Criteria: According to 2 CFR §200.305(b), when a non-federal entity receives advance payments of
federal funds, it must deposit those funds in interest-bearing accounts, unless certain exceptions apply,
and must remit any interest earned on advances in excess of $500 per year to the federal agency.
Furthermore, advance payments should be segregated to ensure proper tracking and safeguarding of
federal funds.
Condition: During our audit of the Organization’s federal awards, we identified deficiencies in the
grantee’s cash management procedures related to advance payments received from federal awarding
agencies. Specifically, the grantee did not segregate advance payments into separate insured interestbearing
accounts as required by the Uniform Guidance.
Cause: The Organization did not have adequate policies and procedures or internal controls in place to
ensure compliance with the cash management requirements related to advance payments.
Effect: The federal awarding agency did not receive interest that could have been earned on the
advances. All advances received during 2024 were expended by December 31, 2024. There was no loss
from uninsured funds or from lack of segregating funds into separate accounts.
Recommendation: We recommend that the Organization implement policies and procedures to ensure
that all advance payments are deposited into separate, insured, interest-bearing accounts as required.
The Organization should also establish controls to track interest earned on these accounts and remit
amounts due to the federal awarding agencies in a timely manner. Training should be provided to staff
responsible for cash management to ensure ongoing compliance with federal requirements.
Views of Responsible Officials: Management agrees with the finding and procedures have been
implemented to address the related issues.
Criteria: According to 2 CFR §200.214, nonfederal entities other than states must follow the suspension
and debarment standards set out at 2 CFR Part 180, which restrict making Federal awards, subawards,
and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or
participating in Federal awards.
Condition: During our audit of the Organization's federal awards, we identified a deficiency in the
grantee’s procurement, suspension, and debarment procedures related to suspension and debarment for
4 of 4 subcontractors we reviewed. Specifically, the grantee did not verify that subcontractors were not
excluded or disqualified before entering into transactions expected to exceed $25,000 in accordance with
the Uniform Guidance.
Cause: The Organization did not have adequate policies and procedures or internal controls in place to
ensure compliance with the procurement, suspension, and debarment requirements.
Effect: The Organization may be paying subcontractors that are suspended or debarred, which would be
unallowable costs. However, none of the 4 subcontractors were suspended or debarred as of the date
audit procedures were performed.
Recommendation: We recommend that the Organization implement policies and procedures to ensure
that all subcontractors and subrecipients of covered transactions are properly verified before entering into
transactions, and that this be documented as a control each time it is performed.
Views of Responsible Officials: Management agrees with the finding and procedures have been
implemented to address the related issues.
Criteria: According to 2 CFR §200.305(b), when a non-federal entity receives advance payments of
federal funds, it must deposit those funds in interest-bearing accounts, unless certain exceptions apply,
and must remit any interest earned on advances in excess of $500 per year to the federal agency.
Furthermore, advance payments should be segregated to ensure proper tracking and safeguarding of
federal funds.
Condition: During our audit of the Organization’s federal awards, we identified deficiencies in the
grantee’s cash management procedures related to advance payments received from federal awarding
agencies. Specifically, the grantee did not segregate advance payments into separate insured interestbearing
accounts as required by the Uniform Guidance.
Cause: The Organization did not have adequate policies and procedures or internal controls in place to
ensure compliance with the cash management requirements related to advance payments.
Effect: The federal awarding agency did not receive interest that could have been earned on the
advances. All advances received during 2024 were expended by December 31, 2024. There was no loss
from uninsured funds or from lack of segregating funds into separate accounts.
Recommendation: We recommend that the Organization implement policies and procedures to ensure
that all advance payments are deposited into separate, insured, interest-bearing accounts as required.
The Organization should also establish controls to track interest earned on these accounts and remit
amounts due to the federal awarding agencies in a timely manner. Training should be provided to staff
responsible for cash management to ensure ongoing compliance with federal requirements.
Views of Responsible Officials: Management agrees with the finding and procedures have been
implemented to address the related issues.
Criteria: According to 2 CFR §200.214, nonfederal entities other than states must follow the suspension
and debarment standards set out at 2 CFR Part 180, which restrict making Federal awards, subawards,
and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or
participating in Federal awards.
Condition: During our audit of the Organization's federal awards, we identified a deficiency in the
grantee’s procurement, suspension, and debarment procedures related to suspension and debarment for
4 of 4 subcontractors we reviewed. Specifically, the grantee did not verify that subcontractors were not
excluded or disqualified before entering into transactions expected to exceed $25,000 in accordance with
the Uniform Guidance.
Cause: The Organization did not have adequate policies and procedures or internal controls in place to
ensure compliance with the procurement, suspension, and debarment requirements.
Effect: The Organization may be paying subcontractors that are suspended or debarred, which would be
unallowable costs. However, none of the 4 subcontractors were suspended or debarred as of the date
audit procedures were performed.
Recommendation: We recommend that the Organization implement policies and procedures to ensure
that all subcontractors and subrecipients of covered transactions are properly verified before entering into
transactions, and that this be documented as a control each time it is performed.
Views of Responsible Officials: Management agrees with the finding and procedures have been
implemented to address the related issues.
