Audit 406187

Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR 200.305(b)). Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR 200.1). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the US Treasury and disbursement by the nonfederal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR 200.305(b)(1)). The reimbursement payment method is the preferred payment method if (a) the non-federal entity cannot meet the requirements in 2 CFR 200.305(b)(1) for advance payment, (b) the federal awarding agency sets a specific condition for use of the reimbursement or (c) if requested by the non-federal entity (2 CFR 200.305(b)(3) and 200.208). The reimbursement payment method also may be used on a federal award for construction or for other construction activity as specified in 2 CFR 200.305(b)(3). To the extent available, the non-federal entity must disburse funds available from program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries, and interest earned on such funds before requesting additional federal cash draws (2 CFR 200.305(b)(5)). Except for interest exempt under the Indian Self-Determination and Education Assistance Act (25 USC 5301 et seq.), interest earned by non-federal entities other than states on advances of federal funds is required to be remitted annually to the US Department of Health and Human Services, Payment Management System, P.O. Box 6021, Rockville, MD 20852. Up to $500 per year may be kept for administrative expenses (2 CFR 200.305(b)(9)). During testing of federal compliance, we noted the City drew federal funds for expenses paid by another funding source. This resulted in the City accumulating a federal cash balance of $2,260,553. The City inquired with the grantor about the cash balance and was instructed to pay the next few project invoices with the cash balance until fully expended. Further, we noted that two of the five remaining draws in 2025 were held by the City in excess of five days. Estimated interest earned in 2025 on the balance of federal grants held is $27,658. Estimated interest in 2024 on the balance of federal grants held is $14,811. Finally, we noted the City does not have a federal cash management policy. The City should implement additional procedures to ensure they minimize the time elapsing between the transfer of funds from the US Treasury and disbursement by the City. Further, the City should adopt a written policy regarding cash management of federal funds.

The EPA assistance agreement, in accordance with 2 CFR 200.328, required the recipient to submit semi-annual progress reports and an annual financial report by the dates specified in the award. Recipients must use the standard financial reporting forms or such other forms as may be authorized by OMB (approval is indicated by an OMB paperwork control number on the form) when reporting to the Federal awarding agency. Each recipient must report program outlays and program income on a cash or accrual basis, as prescribed by the Federal awarding agency. If the Federal awarding agency requires reporting of accrual information and the recipient’s accounting records are not normally maintained on the accrual basis, the recipient is not required to convert its accounting system to an accrual basis but may develop such accrual information through analysis of available documentation. The Federal awarding agency may accept identical information from the recipient in machine-readable format, computer printouts, or electronic outputs in lieu of closed formats or on paper. The standard financial reporting forms for grants and cooperative agreements are as follows: - Federal Financial Report (FFR) (SF-425/SF-425A) (OMB No. 0348-0061)). Recipients use the FFR as a standardized format to report expenditures under Federal awards, as well as, when applicable, cash status (lines 10.a, 10.b, and 10c). References to this report include its applicability as both an expenditure and a cash status report unless otherwise indicated. The recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period (2 CFR 200.328(c). Performance and Special Reporting Non-Federal entities may be required to submit performance reports at least annually but not more frequently than quarterly, except in unusual circumstances, using a form or format authorized by OMB (2 CFR 200.329(c)(1)). They also may be required to submit special reports as required by the terms and conditions of the Federal award. Per the conditions of the award, the City was required to submit semi-annual progress reports and an annual financial report. During the audit period, the City did not submit the first progress report on time and the second report was not submitted. We also found that the financial report was submitted outside of the 90 day time period in which it should have been submitted. The City should implement additional procedures to ensure compliance with federal reporting requirements.