Finding Text
Information on Federal Program ‒ Federal Family Education Loans Assistance Listing Number 84.032
Criteria – Compliance Requirement C – Cash Management – The University must return all excess cash
received from the U.S. Department of Education in a timely manner, if funds are not credited to an enrolled
student’s account within 3 business days following the receipt of funds.
Condition – During the audit, we noted the following:
• The University has approximately $388,000 of excess cash held in a segregated federal funds cash
account, which relates to awards from prior years.
Cause – Prior management’s lack of oversight of student financial aid in prior years. The lack of proper
oversight and insufficient internal controls resulted in excess cash received from third-party awarding
agencies, which was not properly refunded, causing the University to have excess cash on hand.
Effect – The University has excess cash on hand and was not in compliance with cash management
requirements; however, the University has the funds properly held in an identifiable federal funds cash
account, as they are currently investigating the best way to refund the excess cash.
Questioned Costs – None.
Context – We reviewed cash received and expended in a prior year, noting the University has additional
funds on hand from prior awarding years. All current year funds were properly received and disbursed with
no excess cash on hand from the current year. The University has continued to work to reconcile the excess
cash and has consolidated the accounts to review down to 4 students in 2023. This is down from 438
students in the prior year.
Indication of a Repeat Finding – This is a repeat finding 2022-001 from prior year.
Recommendation – We recommend the University enhance internal controls over compliance with cash
management requirements, as well as work with current and prior awarding agencies to determine the
appropriate course of action to return the excess cash on hand.
Views of Responsible Officials – The cash balance of federal financial aid funds does not pertain to the
currently audited year. The University is diligently ensuring that these funds continue to remain separate
while undergoing reconciliation and has safeguarded them from expenditure. Given the complexity of
reviewing each student's history, we've enlisted the expertise of an external financial aid consulting firm
experienced in reconciling FFEL loan programs.