Finding 1240244 (2025-004)

Material Weakness Repeat Finding
Requirement
CL
Questioned Costs
-
Year
2025
Accepted
2026-10-10

AI Summary

  • Core Issue: The University improperly drew down $30,568 in Federal funds for future payroll costs, violating cash management requirements.
  • Impacted Requirements: Federal funds must only be requested for actual, allowable expenditures incurred at the time of the drawdown.
  • Recommended Follow-Up: Strengthen cash management procedures to ensure drawdowns are based on incurred costs; implement reconciliations and management reviews before requests.

Finding Text

Finding 2025-004 – U.S. Department of Education (ED) – Title III Program-Noncompliance With Cash Management, (Significant Deficiencies): Information on the federal program – Strengthening Historically Black Colleges and Universities (HBCU), ALN 84.031B, June 30,2025. Criteria – Under 2 CFR § 200.305, non-Federal entities must request Federal funds only for allowable program costs that have been incurred and must maintain supporting documentation available at the time of the drawdown demonstrating: 1. Actual, allowable expenditures existed at the time Federal funds were drawn; and 2. Records supporting the nature and timing of those expenditures were maintained and readily available for review. These requirements ensure that drawdowns reflect immediate cash needs supported by verifiable program expenditures. Condition – One (1) of eight (8) drawdowns tested for the Title III program was not based on actual expenditures incurred at the time the drawdown was requested. Audit testing determined that the University drew down $30,568 to fund a future payroll cycle more than fifteen (15) days before payroll costs were earned and incurred. As a result, Federal funds were requested in advance of immediate cash needs and were not supported by allowable program expenditures existing at the time of the drawdown. Cause – The condition occurred because the University did not have adequate procedures to ensure payroll expenditures included in drawdown requests had been incurred prior to requesting Federal funds. Management review controls did not detect that the drawdown included future payroll costs that had not yet been earned by employees. Effect – The University held Federal funds in advance of actual program expenditures, which is not consistent with the requirement that advance payments be limited to immediate cash needs. This condition increased the risk of excess Federal cash on hand, questioned costs, and noncompliance with Federal cash management requirements. Questioned Costs – $0. Repeat Finding – No. Auditor’s Perspective – From the auditors' perspective, the University's controls over cash management were not operating effectively to ensure that Federal drawdowns were based on allowable expenditures incurred and immediate cash needs. Specifically, the University drew down $30,568 for a future payroll cycle more than fifteen (15) days before the related payroll costs were earned and incurred. The lack of procedures to verify that expenditures had been incurred prior to requesting Federal funds resulted in noncompliance with Federal cash management requirements. Because this exception was identified in one of eight drawdowns tested, the deficiency increased the risk that Federal funds could be drawn and held in advance of program needs without timely detection. Auditor's Recommendation – We recommend that the University strengthen its cash management procedures to ensure that Federal drawdown requests are based solely on allowable expenditures that have been incurred as of the drawdown date. Prior to submitting a draw request, grant and finance personnel should reconcile requested amounts to supporting payroll records, general ledger expenditures, or other documentation evidencing incurred costs. In addition, management should perform and document a review of all drawdown requests to verify that requested funds are limited to the program's immediate cash needs and do not include future payroll or other anticipated expenditures. View of Responsible Officials – Management agrees with the finding. See the accompanying Corrective Action Plan for the University's planned corrective actions, responsible officials, and implementation dates.

Corrective Action Plan

Federal Program / Assistance Listing Number (ALN) 84.031 Finding Reference Number 2025-004 1. Finding Summary The auditor noted one (1) of eight (8) drawdowns tested for the Title III program were requested in advance of expenditures incurred. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that during the year, we were notified that the Federal 05 system was scheduled for shutdown, which would block all access to Federal drawdowns. At that time, the University had already incurred, or was expected to incur, expenditures under the Title III program. To ensure timely payment to our Title III staff we expedited our procurement process and identified the necessary amount to cover payroll before the 05 shutdown. After subsequently learning that the Title III program would remain unaffected by the 05 shutdown, we decelerated our procurement process, refunded the drawn funds and resumed normal operations to avoid any cash management non-compliance issues. 3. Root Cause Analysis The root cause was an isolated incidence during an anticipated government shutdown. 4. Corrective Action(s) The early drawdown of federal funds was made in anticipation of a potential federal government shutdown to ensure sufficient funding would be available to support ongoing program operations and avoid disruptions in funding during the anticipated shutdown period. The funds were immediately reconciled upon receipt, and the University confirmed that the drawdown was appropriately accounted for. Description of Corrective Actions The University will draw down Federal funds based on documented cash needs, anticipated eligible expenditures, and applicable federal requirements, while documenting extraordinary circumstances. 5. Risk Mitigation (Required - Even if Disagreeing) The University institution recognizes the importance of drawing down Title III funds in accordance with Federal guidelines. 6. Responsible Party • Office/Department: Title III Office • Title of Responsible Official: Interim Title III Director • Name (optional): ____________ _ 7. Implementation Timeline • Corrective action implemented: IZI Yes D No • If not fully implemented, expected completion date: 8. Status of Corrective Action (For Prior-Year or Repeat Findings) D Fully implemented D Partially implemented D Not yet implemented Evidence of Implementation 9. Monitoring and Sustainability The University will continue is monitoring procedures to ensure Title III funds are drawn down in accordance with Federal guidelines.

