Finding Text
Finding 2023-004 – Significant Deficiency: Cash Management – Control Finding
ALN 84.425E, 84.425F and 84.425J – Higher Education Emergency Relief Fund (HEERF)
Federal Agency: Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs.
Condition: Based on the testing completed over the cash management compliance requirement, the University did not retain documentation of a second review of the cash drawdown to verify that the correct amount of funds are requested.
Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements.
Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance.
Questioned Costs: Not applicable.
Context: During testing performed for cash management, appropriate documentation was not retained as part of the reimbursement packet to provide documentation for the amount of the reimbursement request. For 1 out of 4 cash drawdowns reviewed, the draw down was completed without a second review and without appropriate documentation to support the costs requested for reimbursement. Through testing of allowable costs, the amounts requested for reimbursement appear to be allowable. Statistical sampling was not used to test this compliance requirement
Identification As A Repeat Finding: 2022-004, 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003
Recommendation: We recommend that management put a control in place for a second review of the cash drawdown requests. The second review should be properly documented with the reviewer’s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant’s requirements
Views Of Responsible Officials: The University has implemented a process to reconcile all expenditures from federal funding sources prior to being drawn down. This exception was addressed subsequent to the drawdown and detective control addressed it after the fact. The revised preventive control is in place and no subsequent issues were noted.