Finding Text
Finding number: 2022-001 Federal agency: U.S. Department of Education Programs: Higher Education Emergency Relief Fund Assistance Listing #: 84.425F Award year: 2022 Criteria For Coronavirus Response and Relief Supplemental Appropriations Act HEERF II and American Rescue Plan Act HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from the Department of Education?s G5 grants system (?G5?) and Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within 3 calendar days of the drawdown from G5. For lost revenue, the ?obligation? occurs on the date the institution completes its estimate of its amount of lost revenue after the estimation period. Condition The Federal Government requires the College to disburse the Institutional Aid Portion of HEERF funds within three calendar days of drawdown from G5. During our testing, we noted that the entire balance of the HEERF III Institutional Aid Portion was drawn down during fiscal year 2022 but none of the balance was expended within three calendar days of drawdown. Cause Due to the inexperience with the HEERF III program, the College did not have adequate procedures in place to ensure that Institutional Aid Funds were disbursed within three calendar days of drawdown. Effect HEERF III Institutional Aid Funds were drawn down in excess of disbursements and the excess funds remained unspent beyond the three-calendar day threshold for institutional expenditures. Due to these circumstances, the College was not in compliance with the cash management requirement of the HEERF III agreements. Questioned Costs $6,062,177 Perspective Our sample was not, and was not intended to be, statistically valid. We selected one HEERF institutional drawdown to test and it was not disbursed within the required three-calendar day threshold. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that the College review their excess cash and utilize that cash before drawing additional funds from the HEERF funding to ensure that there is not any additional excess cash on hand. In addition, we recommend that the College implements procedures to ensure that future cash drawdowns occur within the required period before or after expending the grant funds. View of Responsible Officials The College agrees with the finding.