK MANAGEMENT EDUCATION PARTNERSHIPS COMPETITIVE GRANTS PROGRAM $24,138
10.229 EXTENSION COLLABORATIVE ON IMMUNIZATION TEACHING & ENGAGEMENT $22,016
47.074 BIOLOGICAL SCIENCES $21,426
10.311 BEGINNING FARMER AND RANCHER DEVELOPMENT PROGRAM $21,320
10.309 SPECIALTY CROP RESEARCH INITIATIVE $18,950
10.147 OUTREACH EDUCATION AND TECHNICAL ASSISTANCE $18,220
12.630 BASIC, APPLIED, AND ADVANCED RESEARCH IN SCIENCE AND ENGINEERING $16,658
47.049 MATHEMATICAL AND PHYSICAL SCIENCES $10,311
10.515 RENEWABLE RESOURCES EXTENSION ACT $9,887
10.170 SPECIALTY CROP BLOCK GRANT PROGRAM - FARM BILL $8,748
10.215 SUSTAINABLE AGRICULTURE RESEARCH AND EDUCATION $7,000
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $5,772
84.425 EDUCATION STABILIZATION FUND $5,680
10.500 COOPERATIVE EXTENSION SERVICE $5,663
10.216 1890 INSTITUTION CAPACITY BUILDING GRANTS $5,600
10.328 FOOD SAFETY OUTREACH PROGRAM $5,556
47.084 NSF TECHNOLOGY, INNOVATION, AND PARTNERSHIPS $5,244
10.727 INFLATION REDUCTION ACT URBAN & COMMUNITY FORESTRY PROGRAM $3,830
47.041 ENGINEERING $2,849
43.008 OFFICE OF STEM ENGAGEMENT (OSTEM) $24
10.524 SCHOLARSHIPS FOR STUDENTS AT 1890 INSTITUTIONS $-1,675