Audit 305892

Finding 2021-005 Program: Office for Coastal Management Federal Financial Assistance Listing: 11.473 Federal Grantor: U.S. Department of Commerce Passed-through: National Fish and Wildlife Foundation Award No. and Year: 0318.19.070225 (2020) Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Type of Finding: Significant Deficiency Criteria: 2 CFR 200.403(a) - Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Condition: For one payroll sample that was selected, the amount of time charged to the grant was greater than the amount of time work was performed. As such, the program was overcharged. Questioned Costs: Questioned costs were identified as a result of our procedures in the amount of $74. Context/Sampling: A nonstatistical sample of 17 out of 82 total payroll costs ($25,275 of $35,106) were selected for testing for the Office for Coastal Management program. The condition noted above was identified during our procedures over the CFSC’s allowable costs provisions. EB expanded the sample to 22 ($26,792) and no further questioned costs were identified. Repeat Finding from Prior Year: No Effect: CFSC did not identify the error to be able to make the appropriate corrections before receiving reimbursement for incorrect payroll related expenditures. Cause: CFSC did not consistently ensure that the hours worked by each employee related to the federal program were accurate applying the cost to the grant. Recommendation: We recommend that CFSC strengthen its current policies and procedures to ensure that all payroll amounts applied to the grant were for actual hours worked based on employee timesheets. Views of Responsible Officials and Planned Corrective Actions: See Separate Corrective Action Plan.

Finding 2021-006 Program: Office for Coastal Management Federal Financial Assistance Listing: 11.473 Federal Grantor: U.S. Department of Commerce Passed-through: National Fish and Wildlife Foundation Award No. and Year: 0318.19.070225 (2020) Compliance Requirements: Reporting Type of Finding: Material Non-Compliance/Material Weakness Criteria: 2 CFR 200.328 - Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. 2 CFR 200.329(c)(1) -Requirements state that the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Condition: For three of the four reports selected for testing, CFSC did not submit the reports to the National Fish and Wildlife Foundation by the required date. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was not used. We selected all four reports filed during year. The condition noted above was identified during our procedures over the CFSC’s reporting provisions. Repeat Finding from Prior Year: No Effect: CFSC did not submit required reports in a timely manner, increasing the risk of noncompliance. Cause: CFSC’s procedures did not consistently ensure that the required reports were submitted on a timely basis. Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that all required reports are submitted on a timely basis to the appropriate Federal Agency or Pass-Through Entity. Views of Responsible Officials and Planned Corrective Actions: See Separate Corrective Action Plan.

Finding 2021-007 Program: Office for Coastal Management Federal Financial Assistance Listing: 11.473 Federal Grantor: U.S. Department of Commerce Passed-through: National Fish and Wildlife Foundation Award No. and Year: 0318.19.070225 (2020) Compliance Requirements: Reporting Type of Finding: Material Non-Compliance/Material Weakness Criteria: 2 CFR 200.302(b)(2) - Requirements state that there must be accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. Condition: Expenditures for one financial report that was selected for testing did not agree with the expenditures that were reported on the SEFA and recorded in the General Ledger (difference of $11,791), based on the dates requested in the report. CFSC did not include known operational expenses for the period that were program costs at the time the report was due, which resulted in underreporting expenditures by $11,791. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was not used. We selected all four reports filed during year. The condition noted above was identified during our procedures over CFSC’s reporting provisions. Repeat Finding from Prior Year: No Effect: CFSC did not include all known expenditures at the time the report was submitted to the National Fish and Wildlife Foundation, increasing the risk of noncompliance. Cause: CFSC’s procedures did not consistently ensure that all known expenditures at the time the report was submitted were included. Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that all known expenditures are included at the time reports are required to be submitted. Views of Responsible Officials and Planned Corrective Actions: See Separate Corrective Action Plan.

