Finding Text
2022-001 Compliance and Internal Controls over Cash Management (Significant Deficiency) U.S. Department of Education COVID -19: Education Stabilization Fund: Higher Education Emergency Relief Fund 84.425E ? COVID-19 Student Portion 2021-2022 Funding 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 statues, 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 G5 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 G5 and not paid the obligations (the financial aid grants to students) to the students within fifteen calendar days. Condition: We noted that for all 25 of the disbursements reviewed, the payments to students were processed after the fifteen calendar day timeframe. Effect: While HEERF funding has been exhausted as of June 30, 2022, not issuing refunds within due dates may impact future federal funding levels for the College. Cause: Issues with communications between the business office and student financial aid department and system issue with the student software caused delays in processing payment to students. Questioned Costs: None. Perspective: Systemic problem noted for all disbursements made to students arising from communication issues between the College?s departments and student software issues. Repeat Finding: No Auditors? Recommendation: While not applicable for HEERF funding since this has been fully utilized, for all related federal awards to students, we recommend that in order to minimize the time between funds drawn and eventual disbursement to students, the Business Office should only make draws after communication from the Student Financial Aid department that all student reviews have been completed and these are ready to be paid. Evidence of this communication should also be maintained to allow for proper audit trail. Views of Responsible Officials: See corrective action plan