Categories

Cash Management

Other Findings in this Audit

  • 1240228 2025-003
    Material Weakness Repeat
  • 1240229 2025-003
    Material Weakness Repeat
  • 1240230 2025-003
    Material Weakness Repeat
  • 1240231 2025-003
    Material Weakness Repeat
  • 1240232 2025-003
    Material Weakness Repeat
  • 1240233 2025-003
    Material Weakness Repeat
  • 1240234 2025-003
    Material Weakness Repeat
  • 1240235 2025-003
    Material Weakness Repeat
  • 1240236 2025-003
    Material Weakness Repeat
  • 1240237 2025-003
    Material Weakness Repeat
  • 1240238 2025-003
    Material Weakness Repeat
  • 1240239 2025-003
    Material Weakness Repeat
  • 1240240 2025-003
    Material Weakness Repeat
  • 1240241 2025-003
    Material Weakness Repeat
  • 1240242 2025-003
    Material Weakness Repeat
  • 1240243 2025-003
    Material Weakness Repeat
  • 1240245 2025-005
    Material Weakness Repeat
  • 1240246 2025-006
    Material Weakness Repeat
  • 1240247 2025-006
    Material Weakness Repeat
  • 1240248 2025-006
    Material Weakness Repeat
  • 1240249 2025-006
    Material Weakness Repeat
  • 1240250 2025-007
    Material Weakness Repeat
  • 1240251 2025-007
    Material Weakness Repeat
  • 1240252 2025-007
    Material Weakness Repeat
  • 1240253 2025-007
    Material Weakness Repeat
  • 1240254 2025-008
    Material Weakness Repeat
  • 1240255 2025-008
    Material Weakness Repeat
  • 1240256 2025-008
    Material Weakness Repeat
  • 1240257 2025-008
    Material Weakness Repeat
  • 1240258 2025-009
    Material Weakness Repeat
  • 1240259 2025-009
    Material Weakness Repeat
  • 1240260 2025-009
    Material Weakness Repeat
  • 1240261 2025-009
    Material Weakness Repeat
  • 1240262 2025-010
    Material Weakness Repeat
  • 1240263 2025-010
    Material Weakness Repeat
  • 1240264 2025-010
    Material Weakness Repeat
  • 1240265 2025-010
    Material Weakness Repeat
  • 1240266 2025-011
    Material Weakness Repeat
  • 1240267 2025-011
    Material Weakness Repeat
  • 1240268 2025-011
    Material Weakness Repeat
  • 1240269 2025-011
    Material Weakness Repeat
  • 1240270 2025-012
    Material Weakness Repeat
  • 1240271 2025-012
    Material Weakness Repeat
  • 1240272 2025-012
    Material Weakness Repeat
  • 1240273 2025-012
    Material Weakness Repeat
  • 1240274 2025-013
    Material Weakness Repeat
  • 1240275 2025-013
    Material Weakness Repeat
  • 1240276 2025-013
    Material Weakness Repeat
  • 1240277 2025-013
    Material Weakness Repeat
  • 1240278 2025-014
    Material Weakness Repeat
  • 1240279 2025-014
    Material Weakness Repeat
  • 1240280 2025-014
    Material Weakness Repeat
  • 1240281 2025-014
    Material Weakness Repeat
  • 1240282 2025-015
    Material Weakness Repeat
  • 1240283 2025-015
    Material Weakness Repeat
  • 1240284 2025-015
    Material Weakness Repeat
  • 1240285 2025-015
    Material Weakness Repeat
  • 1240286 2025-016
    Material Weakness Repeat
  • 1240287 2025-016
    Material Weakness Repeat
  • 1240288 2025-016
    Material Weakness Repeat
  • 1240289 2025-016
    Material Weakness Repeat
  • 1240290 2025-017
    Material Weakness Repeat
  • 1240291 2025-017
    Material Weakness Repeat
  • 1240292 2025-017
    Material Weakness Repeat
  • 1240293 2025-017
    Material Weakness Repeat
  • 1240294 2025-018
    Material Weakness Repeat
  • 1240295 2025-018
    Material Weakness Repeat
  • 1240296 2025-018
    Material Weakness Repeat
  • 1240297 2025-018
    Material Weakness Repeat
  • 1240298 2025-019
    Material Weakness Repeat
  • 1240299 2025-019
    Material Weakness Repeat
  • 1240300 2025-019
    Material Weakness Repeat
  • 1240301 2025-019
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $4.67M
84.063 FEDERAL PELL GRANT PROGRAM $3.57M
11.028 CONNECTING MINORITY COMMUNITIES PILOT PROGRAM $566,939
84.031 HIGHER EDUCATION_INSTITUTIONAL AID $445,997
93.658 FOSTER CARE_TITLE IV-E $212,366
84.033 FEDERAL WORK-STUDY PROGRAM $88,615
47.076 EDUCATION AND HUMAN RESOURCES $65,481
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $37,012
93.307 MINORITY HEALTH AND HEALTH DISPARITIES RESEARCH $14,994
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $11,071
47.083 INTEGRATIVE ACTIVITIES $4,382