Finding Text
Federal Agency: U.S. Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.268
Federal Award Identification Number and Year: P268K32067, 2022-2023
Award Period: July 1, 2022 – June 30, 2023
Type of Finding:
Other Matters
Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: 34 CFR 668.164(l) requires an institution must have a process that ensures SFA funds never escheat to a state or revert to the institution. Additionally, if a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Additionally, Institutions must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Institution is managing the Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award (2 CFR 200.303).
Condition: During our testing of outstanding SFA checks, we identified three checks outstanding that had not been returned to the U.S. Department of Education within 240 days.
Questioned costs: None
Context: Out of our population of 31 outstanding checks, we noted three had the exception described above.
Cause: The University did not have a process in place when these checks were created in fiscal year 2021; when a process was created, it was not retroactively applied to all outstanding SFA checks to date.
Effect: The University did not return all SFA funds timely to the Department of Education.
Repeat Finding: No
Recommendation: CLA recommends that the University enhance its policies and procedures regarding stale-dated check escheatment to ensure that the funds are returned to the appropriate program within 240 days from the date of issue.
Views of responsible officials: The University agrees with the finding. Management has developed a
plan to correct the finding.