Finding Text
Finding No.: 2024-010 – Cash Management Identification of the federal program: Federal Agency: U.S. Department of Education AL No. and Title: 84.063 Federal Pell Grant Program Federal Award No.: P063Q194572, P063Q204572, P063Q214572, P063Q224572, P063Q234572, P063P224572, P063P234572, P063P244572 Criteria or specific requirement (including statutory, regulatory or other citation): The College’s Program Participation Agreement indicates that the College is placed on the Heightened Cash Monitoring (HCM) Payment Method. Based on the U.S. Department of Education (ED)’s publication, the College is placed on HCM1 Payment Method for the quarters ended December 1, 2023, March 1, 2024, June 1, 2024, and September 1, 2024. Under the HCM Payment Method, an institution must credit a student’s account for the amount of Title IV funds the student is eligible to receive and pay the amount of any credit balance due before the institution submits a request for funds or seeks reimbursement. Under HCM1 Payment Method, after making a disbursement to eligible students from institutional funds and submitting disbursement records to the Common Origination and Disbursement (COD) system, the institution draws down funds to cover those disbursements through G5 the same way as an institution on the Advance Payment Method. Condition: The College did not provide a complete detailed listing of expenditures supporting the drawdowns during the year. Cause: The College lacks adequate internal control policies and procedures over compliance with applicable federal regulations related to cash management requirements, specifically, monitoring actual disbursements of drawdowns. Effect or potential effect: We are unable to determine whether the College is in compliance with applicable cash management requirements. Questioned costs: Undeterminable Context: Due to the nature of the finding, we are unable to quantify the extent of noncompliance. We identified 42 cash drawdowns during the year totaling $7,296,185. The College did not provide a complete detailed listing of expenditures supporting the following drawdowns: Identification as a repeat finding, if applicable: 2023-013 Recommendation: College management should establish written policies and procedures over cash management requirements, including monitoring of actual disbursements of drawdowns. Views of responsible officials: The College agrees with the finding and provides details in its Corrective Action Plan.