Criteria: According to 2 CFR §200.305(b), when a non-federal entity receives advance payments of
federal funds, it must deposit those funds in interest-bearing accounts, unless certain exceptions apply,
and must remit any interest earned on advances in excess of $500 per year to the federal agency.
Furthermore, advance payments should be segregated to ensure proper tracking and safeguarding of
federal funds.
Condition: During our audit of the Organization’s federal awards, we identified deficiencies in the
grantee’s cash management procedures related to advance payments received from federal awarding
agencies. Specifically, the grantee did not segregate advance payments into separate insured interestbearing
accounts as required by the Uniform Guidance.
Cause: The Organization did not have adequate policies and procedures or internal controls in place to
ensure compliance with the cash management requirements related to advance payments.
Effect: The federal awarding agency did not receive interest that could have been earned on the
advances. All advances received during 2024 were expended by December 31, 2024. There was no loss
from uninsured funds or from lack of segregating funds into separate accounts.
Recommendation: We recommend that the Organization implement policies and procedures to ensure
that all advance payments are deposited into separate, insured, interest-bearing accounts as required.
The Organization should also establish controls to track interest earned on these accounts and remit
amounts due to the federal awarding agencies in a timely manner. Training should be provided to staff
responsible for cash management to ensure ongoing compliance with federal requirements.
Views of Responsible Officials: Management agrees with the finding and procedures have been
implemented to address the related issues.
Criteria: According to 2 CFR §200.214, nonfederal entities other than states must follow the suspension
and debarment standards set out at 2 CFR Part 180, which restrict making Federal awards, subawards,
and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or
participating in Federal awards.
Condition: During our audit of the Organization's federal awards, we identified a deficiency in the
grantee’s procurement, suspension, and debarment procedures related to suspension and debarment for
4 of 4 subcontractors we reviewed. Specifically, the grantee did not verify that subcontractors were not
excluded or disqualified before entering into transactions expected to exceed $25,000 in accordance with
the Uniform Guidance.
Cause: The Organization did not have adequate policies and procedures or internal controls in place to
ensure compliance with the procurement, suspension, and debarment requirements.
Effect: The Organization may be paying subcontractors that are suspended or debarred, which would be
unallowable costs. However, none of the 4 subcontractors were suspended or debarred as of the date
audit procedures were performed.
Recommendation: We recommend that the Organization implement policies and procedures to ensure
that all subcontractors and subrecipients of covered transactions are properly verified before entering into
transactions, and that this be documented as a control each time it is performed.
Views of Responsible Officials: Management agrees with the finding and procedures have been
implemented to address the related issues.
Criteria: According to 2 CFR §200.305(b), when a non-federal entity receives advance payments of
federal funds, it must deposit those funds in interest-bearing accounts, unless certain exceptions apply,
and must remit any interest earned on advances in excess of $500 per year to the federal agency.
Furthermore, advance payments should be segregated to ensure proper tracking and safeguarding of
federal funds.
Condition: During our audit of the Organization’s federal awards, we identified deficiencies in the
grantee’s cash management procedures related to advance payments received from federal awarding
agencies. Specifically, the grantee did not segregate advance payments into separate insured interestbearing
accounts as required by the Uniform Guidance.
Cause: The Organization did not have adequate policies and procedures or internal controls in place to
ensure compliance with the cash management requirements related to advance payments.
Effect: The federal awarding agency did not receive interest that could have been earned on the
advances. All advances received during 2024 were expended by December 31, 2024. There was no loss
from uninsured funds or from lack of segregating funds into separate accounts.
Recommendation: We recommend that the Organization implement policies and procedures to ensure
that all advance payments are deposited into separate, insured, interest-bearing accounts as required.
The Organization should also establish controls to track interest earned on these accounts and remit
amounts due to the federal awarding agencies in a timely manner. Training should be provided to staff
responsible for cash management to ensure ongoing compliance with federal requirements.
Views of Responsible Officials: Management agrees with the finding and procedures have been
implemented to address the related issues.
Criteria: According to 2 CFR §200.214, nonfederal entities other than states must follow the suspension
and debarment standards set out at 2 CFR Part 180, which restrict making Federal awards, subawards,
and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or
participating in Federal awards.
Condition: During our audit of the Organization's federal awards, we identified a deficiency in the
grantee’s procurement, suspension, and debarment procedures related to suspension and debarment for
4 of 4 subcontractors we reviewed. Specifically, the grantee did not verify that subcontractors were not
excluded or disqualified before entering into transactions expected to exceed $25,000 in accordance with
the Uniform Guidance.
Cause: The Organization did not have adequate policies and procedures or internal controls in place to
ensure compliance with the procurement, suspension, and debarment requirements.
Effect: The Organization may be paying subcontractors that are suspended or debarred, which would be
unallowable costs. However, none of the 4 subcontractors were suspended or debarred as of the date
audit procedures were performed.
Recommendation: We recommend that the Organization implement policies and procedures to ensure
that all subcontractors and subrecipients of covered transactions are properly verified before entering into
transactions, and that this be documented as a control each time it is performed.
Views of Responsible Officials: Management agrees with the finding and procedures have been
implemented to address the related issues.