Finding Text
Finding 2023-004 – C. Cash Management
Information on Federal Program(s) - Federal Pell Grant Program (ALN 84.063)
Criteria or Specific Requirement - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)).
Condition – An instance was identified where funds drawn were held in excess of the allowable time frame.
Cause - Administrative oversight.
Effect or Potential Effect - The University was not in compliance with Cash Management requirements.
Questioned Costs – None.
Context – During our audit procedures, we noted the following:
• 1 instance of cash held in excess of the allowable time frame for the Federal Pell Grant Program for the year ended June 30, 2023
Indication of Repeat Finding - There was no similar finding identified in the prior year.
Recommendation – We recommend the University enhance its procedures to ensure that excess cash is returned timely.
Views of Responsible Officials – The University has formalized and documented financial processes to establish internal controls in order to ensure accurate, timely and consistent reporting. In addition, this has created a reasonable transition plan during employee turnover, as well as ensures proper and timely filings. The corrective action involves drawing down the funds from the G5 federal website and issuing refunds to students that day. There is a checks and balance process built in so multiple staff members are involved with the process. The financial aid department calculates the amount of a federal drawdown and relays that information to the business department. The senior accountant draws down the appropriate amount of federal financial aid. The student accounts billing coordinator applies the aid to the various student accounts in the software. After the aid has been applied, the student account billing coordinator determines if a refund is due to the students. Any students that are entitled to a refund will be cut a refund check that day. The students will then have a window of opportunity of to come pick up the refund checks. Within 2 business period, any students who have not picked up their refund checks will have them mailed to their address on file with the University. This process has been developed to ensure that students receive their refunds in a timely and accurate manner.