Finding 2022-003: Information on the Federal Program: 84.42SF - Higher Education Emergency Relief Fund - institutional Portion, 84.42SE- Higher Education Emergency Relief Fund - Student Portion Compliance Requirement: Cash Management Type of Finding: Material Weakness Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statutes, regulations, and the terms and conditions of the award. Additionally, under HEERF award, grantees are under an obligation to minimize the time between drawing down funds from GS and paying obligations incurred by the grantee (liquidation). If a HEERF grantee is using HEERF grant funds to make financial aid grants to students, the Department may evaluate for compliance with the rule grantees who have not drawn down the funds from GS and not paid the obligations (the financial aid grants to students) to the students within fifteen calendar days. The Supplemental Agreement published by the U.S. Depaitment of Education pe1tammg to Supplemental Grant Funds identifies that funds not disbursed within 3 days of being drawn down may be subject to heightened scrutiny by the U.S. Department of Education, the institution's auditors, and/or the Department's Office of the Inspector General. Internal controls over compliance with direct and material compliance requirements should be sufficient to prevent or detect and correct material noncompliance in a timely manner. Condition: During testing of cash management compliance requirements, it was noted that Jacksonville College had drawn down the entirety of the HEERF awards in 2021 and recorded $1,302,078. In 2022, the College had expended the majority of the funds but continues to report a deferred liability of $42,887 related to prematurely drawn-down HEERF funds. Context: Jacksonville College did not review compliance requirements related to drawing down of grant funds and over-drew funds related to the HEERF grant. Questioned Costs: $42,887 remaining in Deferred Income. Cause: A material weakness in internal control over compliance exists relating to cash management. Personnel responsible for maintaining compliance with cash management did not have sufficient education on the cash management requirements. In addition, there was no review over compliance with cash management requirements to monitor compliance. Effect or Potential Effect: The College was not in compliance with Federal requirements of the COVID-l 9 Education Stabilization Fund. 44 Repeat Finding: Not a repeat finding. Recommendation: We recommend that the College put into place controls that require review of grant requirements prior to drawing down funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College regrets that this was the process that was used. The failure to review the requirements for the draw-down of HEERF funds was managed by a previous administration. When it was discovered that the proper process was not used by the previous administration, immediate controls and policy reviews were put into place to avoid any further issues of non-compliance. Specifically, Cabinet held weekly meetings where the Executive Vice President was responsible to update Executive Administration with the current status on the utilization of funds. Since that time, a new president has been put into place by the Board of Trustees. The president is committed to following whatever requirements are mandated for all federal programs. In collaboration with all Cabinet members, relevant departments on campus, and a financial consultant, the College will avoid any further issues of non-compliance.