Finding 2021-008 Program: Office for Coastal Management Federal Financial Assistance Listing: 11.473 Federal Grantor: U.S. Department of Commerce Passed-through: National Fish and Wildlife Foundation Award No. and Year: 0318.19.070225 (2020) Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Non-Compliance/Material Weakness Criteria: 2 CFR Part 200.331(a) - Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not identified at the time of subaward for three of the three subawards selected for testing from the Office for Coastal Management: • Federal Award date by the Federal Agency • Whether or not the award was R&D • The indirect cost rate for the Federal Award (including if the de minimus rate is charged) Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was not used. We selected all three subrecipients for testing. The condition noted above was identified during our procedures over CFSC’s subrecipient monitoring provisions. Repeat Finding from Prior Year: No Effect: CFSC did not identify the required elements of the subaward to the subrecipients at the time of subaward, increasing the risk of noncompliance. Cause: CFSC’s procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Views of Responsible Officials and Planned Corrective Actions: See Separate Corrective Action Plan.

Finding 2021-009 Program: Office for Coastal Management Federal Financial Assistance Listing: 11.473 Federal Grantor: U.S. Department of Commerce Passed-through: National Fish and Wildlife Foundation Award No. and Year: 0318.19.070225 (2020) Compliance Requirements: Subrecipient Monitoring and Matching Type of Finding: Material Non-Compliance/Material Weakness Criteria: 2 CFR 200.303(a) - establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 200.331(b) - Requirements for Pass-Through Entities, states that all pass-through entities must assess the subrecipient’s risk of non-compliance with federal statutes, regulations, and terms and conditions of the subaward. 2 CFR 200.331(d) - establishes that the auditee must follow up and ensure subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided from the Pass Through Entity (PTE) detected through audits. 2 CFR 200.332(d) - establishes that the auditee must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. As part of monitoring the subrecipients, since there is a matching requirement within the grant, the CFSC’s procedures should monitor and ensure the subrecipients are complying the required match arrangements outlined in the subaward agreements. Condition: CFSC did not perform risk assessment for all subrecipients selected for testing. CFSC was unable to provide supporting documentation to show that they inquired with the subrecipients about any audits they had undergone or evidence that CFSC received and reviewed audit reports to ensure timely follow ups were made if any findings pertaining to the Federal Award was noted. Monitoring of matching is not done each time expenditures are incurred by a subrecipient, which increases the risk that a subrecipient may not incur the required match costs before the end of the grant period. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was not used. We selected all three subrecipients for testing. The condition noted above was identified during our procedures over CFSC’s subrecipient monitoring provisions. Repeat Finding from Prior Year: Yes –2020-001 Effect: CFSC did not perform the following, which increases the risk of noncompliance: • Required risk assessments for the subrecipients, • Review subrecipient audit reports to ensure compliance with Federal Awards or make any necessary follow-ups pertaining to any findings noted, if any. • Ensure match expenditures are incurred throughout the duration of the grant period, which increases risk that CFSC may not meet its matching requirements through its subrecipients. Cause: CFSC’s procedures did not consistently ensure that the required risk assessments, monitoring, matching through subrecipients, or subrecipient follow-up were performed. Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that all required risk assessments are performed in accordance with the criteria outlined above. Views of Responsible Officials and Planned Corrective Actions: See Separate Corrective Action Plan.

