Finding Text
Program: COVID-19 Education Stabilization Fund ALN 84.425F Higher Education Emergency Relief Fund ? Institutional Portion Compliance Requirement: Cash Management Criteria: Pursuant to 2022 Compliance Supplement ESF Section 2 III Cash Management, the College is required to disburse funds within three days of draw from G5. Condition: The College had approval from the Department of Education to transfer allowable activities to other expenditures that were applicable under the grant guidelines and replace debt forgiveness outside the period of performance. This caused cash management to become out of compliance with the three days to apply expenditures from the date of drawdown. Context: The College originally applied funds to debt forgiveness in which the parameters of the three days to apply funds did apply. The debt forgiveness was not approved by the Department of Education for items before March 13, 2020. The Department of Education gave written approval to the College to reclass invoices that were applicable under the grant guidelines. This produced the draws being over three days from drawdown for majority of the items. Cause: On September 23, 2022, the College was asked to contact the Department of Education for guidance on debt forgiveness or obtain a waiver. The College?s request for a waiver was denied on November 29, 2022. The Department of Education gave written approval to the College to apply invoices that are within the guidelines of the grant as grant expenditures instead of the original debt forgiveness. Transferring allowable activities resulted in noncompliance with the criteria of expending funds within three days of draw. Effect: The College could be asked to return funding if draws are viewed as out of compliance after the reclassification. Questioned Cost: None Repeat Finding: No Recommendation: The College needs to ensure they understand high-risk grant requirements by reviewing the compliance supplement, the Department of Education?s website and making contact with the Department on questions of concern. Views of Responsible Officials: The College requested a reclassification of expenditures for the grant year. The request was approved by the Department of Education. The College will request any clarification on items from the Department when in question to ensure they understand the requirements of the grant. No further action is required.