Finding Text
Finding 2022-004 ? Material Weakness: Cash Management ? Compliance and Control Finding ALN 84.042 ? Student Support Services, 84.044 ? Talent Search and 84.047 ? Upward Bound ? TRIO Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None ALN 47.076 ? Research and Development Cluster: National Science Foundation ?Missouri Louis Stokes Alliances for Minority Participation, Research Initiation Grant, and Entrepreneurship Federal Agency: National Science Foundation Pass-Through Entity: None ALN 84.425E, 84.425F and 84.425J ? Higher Education Emergency Relief Fund (HEERF) Federal Agency: Department of Education Pass-Through Entity: None ALN 84.031 ? Title III ? Higher Education ? Institutional Aid Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 2 CFR Section 200.305 requires that an entity pay for the costs for which reimbursement is being requested. 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 for allowable activities and costs, appropriate documentation was not retained to provide proof that costs were paid prior to requesting reimbursement. A second review of the cash drawdown to verify that the correct amount of funds are requested did not occur. 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 to provide proof that costs were paid prior to reimbursement. For 1 out of 4 cash drawdowns reviewed, the amount of the draw down exceeded the listing of expenditures to date provided. We noted all reimbursement requests are completed and drawn down without a second review. Statistical sampling was not used to test this compliance requirement Identification As A Repeat Finding: 2021-004, 2021-009, 2021-016, 2020-004, 2020-008 2019-005 and 2018-003 Recommendation: Management should retain appropriate documentation to support costs charged to the grant and to support that costs were paid prior to requesting reimbursement. 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 document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.