Finding Text
Noncompliance with Cash Management Requirements DEPARTMENT OF EDUCATION
ALN #: 84.268 and 84.063
Federal Award Identification #: 2023-2024 Award Year
Condition: The University did not disburse Pell or FDL timely after requesting reimbursement.
Criteria: 34 CFR 668.162
Questioned Costs: $0
Context: 5 out of 15 drawdowns tested for cash management compliance did not show disbursements per the student rosters within 3 days of receipt of cash. 1 FDL drawdown in September 2023 was $333,564 in excess of actual disbursements but was returned 12 days later. 1 March 2023 drawdown of Pell in the amount of $51,712 was disbursed 2 days late. The other 3 were Pell draws in excess of disbursements totaling $17,247.
Cause: Insufficient internal controls after main disbursement for each semester and prior to the final reconciliation for the academic year.
Effect: University had cash on hand not allowable per regulations
Identification as repeat finding, if applicable: N/A
Recommendation: We recommend the University put procedures in place draw down Title IV funds based on actual disbursements. If funds are drawn based on anticipated disbursements, those funds need to be disbursed in 3 days and any amounts in excess of actual disbursements be returned to the Department of Education timely.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.