Finding Text
Program Information: Title III Strengthening Historically Black Colleges and Universities Program (“Title III”) (ALN: 84.031B),TRIO Cluster (ALN: Various) and Education Stabilization Fund - Higher Education Emergency Relief Fund (ALN: 84.425)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management - When awards provide for advance payments, recipients must follow procedures to minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement. Cash advances to a recipient organization shall be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the recipient organization in carrying out the purpose of the approved program or project. The timing and amount of cash advances shall be as close as is administratively feasible to the actual disbursements by the recipient organization for direct program or project costs (2 CFR 215.22).
Condition: Instance were identified during the year where the University was unable to provide a reconciliation and/or expenditure detail (which would represent the immediate cash need of the University) for cash drawdowns requested.
Cause: Lack of internal controls and administrative oversight with respect to cash management requirements.
Effect or Potential Effect: The University was not in compliance with the applicable requirements of the cash management compliance requirements. Federal funds were drawn in excess of program expenditures, thus not representing the actual, immediate cash requirements of the University, as required.
Questioned Costs: None.
Context: For federal funds drawdowns that occurred between during the current fiscal year, the cumulative amount drawn down exceeded cumulative expenditures.
Repeat Finding: This is a repeat finding from prior year. This was reported as Finding 2020-017 in the prior year schedule of findings and questioned costs.
Recommendation: We recommend that the University enhance its internal controls to comply with cash management requirements associated with its drawdowns of federal funds.
Views of Responsible Officials and Planned Corrective Actions: Significant steps have been taken to remediate this finding. A process to implement a monthly reconciliation of Title III funds and TRIO Cluster to ensure that the amount drawn down does not exceed the allowable costs. Additionally, more robust communication protocols, policies and procedures have been developed between the Grant Accounting division and the Office of Sponsored Programs, to reduce the risk of this recurring.