Finding Text
Assistance Listing Number, Federal Agency, and Program Name - 84.033, U.S. Department of Education, Federal Work Study and 84.268, U.S. Department of Education, Federal Direct Student Loans Finding Type - Material weakness Repeat Finding - Yes - 2021-005 Criteria - The Seminary is required to maintain documentation of the initiation and approval by the designated individual at the Seminary that the cash drawdowns are certified in accordance with 2 CFR 200.415. Condition - Of the two drawdowns selected in our testing, the Seminary did not retain documentation to support one of the samples that the drawdown request was initiated, reviewed, and approved by the appropriate individuals. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - For all draws in the fiscal year that occurred prior to January 2022, the Seminary was relying solely on email communication between the student financial aid director and the bursar to support the requirements. The documentation does not meet the requirements to support that the Seminary is in compliance with the required regulations. Cause and Effect - The lack of maintaining records of the review and approval of the cash management process could lead to a lack of segregation of duties, as well as potential misstatement of funds, including funds being drawn on the incorrect grant, funds used for an unallowable cost, or funds recorded at an incorrect amount. Recommendation - We recommend the Seminary implement procedures and controls to ensure that drawdown documentation is maintained supporting that independent review was performed for each drawdown, including supporting documentation of approval of the cash drawdown. Views of Responsible Officials and Planned Corrective Actions - The financial aid director is implementing a procedure that will involve an email with supporting documentation for the drawdown requests sent to the CFO or VP of enrollment for review. The individual will sign a statement indicating the information has been reviewed and is accurate and the funds have been approved for drawdown. That email will then be forwarded to the controller to draw down the funds in G5. These requests/approvals will be documented in our internal office drawdown request folder.