Condition: During the fiscal year ended June 30, 2025, NeoMed Center, Inc. used the advance payment method through the HHS Payment Management System (PMS) to obtain federal funds. In certain instances, drawdowns were requested based on aggregated projections and liquidity needs before specific eligi...
Condition: During the fiscal year ended June 30, 2025, NeoMed Center, Inc. used the advance payment method through the HHS Payment Management System (PMS) to obtain federal funds. In certain instances, drawdowns were requested based on aggregated projections and liquidity needs before specific eligible expenses were fully identified and ready for immediate disbursement. Although the funds were later applied to eligible expenses incurred within the authorized award periods, the absence of a documented, expense-level linkage at the time of each drawdown created a temporary timing difference between cash receipt and expense recognition. Accordingly, funds that did not meet revenue recognition criteria at the end were recorded as Unearned Revenue. Consistent with U.S. GAAP and federal grant revenue recognition policies, the Unearned Revenue balance of approximately $1.8 million as of June 30, 2025, represents federal funds received in advance, for which revenue recognition was contingent on incurring future eligible expenses. This balance was analyzed, reconciled, and recognized as eligible expenses were incurred, as supported by reconciliations provided to the external auditors, and was appropriately disclosed in the notes to the financial statements for the years ended June 30, 2025, and 2024. Planned Corrective Action: To prevent recurrence, NeoMed Center, Inc. adopted and implemented “Federal Fund Drawdown via HHS Payment Management System (PMS)” (Policy No. NMCIP 46), approved by the Board of Directors and effective March 2026. The policy requires drawdowns to be based solely on immediate cash needs, supported by a documented short-term cash forecast, and prohibits requesting funds for expenses not yet incurred or not ready for immediate disbursement. Key internal controls include: • Mandatory preparation of a cash forecast by award prior to each drawdown. • Independent review and approval by the Finance Department prior to submission of drawdown requests in PMS. • Monthly reconciliations between PMS, bank accounts, and the general ledger. • Monitoring of the time elapsed between the receipt of funds and their disbursement, with a maximum internal standard of three (3) business days. • Documentation and formal approval of any exceptions. • Adoption of an internal benchmark of 8.33% per month (1/12 of the annual award) as a control parameter. • Clear definition of segregation of duties; and • Periodic reporting to Senior Management and the CEO. Management concludes that this matter resulted from cash-management timing and not from misuse of federal funds. Monitoring: Management will perform monthly monitoring of federal fund drawdowns beginning April 1st ,2026 to ensure they are limited to immediate cash needs and supported by documented short‑term cash forecasts. Drawdowns will be reconciled monthly to the general ledger, bank statements, and allowable expenditures incurred within the approved period of performance. Any timing variances or exceptions will be reviewed and documented. Monitoring results will be reviewed by senior management to ensure continued compliance with Uniform Guidance requirements. Responsible Official: Jose A. Guzman Machuca Time frame: This condition was identified on February 20, 2026, and is expected to be resolved by May 2026, upon the implementation of formal monitoring procedures and enhanced remittance controls.