Finding Text
Finding 2025-003 – U.S. Department of Education (ED) – Federal Work-Study - Noncompliance With Cash Management (Material Weakness): Information on the federal program –Federal Work-Study, FAL No. 84.033, June 30, 2025. Criteria – The Uniform Guidance (§200.305(b)) requires non-Federal entities to minimize the time elapsing between the drawdown of federal funds and the disbursement of those funds for program purposes. For the Federal Work-Study Program, institutions are required to draw federal funds only as funds are needed to reimburse allowable student payroll costs and related employer share expenses and to promptly disburse or return excess federal funds. Condition – As of June 30, 2025, the College reported excess federal cash of $415,971 related to the Federal Work-Study Program. The excess cash represented cumulative federal funds drawn down through the federal payment system that were not disbursed for allowable Federal Work-Study payroll costs as of year-end. The excess cash balance included amounts related to prior award years that had not been fully liquidated through reimbursement of allowable student wage expenditures or returned to the U.S. Department of Education as of June 30, 2025. Cause – The excess cash condition resulted from insufficiently effective cash-management monitoring controls over the Federal Work-Study Program. While allowable payroll expenditures were incurred and supported, cumulative federal draw activity was not adjusted on a sufficiently timely basis to ensure ongoing compliance with 2 CFR §200.305(b). Effect - As a result, the College held federal funds for an extended period beyond immediate program needs, resulting in noncompliance with federal cash-management requirements. Holding excess federal cash increases the risk that federal funds are not administered in accordance with applicable regulations and oversight expectations. Questioned Costs – $415,971 Repeat Finding – Yes. Auditor’s Perspective – From the auditors’ perspective, the excess federal cash balance identified represents a material weakness in cash-management controls over the Federal Work-Study Program. Although the College incurred allowable and supported Federal Work-Study payroll expenditures, routine cash-management procedures did not sufficiently ensure that federal funds were drawn only as needed and promptly liquidated. Government Auditing Standards and the Uniform Guidance emphasize the importance of effective monitoring controls to prevent the accumulation of excess federal cash and to ensure compliance with cash-management requirements. Auditor’s Recommendations – The auditors recommend that the College implement and document routine cash-management reconciliation procedures for the Federal Work-Study Program. At a minimum, reconciliations should be performed regularly between federal drawdowns, allowable payroll expenditures, and amounts subject to liquidation or return. Management review and approval of these reconciliations should be documented to ensure ongoing compliance with 2 CFR §200.305(b). Views of Responsible Officials – The College requests drawdowns for the Federal Work- Study Program on a reimbursable basis, including review and approval procedures. Of the total amount identified, $26,466 related to FY 2025, with the balance relating to prior year(s) activity. The College will review its Federal Work-Study Program cost allocation procedures to ensure all eligible costs are properly identified and supported. The College has engaged two accounting firms to assist with staff training and bring all reconciliations current. In addition, standard month-end and year-end closing procedures will be implemented to address timely, accurate Federal Work-Study Program reconciliations and audit readiness going forward.