Finding 2021-010 Program: Office for Coastal Management Federal Financial Assistance Listing: 11.473 Federal Grantor: U.S. Department of Commerce Passed-through: National Fish and Wildlife Foundation Award No. and Year: 0318.19.070225 (2020) Compliance Requirements: Cash Management / Subrecipient Monitoring Type of Finding: Material Non-Compliance/Material Weakness Criteria: 2 CFR 200.305 – establishes that payment methods must minimize the time elapsing between the transfer of funds from the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer or other means. The non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions. Whenever possible, advance payments must be consolidated to cover anticipated cash needs for all Federal awards made by the Federal awarding agency to the recipient. Non-Federal entities must be authorized to submit requests for advance payments and reimbursements at least monthly when electronic fund transfers are not used, and as often as they like when electronic transfers are used, in accordance with the provisions of the Electronic Fund Transfer Act. Reimbursement is the preferred method when the requirements above cannot be met. Condition: We identified the following: • For amounts advanced from granting agency to CFSC, we noted $559,110 of advances were not expended timely. The expenditures were incurred (or disbursed to subrecipients) between 21 and 50 days after advanced funds were received by CFSC. • For $733,637 of pass-through payments paid by CFSC, the timing of payment to subrecipients didn’t follow a reimbursement method. The agreements allowed for funds to be advanced, with a true-up required quarterly. Funds were frequently remitted to subrecipient more than 30 days in advance of the expenditure being incurred by the subrecipient. o For 5 transactions of 9 payments to subrecipients tested, funds were provided to subrecipients prior to eligible expenditures being incurred by the subrecipient. The number of days between date funds were advanced to subrecipient, and when an eligible expenditures were completely incurred by subrecipients were as follows:  8 days - $191,830 • Time between CFSC receipt of funds (from granting agency) and subsequent remittance to subrecipient was 59 days  34 days - $195,929 • Time between CFSC receipt of funds and subsequent remittance to subrecipient was 44 days  51 days - $100,000 • Time between CFSC receipt of funds and subsequent remittance to subrecipient was 59 days  79 days - $50,000 • time between CFSC receipt of funds and subsequent remittance to subrecipient was 107 days  86 days - $195,929 • time between CFSC receipt of funds and subsequent remittance to subrecipient was 121 days Questioned Costs: Advances received of $559,110 by CFSC, and subrecipient advances paid of $733,637, as detailed under the Condition above. Context/Sampling: Sampling was not used. For advances received, we tested 6 of 6 advances. We selected all three subrecipients for testing. The condition noted above was identified during our procedures over CFSC’s subrecipient monitoring provisions. Repeat Finding from Prior Year: Yes –2020-001 Effect: CFSC did not minimize the time elapsing between receiving advances and incurring eligible expenditures, including the timing of the subrecipients incurring the related eligible expenditures. Cause: CFSC’s procedures did not consistently ensure that subrecipient agreements followed the uniform guidance requirements related to advances, nor did their policies allow for appropriately minimizing the time elapsing on advances received. Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that cash management policies surrounding advances are in line with grant agreements and uniform guidance. Views of Responsible Officials and Planned Corrective Actions: See Separate Corrective Action Plan.

Finding 2021-005 Program: Office for Coastal Management Federal Financial Assistance Listing: 11.473 Federal Grantor: U.S. Department of Commerce Passed-through: National Fish and Wildlife Foundation Award No. and Year: 0318.19.070225 (2020) Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Type of Finding: Significant Deficiency Criteria: 2 CFR 200.403(a) - Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Condition: For one payroll sample that was selected, the amount of time charged to the grant was greater than the amount of time work was performed. As such, the program was overcharged. Questioned Costs: Questioned costs were identified as a result of our procedures in the amount of $74. Context/Sampling: A nonstatistical sample of 17 out of 82 total payroll costs ($25,275 of $35,106) were selected for testing for the Office for Coastal Management program. The condition noted above was identified during our procedures over the CFSC’s allowable costs provisions. EB expanded the sample to 22 ($26,792) and no further questioned costs were identified. Repeat Finding from Prior Year: No Effect: CFSC did not identify the error to be able to make the appropriate corrections before receiving reimbursement for incorrect payroll related expenditures. Cause: CFSC did not consistently ensure that the hours worked by each employee related to the federal program were accurate applying the cost to the grant. Recommendation: We recommend that CFSC strengthen its current policies and procedures to ensure that all payroll amounts applied to the grant were for actual hours worked based on employee timesheets. Views of Responsible Officials and Planned Corrective Actions: See Separate Corrective Action Plan.

Finding 2021-006 Program: Office for Coastal Management Federal Financial Assistance Listing: 11.473 Federal Grantor: U.S. Department of Commerce Passed-through: National Fish and Wildlife Foundation Award No. and Year: 0318.19.070225 (2020) Compliance Requirements: Reporting Type of Finding: Material Non-Compliance/Material Weakness Criteria: 2 CFR 200.328 - Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. 2 CFR 200.329(c)(1) -Requirements state that the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Condition: For three of the four reports selected for testing, CFSC did not submit the reports to the National Fish and Wildlife Foundation by the required date. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was not used. We selected all four reports filed during year. The condition noted above was identified during our procedures over the CFSC’s reporting provisions. Repeat Finding from Prior Year: No Effect: CFSC did not submit required reports in a timely manner, increasing the risk of noncompliance. Cause: CFSC’s procedures did not consistently ensure that the required reports were submitted on a timely basis. Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that all required reports are submitted on a timely basis to the appropriate Federal Agency or Pass-Through Entity. Views of Responsible Officials and Planned Corrective Actions: See Separate Corrective Action Plan.

