FAC Explorer

Finding 584369 (2023-004)

-
Requirement
C
Questioned Costs
-
Year
2023
Accepted
2024-01-09
Audit: 10337
Organization: Morehouse School of Medicine, Inc., Subsidiary and Affiliate (GA)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: The School is holding Title IV funds longer than allowed, violating cash management rules.
  • Impacted Requirements: Funds must be disbursed within 3 business days; excess cash must be returned promptly to the U.S. Department of Education.
  • Recommended Follow-Up: Enhance policies to ensure timely disbursement and return of excess cash balances.

Finding Text

FINDING 2023-004 Federal Program Information: Student Financial Aid Cluster (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management – Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)). Condition: During our cash management testing, we noted multiple instances during the fiscal year where funds drawn were held in excess of the allowable time frame and/or allowable thresholds for the Federal Direct Student Loan Program. Cause: Administrative oversight with respect to cash management compliance requirements as it relates to the Federal Direct Student Loan Program. Effect or Potential Effect: The School is not properly following policies and procedures in place to ensure that compliance is maintained with cash management requirements and the timely return of funds. Questioned Costs: None. Context: We examined all draws of Title IV aid and identified multiple instances of cash held in excess of the allowable time frame and/or allowable thresholds as noted in the condition. Identification as a Repeat Finding: No similar finding was identified during the prior year. Recommendation: We recommend that the School enhance its policies and procedures to ensure that excess cash balances are eliminated timely. Views of Responsible Officials and Planned Corrective Actions: We understand the requirement of disbursing Title IV funding to eligible students and parents and the requirement to make disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds and eliminating excess cash balance within the next 7 calendar days. In this case, the School received funds from the student from unknown sources, and the School submitted the funds to the ED on behalf of the student at the student’s request to lower outstanding educational debt. We discuss the importance of lowering education debt during our debt counseling sessions and encourage students to return funds not needed due to subsequent scholarships or family support. We will begin requiring students to submit the return themselves to the ED by providing them the ED’s instructions.

Categories

Cash Management

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $42.17M
84.031 Higher Education_institutional Aid $13.72M
84.425 Education Stabilization Fund $9.87M
93.647 Social Services Research and Demonstration $1.67M
93.397 Cancer Centers Support Grants $1.46M
93.297 Teenage Pregnancy Prevention Program $1.44M
93.838 Lung Diseases Research $1.34M
93.135 Centers for Research and Demonstration for Health Promotion and Disease Prevention $947,056
93.822 Health Careers Opportunity Program $874,121
93.516 Affordable Care Act (aca) Public Health Training Centers Program $710,237
93.350 National Center for Advancing Translational Sciences $634,498
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $371,862
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $370,468
93.310 Trans-Nih Research Support $333,279
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $329,693
47.083 Integrative Activities $328,940
93.958 Block Grants for Community Mental Health Services $301,797
93.266 Health Systems Strengthening and Hiv/aids Prevention, Care and Treatment Under the President's Emergency Plan for Aids Relief $284,634
47.074 Biological Sciences $277,610
93.145 Aids Education and Training Centers $260,137
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $237,381
93.307 Minority Health and Health Disparities Research $231,735
93.844 Acl Centers for Independent Living, Recovery Act $227,802
93.279 Drug Abuse and Addiction Research Programs $227,002
93.867 Vision Research $211,241
93.137 Community Programs to Improve Minority Health Grant Program $181,405
93.393 Cancer Cause and Prevention Research $180,996
93.959 Block Grants for Prevention and Treatment of Substance Abuse $177,084
10.855 Distance Learning and Telemedicine Loans and Grants $156,724
93.117 Preventive Medicine Residency $146,575
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $144,623
93.426 Improving the Health of Americans Through Prevention and Management of Diabetes and Heart Disease and Stroke $142,302
14.889 Choice Neighborhoods Implementation Grants $124,844
47.070 Computer and Information Science and Engineering $98,418
93.113 Environmental Health $77,336
11.028 Connecting Minority Communities Pilot Program $76,104
93.788 Opioid Str $71,734
93.837 Cardiovascular Diseases Research $67,207
93.638 Aca-Transforming Clinical Practice Initiative: Practice Transformation Networks (ptns) $66,508
93.000 Office of Logistics and Office of Administration Cobb Scholars Program $50,900
93.172 Human Genome Research $49,337
93.184 Disabilities Prevention $48,268
93.000 Evidence-Informed Interventions to Improve Provider Communication with Racial and Ethnic Minority Patients $44,156
93.107 Area Health Education Centers Point of Service Maintenance and Enhancement Awards $41,612
47.076 Education and Human Resources $40,304
64.054 Research and Development $29,135
93.110 Maternal and Child Health Federal Consolidated Programs $29,121
93.011 National Organizations of State and Local Officials $24,506
93.855 Allergy, Immunology and Transplantation Research $23,765
93.866 Child Health and Human Development Extramural Research $19,280
93.989 International Research and Research Training $17,984
93.879 Medical Library Assistance $15,261
93.456 Cdc Undergraduate Public Health Scholars Program (cups): A Public Health Experience to Expose Undergraduates Interested in Minority Health to Public Health and the Public Health Professions $12,874
93.839 Blood Diseases and Resources Research $9,496
12.420 Military Medical Research and Development $6,134
93.859 Biomedical Research and Research Training $6,104
93.129 Technical and Non-Financial Assistance to Health Centers $3,995
43.003 Exploration $3,971
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $3,559
93.242 Mental Health Research Grants $1,786
32.006 Covid-19 Telehealth Program $1,360
93.865 Child Health and Human Development Extramural Research $529