Finding Text
2022-007 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.425 Federal Award Number: P425E202575; P425F202249; P425L200619; P425N200061 Program Name: Education Stabilization Fund - HEERF Cash Management under Higher Education Emergency Relief Funds (HEERF) Material Weakness in Internal Control over Compliance Criteria ? In addition to basic cash management principles, for CRRSAA and ARP HEERF, the Certification and Agreements requires that Student Aid Portion be disbursed within 15 calendar days of the drawdown from DOE?s G5 grants system, and the Institutional Aid Portion within 3 calendar days. Condition ? During our testing of cash management, we noted instances where the Student Aid Portion was not disbursed within 15 calendar days of the drawdown and instances where the Institutional Portion was not disbursed within 3 calendar days of the drawdown. Specifically, the following was noted during our testing: ? The College drew 100% of the student aid portion from HEERF II on January 26, 2021, but they did not have the funds fully disbursed until fiscal year 2022. ? The College drew 100% of the student aid portion from HEERF III on January 21, 2022, and returned all but $10,000 on February 15, 2022, at the direction of the DOE. The College did disburse funds of $10,000 to students between January 21, 2022, and February 15, 2022, but outside the 15-day window of compliance. The DOE is already aware of this finding. ? The College drew 100% of the institutional portion from HEERF III on January 21, 2022, and returned all but $151,805 on February 15, 2022, at the direction of the DOE. The College did incur eligible costs of $151,805 between January 21, 2022, and February 15, 2022, but not within the 3-day window of compliance. The DOE is already aware of this finding. ? The College redrew $556,763 of institutional portion from HEERF III on June 8, 2022, but it appears they only disbursed $508,371 within the 3-day window of compliance. ? The College drew 100% of institutional MSI HEERF II on March 18, 2021, but they did not have the funds fully disbursed until fiscal year 2022 when it was used against lost revenue for quarters 1, 2 and 3. ? The College drew $87,528 of institutional MSI HEERF III on January 21, 2022, but it appears they only disbursed $63,255 within the 3-day window of compliance. Cause ? Because of confusion over the rules and conditions on timing over drawdowns and disbursements, the College drew funds and did not make the disbursements timely. However, as of June 30, 2022, all drawdowns have been disbursed. Effect - The College was out of compliance with the cash management requirements of HEERF. Questioned Costs ? None reported Context/Sampling ? All prior year draws disbursed in the current year and all draws made in the current year were reviewed for compliance. Repeat Finding - No Recommendation - The College should implement a process to ensure that funds are disbursed within the required timeframe. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.