Audit 5226

FY End
2022-12-31
Total Expended
$3.16M
Findings
24
Programs
8
Organization: The Scintillon Institute (CA)
Year: 2022 Accepted: 2023-12-04
Auditor: Leaf & Cole LLP

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
3193 2022-001 Significant Deficiency Yes C
3194 2022-001 Significant Deficiency Yes C
3195 2022-001 Significant Deficiency Yes C
3196 2022-001 Significant Deficiency Yes C
3197 2022-001 Significant Deficiency Yes C
3198 2022-001 Significant Deficiency Yes C
3199 2022-001 Significant Deficiency Yes C
3200 2022-001 Significant Deficiency Yes C
3201 2022-001 Significant Deficiency Yes C
3202 2022-001 Significant Deficiency Yes C
3203 2022-001 Significant Deficiency Yes C
3204 2022-001 Significant Deficiency Yes C
579635 2022-001 Significant Deficiency Yes C
579636 2022-001 Significant Deficiency Yes C
579637 2022-001 Significant Deficiency Yes C
579638 2022-001 Significant Deficiency Yes C
579639 2022-001 Significant Deficiency Yes C
579640 2022-001 Significant Deficiency Yes C
579641 2022-001 Significant Deficiency Yes C
579642 2022-001 Significant Deficiency Yes C
579643 2022-001 Significant Deficiency Yes C
579644 2022-001 Significant Deficiency Yes C
579645 2022-001 Significant Deficiency Yes C
579646 2022-001 Significant Deficiency Yes C

Programs

Contacts

Name Title Type
WAADZMTALN67 Erica, Chavin Auditee
8586589145 Jill Branch Auditor
No contacts on file

Notes to SEFA

Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass-through entity identifying numbers are presented where available. De Minimis Rate Used: N Rate Explanation: The Scintillon Institute has elected not to use the 10-percent de minimis indirect cost rate as allowed under Uniform Guidance.

Finding Details

2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.
2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.
2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.
2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.
2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.
2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.
2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.
2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.
2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.
2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.
2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.
2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.
2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.
2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.
2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.
2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.
2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.
2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.
2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.
2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.
2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.
2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.
2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.
2022‐001: Cash Management – Research and Development Cluster Condition Funds were drawn down by the Institute in excess of the three‐day period recommended by its funding agency, and did not minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient during the year ended December 31, 2022. Criteria Cash management under 2 CFR 215.22 states that payment methods shall minimize the time elapsing between the transfers of funds from the grantor to the issue of payment by the recipient. Cause The Institute’s preparation and review procedures over the draw‐down of funds were insufficient to minimize the time elapsing between the transfers of funds from the grantor to the issue of payments by the Institute. Effect The Institute was not in compliance with the cash management compliance requirements stated in 2 CFR 215.22 during the year. Recommendation The Institute should improve policies and procedures regarding cash management. This should include the procedure for calculating the allowable cash draw for actual immediate cash needs for expenses to be paid within the three‐day period, in order to minimize the time elapsing between the transfer of funds from the grantor to the issue of payment by the recipient to cover operating cash flow needs.