Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
Assistance Listing Number: 84.425U Program Title: COVID-19 Education Stabilization Fund - American Rescue Plan ? ESSER III ? MFT & Operating Fund Federal Award Number: N/A Federal Award Year: 2021/2022 Pass Through Entity: Chicago Public Schools Criteria: In accordance with 2 CFR 200.303, the non-Federal entity must 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. Condition: The Organization is either lacking or has nonconforming written policies and procedures for the following administrative functions, required by the Uniform Guidance: 1. Financial management - 2 CFR 200.302(b)(6) 2. Allowable Costs - 2 CFR 200.302(b)(7) 3. Federal payment - 2 CFR 200.305(b)(1) 4. Procurement - 2 CFR 200.318(a) and 2 CFR 200.318(c)(1) 5. Competition - 2 CFR 200.319(d) 6. Methods of procurement to be followed - 2 CFR 200.320 7. Compensation (Personal Services) - 2 CFR 200.430(a)(1) 8. Compensation (Fringe Benefits - Leave) - 2 CFR 200.431(b)(1) 9. Relocation costs of employees - 2 CFR 200.464(a)(2) 10. Travel costs - 2 CFR 200.474 Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our review of the Organization?s policies and procedures, which were found to be not in accordance with Uniform Guidance. Cause: The Organization was not aware of the specific Uniform Guidance requirements for certain written policies and procedures. Effect: The Organization did not have these policies and procedures in place to reasonably ensure that program functions are achieved effectively, efficiently and in compliance with Federal statutes, regulations, and the terms and conditions of the award. The Organization was not in compliance with the administrative requirements set forth in the Uniform Guidance. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization design procedures and implement internal control procedures to ensure that the Uniform Guidance administrative requirements are met. Views of Responsible Officials and Corrective Action Plan: Management agrees with this finding and plans on implementing the appropriate policies and procedures in accordance with Uniform Guidance.
Assistance Listing Number: 84.425U Program Title: COVID-19 Education Stabilization Fund - American Rescue Plan ? ESSER III ? MFT & Operating Fund Federal Award Number: N/A Federal Award Year: 2021/2022 Pass Through Entity: Chicago Public Schools Criteria: In accordance with 2 CFR 200.303, the non-Federal entity must 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. Condition: The Organization is either lacking or has nonconforming written policies and procedures for the following administrative functions, required by the Uniform Guidance: 1. Financial management - 2 CFR 200.302(b)(6) 2. Allowable Costs - 2 CFR 200.302(b)(7) 3. Federal payment - 2 CFR 200.305(b)(1) 4. Procurement - 2 CFR 200.318(a) and 2 CFR 200.318(c)(1) 5. Competition - 2 CFR 200.319(d) 6. Methods of procurement to be followed - 2 CFR 200.320 7. Compensation (Personal Services) - 2 CFR 200.430(a)(1) 8. Compensation (Fringe Benefits - Leave) - 2 CFR 200.431(b)(1) 9. Relocation costs of employees - 2 CFR 200.464(a)(2) 10. Travel costs - 2 CFR 200.474 Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our review of the Organization?s policies and procedures, which were found to be not in accordance with Uniform Guidance. Cause: The Organization was not aware of the specific Uniform Guidance requirements for certain written policies and procedures. Effect: The Organization did not have these policies and procedures in place to reasonably ensure that program functions are achieved effectively, efficiently and in compliance with Federal statutes, regulations, and the terms and conditions of the award. The Organization was not in compliance with the administrative requirements set forth in the Uniform Guidance. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization design procedures and implement internal control procedures to ensure that the Uniform Guidance administrative requirements are met. Views of Responsible Officials and Corrective Action Plan: Management agrees with this finding and plans on implementing the appropriate policies and procedures in accordance with Uniform Guidance.
