The College does not dispute this finding. The finding pertains to the College’s efforts to renovate its historic library to make it more accessible and user-friendly. To fund the project's initial phase, the renovations required the aggregation and carry-over of Title IIIB funds over multiple fiscal year periods. Before the commencement of construction, the Title IIIB program officer was informed of the College’s intent to dedicate the aggregated funds to the project. There was no indication from the Department of Education that such use would be an inappropriate practice. Because no blueprints or other construction documents were available for the mid-1950s era building, the College, and the construction professionals it utilized, anticipated that the project would experience unknown conditions and unanticipated material and equipment supply delays during the construction period that would increase the cost of the project. Some unknown conditions included a significant floor height discrepancy between building sections and extensive rock formations in the excavation area. The recording and reconciliation errors noted by the auditor above reflect the College’s attempt to ensure that it had sufficient cash on hand during the project to meet both anticipated and unanticipated expenses. Additionally, a second phase of the library modernization project involving HVAC, window system, and flooring upgrades was planned even before the beginning of the initial phase of construction. While few of the second-phase improvements were ultimately included in the initial stage, the College has proceeded with the remaining second-phase enhancements, including replacing existing windows and flooring. These items will be expensed in the next quarter (October-December 2022). The College now recognizes that the approach described above is unallowable, and will confine its future drawdowns of federal funds to actual, not speculative, expenditures. The Board will implement the above procedure immediately.