Finding Text
Cash Management Federal Program Name
Higher Education Emergency Relief Fund (HEERF)
HEERF Institutional Portion, ALN. 84.425F
HEERF Minority Serving Institutions (MSIs), ALN. 84.425L
Name of Federal Agency
U.S. Department of Education
Pass-through Entity
N/A
Criteria
According to the 2 CFR 200.305(b) non-federal entities must minimize the time elapsing between the
transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the
recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other
means. Also, CRRSAA HEERF II and ARP HEERF III, the Certification and Agreements and/or
Supplemental Agreements requires that Institutional Aid Portion, (a)(2), and (a)(3) funds should be
disbursed within 3 calendar days of the drawdown from G5.
Condition
During our examination, we found the following instances on which the Institution did not disbursed funds in
an expedite matter:
Fund Instances Average of days late
84.425F 106 7
84.425L 5 31
Cause
The delay in disbursements responds to several situations: remote work, lack of banking or information
from suppliers, multiplicity of tasks under the responsibility of the Administration and Operations Director,
which affected the dates of sending the payments.
Effect
As a result of this condition, the USDE may issue warnings and/or impose penalties to the Institution.
Questioned Cost
None
Context
During our examination, we noted one hundred six (106) instances from one hundred thirty-six (136) of the
HEERF Institutional portion and five (5) instances from five (5) from Minority, on which the Institution did
not disbursed funds within 3 calendar days of the drawdown from G5.
Identification of a Repeat Finding
This is not a repeat finding from the immediate previous audit.
Recommendation
The management of the Institution should reinforce its cash management procedures and internal controls
to ensure the disbursement of funds in the required time frame after the drawdowns from G5.
Views of Responsible Officials of the Auditee and Planned Corrective Actions
The management of the Institution agrees with this finding. Please refer to the corrective action plan on
pages 22-26.