Criteria: Per 2 CFR section 200.305(b)(5), the entity is required to pay for the costs before the date of the reimbursement request. Condition: The Organization was unable to provide adequate audit support for reimbursement requests during the fiscal year under audit. Cause: The Organization did not have adequate internal controls to ensure documentation was maintained to support reimbursement requests. Effect: The lack of internal controls surrounding the cash management compliance requirement could lead to potential funding issues in the future. Questioned Costs: None. Repeat Finding: N/A, first year for this finding. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Organization Response: Management agrees with this finding.
Criteria: Per 2 CFR section 200.305(b)(5), the entity is required to pay for the costs before the date of the reimbursement request. Condition: The Organization was unable to provide adequate audit support for reimbursement requests during the fiscal year under audit. Cause: The Organization did not have adequate internal controls to ensure documentation was maintained to support reimbursement requests. Effect: The lack of internal controls surrounding the cash management compliance requirement could lead to potential funding issues in the future. Questioned Costs: None. Repeat Finding: N/A, first year for this finding. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Organization Response: Management agrees with this finding.
FINDING 2022-005: CRIME VICTIM ASSISTANCE (16.575) ? CASH MANAGEMENT ? REIMBURSEMENT REQUESTS AND SUPPORTING DOCUMENTATION FINDING TYPE: Federal Awards ? Material Weakness/Noncompliance CRITERIA: 2 CFR section 200.305(b)(3) states that a non-Federal entity must incur costs prior to the date of the reimbursement request when the reimbursement method is used. Supporting documentation must be maintained. CONDITION: The auditor noted, while testing a sample of reimbursement requests for Crime Victim Assistance for compliance and adherence to internal controls, that several reimbursement requests in excess of materiality were requested in advance of any expenses being incurred. The auditor noted, in particular, several large final drawdowns for a grant with a period ending on 9/30/21. The amounts requested were based off budgeted and estimated amounts. It was difficult for the auditor to determine that eligible costs were incurred before the close of the grant period. CAUSE: Turnover at the accounting position and override of controls lead to accidental and non-compliant reimbursement requests. EFFECT: Safenet, Inc. was not in compliance with cash management compliance requirements and internal controls were not functioning in a manner that would ensure proper reimbursement requests. Excess funds could have potentially been drawn and not expended. QUESTIONED COST: Undetermined RECOMMENDATION: Management should ensure internal controls are designed in a manner that ensures reimbursement requests are based off expenses that have been incurred prior to the date of the reimbursement request. Requests should be reviewed by someone other than the preparer and should agree to supporting documentation. VIEWS OF RESPONSIBLE OFFICIALS: Management agrees with the finding.
2022-001 Activities Allowed or Unallowed and Allowable Costs/Cost Principles / Types of Services Allowed or Disallowed, Cash Management, and Reporting U.S. Department of Health and Human Services: Passed through State of New Jersey, Department of Health: COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (SARS-COV-2 Hospital Testing) Federal Grant Number and Years: PHLP21CHT017 (7/1/2021 ? 6/30/2022) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Findings: None Criteria: Activities Allowed or Unallowed and Allowable Costs/Cost Principles / Types of Services Allowed or Disallowed - Except where otherwise authorized by statute, costs must be adequately documented in order to be allowable under Federal awards (2 CFR Section 200.404). Cash Management - Except where otherwise authorized by statute, when non-federal entities are funded under the reimbursement method, costs must be adequately documented as paid prior to the date of the reimbursement request (2 CFR section 200.305(b)(3)) Reporting - In accordance with the grant agreement and the reporting requirements for State of New Jersey Department of Health (NJDOH), direct grants and pass-through funds are fulfilled utilizing a Report of Expenditures (ROE). ROEs are prepared and submitted quarterly in order to allow for relevant and reliable information to be provided to the Federal government or State of New Jersey for reimbursement and tracking purposes. The ROEs are the source documents for the grantee to prepare a schedule of expenditures of Federal awards (SEFA) for the period covered by