Audit 403295

Finding: 2025-002 – Cash Management – Significant Deficiency in Controls over Compliance and immaterial instance of non-compliance Department: United States Department of Health and Human Services Program Name: Assistance for Torture Victims Federal Assistance Listing Number: 93.604 Criteria: 2 CFR 200.303: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework” issued by COSO. 2 CFR 200.305 mandates that federal payments, including reimbursement, must minimize the time elapsing between fund transfer and disbursement. Condition/Context: During our walkthroughs of the cash draw process, the Organization indicated that evidence supporting preparation of the draw and review of the draw is not retained in its books and records. Additionally, the Organization drew funds in excess of their immediate cash needs, totaling approximately $350,000. Cause: Management did not have a documented policy and set of documented procedures in place to ensure consistent application of an independent review and memorializing that review. Effect: Draws in excess of amounts incurred may not be spent within three days. Further, any amounts claimed that are not allowable grant expenditures may be disallowed by the granting agency. Questioned Costs: None Repeat finding: This is a repeat finding – see prior year 2024-002. Recommendation: We recommend that the Organization establish a written policy and procedures for cash management that should be reviewed and approved by those charged with governance. The policy should require that all draws be reviewed by someone independent of the individual calculating the draw. The review should be documented in the Organization’s books and records. Views of responsible officials and planned corrective actions: Management agrees with the recommendation and has established a written policy and implemented a documented process for the preparation and review of federal drawdowns, including clear evidence of review such as signoffs or electronic approvals.