Finding Text
Finding 2022-012 ? Material Weakness: Cash Management ? Control Finding ALN 84.007 ? Federal Supplemental Educational Opportunity Grant, 84.033 ? Federal Work Study Program, 84.063 - Federal Pell Grant Program, 84.268 ? Federal Direct Student Loan Program, and 84.379 ? Teacher Education Assistance For College and Higher Education (TEACH) ? Student Financial Aid Cluster Student Financial Aid Cluster Federal Agency: U.S. Department of Education Pass-Through Entity: None Criteria Or Specific Requirement: 34 CFR Section 668.162 requires that an entity under the advance payment method request funds that do not exceed the immediate need for disbursements. Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: Based on the testing completed for cash management, the University did not provide documentation of 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, 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: 2021-023. Recommendation: Management should ensure that funds drawn down agree to the immediate needs of the University or to the amount the University has already spent. 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 Comptroller for 2nd review, and sent to the CFO for final review and approval 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.