Finding 2021-007 Program: Office for Coastal Management Federal Financial Assistance Listing: 11.473 Federal Grantor: U.S. Department of Commerce Passed-through: National Fish and Wildlife Foundation Award No. and Year: 0318.19.070225 (2020) Compliance Requirements: Reporting Type of Finding: Material Non-Compliance/Material Weakness Criteria: 2 CFR 200.302(b)(2) - Requirements state that there must be accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. Condition: Expenditures for one financial report that was selected for testing did not agree with the expenditures that were reported on the SEFA and recorded in the General Ledger (difference of $11,791), based on the dates requested in the report. CFSC did not include known operational expenses for the period that were program costs at the time the report was due, which resulted in underreporting expenditures by $11,791. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was not used. We selected all four reports filed during year. The condition noted above was identified during our procedures over CFSC’s reporting provisions. Repeat Finding from Prior Year: No Effect: CFSC did not include all known expenditures at the time the report was submitted to the National Fish and Wildlife Foundation, increasing the risk of noncompliance. Cause: CFSC’s procedures did not consistently ensure that all known expenditures at the time the report was submitted were included. Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that all known expenditures are included at the time reports are required to be submitted. Views of Responsible Officials and Planned Corrective Actions: See Separate Corrective Action Plan.

Finding 2021-008 Program: Office for Coastal Management Federal Financial Assistance Listing: 11.473 Federal Grantor: U.S. Department of Commerce Passed-through: National Fish and Wildlife Foundation Award No. and Year: 0318.19.070225 (2020) Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Non-Compliance/Material Weakness Criteria: 2 CFR Part 200.331(a) - Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not identified at the time of subaward for three of the three subawards selected for testing from the Office for Coastal Management: • Federal Award date by the Federal Agency • Whether or not the award was R&D • The indirect cost rate for the Federal Award (including if the de minimus rate is charged) Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was not used. We selected all three subrecipients for testing. The condition noted above was identified during our procedures over CFSC’s subrecipient monitoring provisions. Repeat Finding from Prior Year: No Effect: CFSC did not identify the required elements of the subaward to the subrecipients at the time of subaward, increasing the risk of noncompliance. Cause: CFSC’s procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Views of Responsible Officials and Planned Corrective Actions: See Separate Corrective Action Plan.

Finding 2021-009 Program: Office for Coastal Management Federal Financial Assistance Listing: 11.473 Federal Grantor: U.S. Department of Commerce Passed-through: National Fish and Wildlife Foundation Award No. and Year: 0318.19.070225 (2020) Compliance Requirements: Subrecipient Monitoring and Matching Type of Finding: Material Non-Compliance/Material Weakness Criteria: 2 CFR 200.303(a) - establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 200.331(b) - Requirements for Pass-Through Entities, states that all pass-through entities must assess the subrecipient’s risk of non-compliance with federal statutes, regulations, and terms and conditions of the subaward. 2 CFR 200.331(d) - establishes that the auditee must follow up and ensure subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided from the Pass Through Entity (PTE) detected through audits. 2 CFR 200.332(d) - establishes that the auditee must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. As part of monitoring the subrecipients, since there is a matching requirement within the grant, the CFSC’s procedures should monitor and ensure the subrecipients are complying the required match arrangements outlined in the subaward agreements. Condition: CFSC did not perform risk assessment for all subrecipients selected for testing. CFSC was unable to provide supporting documentation to show that they inquired with the subrecipients about any audits they had undergone or evidence that CFSC received and reviewed audit reports to ensure timely follow ups were made if any findings pertaining to the Federal Award was noted. Monitoring of matching is not done each time expenditures are incurred by a subrecipient, which increases the risk that a subrecipient may not incur the required match costs before the end of the grant period. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was not used. We selected all three subrecipients for testing. The condition noted above was identified during our procedures over CFSC’s subrecipient monitoring provisions. Repeat Finding from Prior Year: Yes –2020-001 Effect: CFSC did not perform the following, which increases the risk of noncompliance: • Required risk assessments for the subrecipients, • Review subrecipient audit reports to ensure compliance with Federal Awards or make any necessary follow-ups pertaining to any findings noted, if any. • Ensure match expenditures are incurred throughout the duration of the grant period, which increases risk that CFSC may not meet its matching requirements through its subrecipients. Cause: CFSC’s procedures did not consistently ensure that the required risk assessments, monitoring, matching through subrecipients, or subrecipient follow-up were performed. Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that all required risk assessments are performed in accordance with the criteria outlined above. Views of Responsible Officials and Planned Corrective Actions: See Separate Corrective Action Plan.

