Finding 2022-013 ? Internal Controls Over Grant Management (Significant Deficiency) Information on the Federal Program: U.S. Department of Education, CFDA No. 84.425, COVID-19 Education Stabilization Fund ? Higher Education Emergency Relief Fund Criteria: 2 CFR 200.303 requires non-federal entities receiving federal awards establish and maintain internal controls over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations and the terms and conditions of the federal awards. Condition: During audit procedures we tested controls over applicable compliance requirements. We tested two drawdowns for cash management requirements. One of the draws was a reimbursement for lost revenue. Although the method to calculate lost revenue was reviewed and approved, the individual calculations and amounts to be drawn were not reviewed and approved. We tested five disbursements made directly to students as grant awards. Of these five, four disbursements did not have documentation of review or approval of the amounts to be paid. Management?s View: Management had previously held many discussions regarding drawdown calculations and student disbursements either verbally or during in-person meetings that were not formally documented. Corrective Action Plan: Management is in process of updating Policies and Procedures. Management will ensure that all drawdown calculations will be sent to the Director of Accounting and Finance and the VP of Administration and Operations for review and approval via email. Student disbursement information, including the method of determining qualifying students and amounts, will be sent by the Dean of Students to the VP of Administration and Operations for review and approval. In the event such information is discussed verbally or at in-person meetings, documentation of date, time, and summary of the discussion will be documented. This will take effect immediately as the policies are formally updated. Anticipated Completion Date: September 30, 2023