Section III-Federal Awards Findings and Questioned Costs 2022-002 coy10-12 Higher Education Emergency Relief t'und fHEERF} Condition: Criteria: Repeat finding. The College did not have adequate internal controls in place to ensure proper record keeping for grant funds. U. S. Department of Education cash management requirements are consistent with 2 CFR 200.305 which requires a grantee minimize the time elapsing between the transfer of funds from the United States Treasury and the disbursement by the non-Federal entity. According to the Higher Education Emergency Relief Fund (HEERF) II Frequently Asked Questions (FAQ) #17, grantees must pay the incurred obligation (liquidate) within 3 calendar days for HEERF ALN 84.425F (Institutional Portion) and within 15 days for HEERF ALN 84.425E (Student Portion) of receiving the funds. The design and implementation of proper internal controls and the corresponding proper record keeping procedures are essential to comply with cash management requirements. Cause: Effect: Recommendation: Views of Responsible Officials: Corrective Action Plan: It was determined that the College drew down funds expended under both ALN 84.425E and ALN 84.425F from the wrong grants management system accounts. A portion of expenses for ALN 84.425E were drawn from and/or were recorded to the sub-fund for ALN 84.425F and a portion of expenses for ALN 84.425F were drawn from and/or were recorded to the sub-fund for ALN 84.425E. This incorrect recording resulted in substantial positive cash balances reported during the fiscal year under ALN 84.425F which were mostly offset with substantial negative cash balances reported under ALN 84.425E. However, at one point during the fiscal year, this incorrect reporting and drawing down of funds resulted in an overall substantial cash balance recorded for the combined funds." Due to a lack of properly designed and implemented internal controls, even though based on our test, there were no repeat instances of the College drawing down funds from the wrong grants, it was determined that the College has not put proper controls in place as of September 30, 2022 to sufficiently eliminate this finding in the current audit period. The College should design and implement internal controls to ensure proper record keeping for grant funds and monitor cash balances by individual grants. Management agrees with this finding and has taken corrective action. The College will ensure that employees who are responsible for the administration of the Higher Education Emergency Relief Fund (HEERF) grants are properly trained on allowable uses of those funds and on correct administrative procedures relating to the administration of these funds. This will be accomplished individually through training and education via various sources, including the U.S. Department of Education's published guidance and previously provided guidance from the Alabama Community College System. In addition to this training, additional internal control processes will be implemented to ensure that HEERF grant funds comply with cash management requirements and are liquidated within the prescribed timeframe. Additional review and approval procedures will be implemented to ensure that funds are drawn down from the correct grants management system accounts. These internal control processes, procedures and training will ensure proper record keeping for grant funds and proper monitoring of cash balances by individual grants.