Finding 2021-010 Program: Office for Coastal Management Federal Financial Assistance Listing: 11.473 Federal Grantor: U.S. Department of Commerce Passed-through: National Fish and Wildlife Foundation Award No. and Year: 0318.19.070225 (2020) Compliance Requirements: Cash Management / Subrecipient Monitoring Type of Finding: Material Non-Compliance/Material Weakness Criteria: 2 CFR 200.305 – establishes that payment methods must minimize the time elapsing between the transfer of funds from the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer or other means. The non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions. Whenever possible, advance payments must be consolidated to cover anticipated cash needs for all Federal awards made by the Federal awarding agency to the recipient. Non-Federal entities must be authorized to submit requests for advance payments and reimbursements at least monthly when electronic fund transfers are not used, and as often as they like when electronic transfers are used, in accordance with the provisions of the Electronic Fund Transfer Act. Reimbursement is the preferred method when the requirements above cannot be met. Condition: We identified the following: • For amounts advanced from granting agency to CFSC, we noted $559,110 of advances were not expended timely. The expenditures were incurred (or disbursed to subrecipients) between 21 and 50 days after advanced funds were received by CFSC. • For $733,637 of pass-through payments paid by CFSC, the timing of payment to subrecipients didn’t follow a reimbursement method. The agreements allowed for funds to be advanced, with a true-up required quarterly. Funds were frequently remitted to subrecipient more than 30 days in advance of the expenditure being incurred by the subrecipient. o For 5 transactions of 9 payments to subrecipients tested, funds were provided to subrecipients prior to eligible expenditures being incurred by the subrecipient. The number of days between date funds were advanced to subrecipient, and when an eligible expenditures were completely incurred by subrecipients were as follows:  8 days - $191,830 • Time between CFSC receipt of funds (from granting agency) and subsequent remittance to subrecipient was 59 days  34 days - $195,929 • Time between CFSC receipt of funds and subsequent remittance to subrecipient was 44 days  51 days - $100,000 • Time between CFSC receipt of funds and subsequent remittance to subrecipient was 59 days  79 days - $50,000 • time between CFSC receipt of funds and subsequent remittance to subrecipient was 107 days  86 days - $195,929 • time between CFSC receipt of funds and subsequent remittance to subrecipient was 121 days Questioned Costs: Advances received of $559,110 by CFSC, and subrecipient advances paid of $733,637, as detailed under the Condition above. Context/Sampling: Sampling was not used. For advances received, we tested 6 of 6 advances. We selected all three subrecipients for testing. The condition noted above was identified during our procedures over CFSC’s subrecipient monitoring provisions. Repeat Finding from Prior Year: Yes –2020-001 Effect: CFSC did not minimize the time elapsing between receiving advances and incurring eligible expenditures, including the timing of the subrecipients incurring the related eligible expenditures. Cause: CFSC’s procedures did not consistently ensure that subrecipient agreements followed the uniform guidance requirements related to advances, nor did their policies allow for appropriately minimizing the time elapsing on advances received. Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that cash management policies surrounding advances are in line with grant agreements and uniform guidance. Views of Responsible Officials and Planned Corrective Actions: See Separate Corrective Action Plan.