The University is currently following and believes it is in compliance with the cash management regulations as written in 2 CFR Part 200.305(b) which require the organization to minimize the time lapse between request for reimbursement from sponsoring agencies and vendor payment. We understand that ...
The University is currently following and believes it is in compliance with the cash management regulations as written in 2 CFR Part 200.305(b) which require the organization to minimize the time lapse between request for reimbursement from sponsoring agencies and vendor payment. We understand that variations remain in the interpretation of the cash management compliance requirement. For example, on October 20, 2017, the Council On Governmental Relations (COGR) wrote a letter to the Office of Financial Management expressing concern that the cash management requirement language in the 2017 Compliance Supplement was not aligned with the requirements for cash management as currently written in 2 CFR Part 200.305(b). COGR?s position is that the Compliance Supplement should be revised to conform with the cash management requirements as written in 2 CFR 200.305(b). The University agrees with COGR?s position and believes the language in the Compliance supplement leads to an unrealistic and unreasonable administrative burden for universities and possibly a reconfiguration of smoothly running electronic process or a complete replacement of electronic processes with an inefficient, manual one in efforts to ensure each vendor has been paid prior to requesting reimbursement from the sponsoring agency. The University will continue to monitor the OMB interpretation of the Cash Management requirements. For FY22, we note that the overall number of exceptions has decreased. Furthermore, the payments identified as exceptions in the FY22 audit were almost all made to vendors within our institutional standard terms of net 45 days, with the exception of 1 which was made 51 days after the request for reimbursement. The Office of Research Services remains committed to ensuring that the federal government is not unfairly disadvantaged by our processes. To that end, during the fall of 2022, the University implemented certain enhancements to further minimize the time lapse between request for reimbursement from sponsoring agencies and vendor payment. A custom process was implemented in the University?s financial system to update payment terms to `immediate? for vendor invoices on Line of Credit sponsored awards. In addition, the University added a new metric to the reporting dashboard for its Procure-to-Pay system to specifically highlight Purchase Order invoices for sponsored awards which were on hold, to assist the university business and grant managers in prioritizing the resolution of those holds preventing 2 invoices on sponsored awards from being paid immediately. We expect to see the impact of these enhancements in the FY23 audit.