Finding 381196 (2023-002)

Significant Deficiency
Requirement
C
Questioned Costs
-
Year
2023
Accepted
2024-03-19

AI Summary

  • Core Issue: Funds were not disbursed quickly enough after being drawn from the G-5 system, violating federal regulations.
  • Impacted Requirements: Schools must disburse funds within specific timeframes: 15 days for Student Aid and 3 days for other Institutional Aid.
  • Recommended Follow-up: The University should improve procedures for fund drawdowns to ensure compliance with federal timing requirements.

Finding Text

HEERF INSTITUTIONAL AID SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUE) YEAR ENDED JUNE 30, 2023 CASH MANAGEMENT FINDING NO. 2023-002 – TIME ELAPSING BETWEEN THE TRANSFER OF FUNDS CRITERIA Schools must minimize the time elapsing between the transfer of funds from ED and disbursement by the school for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). What constitutes minimized elapsed time for funds transfer will depend on what payment system/method a school uses. Under the advance payment method, payment is made to the school before the school disburses the funds for program purposes (2 CFR section 200.3). Some schools’ grants may have been placed on Route Pay or Stop Pay Status, as indicated by a notification the grantee would have received from ED. This requires ED approval of a spending plan prior to the grantee drawing down funds or the submission of single requests with documentation. For CRRSAA HEERF II and ARP HEERF III, the Certification and Agreement and/or Supplemental Agreement indicate that Student Aid (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from ED’s grant management system (G5), while Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within 3 calendar days of the drawdown from G5. CONDITION During our field work in the cash management area, we noted funds that were requested to G-5 but not disbursed by UPM to minimize the time elapsing between the transfer of funds and disbursement as follows: Description Dates Amount Funds receceived from G-5 on June 8, 2022 6/8/2022 $610,710.35 Funds disbursed during 2022-2023 Fiscal year 2022-23 (525,362.27) Available balance from funds received in 6/8/2022 6/30/2023 $ 75,348.08 Funds receceived from G-5 on June 22, 2023 6/22/2023 $319,251.71 Funds disbursed at the end of fiscal year 2022-2023 6/30/2023 ( 45,000) Available balance from funds received in 6/22/2023 6/30/2023 $274,251.71 HEERF INSTITUTIONAL AID SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUE) YEAR ENDED JUNE 30, 2023 CASH MANAGEMENT (CONTINUE) FINDING NO. 2023-002 – TRANSFER OF FUNDS BEYOND THE REQUIRED TIME LIMITS EFFECT The drawdowns of Federal funds made by UPM not minimized the time elapsing between transfer of funds and the disbursement by the university according to regulations. QUESTIONED COSTS $0.00 CAUSE This situation occurred due to UPM did not make adequate follow up to the cash advances received from G-5 RECOMMENDATION The University should reinforce the procedures the drawdown of funds to comply with the regulation applicable for the transfer of funds through the G-5 system. VIEWS OF RESPONSIBLE OFFICIALS See the Corrective Action Plan for details of action required.

Corrective Action Plan

FINDING NO. 2023-002 - TRANSFER OF FUNDS BEYOND THE REQUIRED TIME LIMITS CONDITION During our field work in the cash management area, we noted funds that were requested to G-5 but not disbursed by UPM to minimize the time elapsing between the transfer of funds and disbursement as follows: Descriotion Dates Amount Funds received from G-5 on June 8, 2022 6/8/2022 $610,710.35 Funds disbursed during 2022-2023 Fiscal vear 2022-23 (525,362.27) Available balance from funds received in 6/8/2022 6/30/2023 $75,348.08 Funds received from G-5 on June 22, 2023 6/22/2023 $319,251.71 Funds disbursed at the end of fiscal year 2022- 2023 6/30/2023 (45,000) Available balance from funds received in 6/22/2023 6/30/2023 $274,251.71 RECOMMENDATION The University should reinforce the procedures the draw down of funds to comply with the regulation applicable for the transfer of funds through the G-5 system. Corrective Action Plan: "Corrective Action Plan: UPM acknowledges that recommendation 2023-002 by Mr. Santiago is correct; however, the Dean of Administration and Finance, who assumed this position on February 21, 2023, wishes to explain the reasons behind this occurrence. UPM managed the HEERF funds without prior experience and knowledge of their administration. The officials at that time were unclear about the rules and procedures for managing these funds because the contract details were not received by UPM, preventing them from establishing spending and disbursement policies. Additionally, UPM was without a president for 6 months, and after appointing a president, it operated for approximately a year without a permanent Dean of Administration and Finance. The employees in the Dean's office were not authorized for this level of decision-making, while time continued to pass. Furthermore, there were several changes in the members of our Higher Education Council. As soon as the Dean of Administration and Finance was appointed, consultations with the president were held to make decisions regarding the disbursement and expenses of these funds, which were implemented in June 2023. As a corrective action plan for the future, we will review all certifications related to federal funds management, prepare a comprehensive folder, and administer these funds while adhering to each of these measures. We will proactively identify our needs and align them with the award, clearly defining each process and protocol with the intention of compliance." During the last fiscal year. the Council of Theological Education approved new regulations for: 1. Regulation for the Acquisition of Equipment, Materials, and Non-Personal Services at UPM. 2. Regulation for the Administration of Movable Property (Equipment) at the UPM. hese new regulations complement the existing rules to ensure the integrity, preservation, accessibility, legibility, and legality of our financial actions. We will continue to work together to standardize our processes and address any non-compliance on our part.

Categories

Cash Management

Other Findings in this Audit

  • 381197 2023-003
    Material Weakness
  • 957638 2023-002
    Significant Deficiency
  • 957639 2023-003
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425e Higher Education Emergeny Relief Fund Student Portion $655,687
84.425F Higher Education Emergency Relief Fund Institutioanl Portion $570,562
84.063 Federal Pell Grant Program $415,842
84.007 Federal Supplemental Educational Opportunity Grant $8,638
84.033 Federal Work Study Program $7,139
97.036 Disater Grant Public Assistance Presidencially Declared Disasters $43