the grantee?s financial statements in accordance with 2 CFR 200.502, Basis for determining Federal awards expended, for the SEFA. Additionally, in accordance with Federal requirements, a non-Federal entity shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context: On a quarterly basis, University Hospital (the Hospital) prepares and reports to New Jersey Department of Health the program expenditures for Federal funding amounts on the ROE, which are then used to prepare the annual SEFA at the end of the fiscal year. The Hospital?s expenditures per the ROE were greater than the expenditures that were supported by the general ledger and accounting records, therefore, the Hospital submitted the ROE and claim towards the grant for reimbursement above the amount allowed by $405,971, due to a double counting of previously reimbursed costs. Further, the Hospital?s indirect costs charged were greater than the allowable amount by $3,514. The original amount reported on the SEFA by the Hospital and charged to the State was $3,142,428. The Hospital has adjusted the SEFA to account for allowable costs, which is $2,732,943. The Hospital?s policies and procedures to ensure compliance with the above compliance requirements did not include certain internal controls that were designed properly and operating effectively to ensure that the Hospital has adequate supporting accounting records for allowable costs claimed and reported on the ROE and SEFA. Cause: Management's review of the ROE did not identify the double counting of previously reimbursed costs, therefore, the review was not performed at the appropriate level of precision in accordance with its design. Effect: The Hospital overcharged the grant by $409,485. Questioned Costs: $409,485 Recommendation: We recommend that the Hospital strengthen its procedures to ensure that the quarterly ROEs include the correct amount of allowable expenditures based upon the general ledger and accounting records and reflected on the SEFA and that the review of the ROE is properly performed prior to submission for reimbursement.
Finding No. 2022-003 Cash Management Federal Program Research and Development Cluster ALNs ALN 93.396, 93.279, 93.846 Federal Agencies Department of Health and Human Services Federal Award Years July 1, 2021 to June 30, 2022 Criteria or Requirement Per 2 CFR section 200.305(b)(3), non-federal entities that are funded under the reimbursement method are required to pay for the costs for which reimbursement was requested prior to the date of the reimbursement request. Condition and Context For 3 of the 40 samples tested, taxes were properly accrued as allowable costs but were drawn prior to payment by the University. While these costs are deemed allowable, they were not paid for prior to seeking reimbursement from the federal agency. The taxes drawn prior to payment totaled $4,035 out of a total of $784,941 tested in the sample of 40. Cause and Potential Effect The control to ensure that all costs were paid for prior to seeking reimbursement was not operating effectively to identify instances of noncompliance related to the applicable taxes. Questioned Cost The known unallowable costs identified in our sample items totaled $4,035. Management?s analysis identified a total of $51,803. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation We recommend that the University strengthen its processes and controls within the procurement office to ensure that all costs are paid prior to seeking reimbursement. View of Responsible Officials Management of the University takes no exception to this reported finding and has subsequently paid the applicable taxes and related interest. We have implemented the remedial actions as outlined in our Corrective Action Plan.
Finding No. 2022-003 Cash Management Federal Program Research and Development Cluster ALNs ALN 93.396, 93.279, 93.846 Federal Agencies Department of Health and Human Services Federal Award Years July 1, 2021 to June 30, 2022 Criteria or Requirement Per 2 CFR section 200.305(b)(3), non-federal entities that are funded under the reimbursement method are required to pay for the costs for which reimbursement was requested prior to the date of the reimbursement request. Condition and Context For 3 of the 40 samples tested, taxes were properly accrued as allowable costs but were drawn prior to payment by the University. While these costs are deemed allowable, they were not paid for prior to seeking reimbursement from the federal agency. The taxes drawn prior to payment totaled $4,035 out of a total of $784,941 tested in the sample of 40. Cause and Potential Effect The control to ensure that all costs were paid for prior to seeking reimbursement was not operating effectively to identify instances of noncompliance related to the applicable taxes. Questioned Cost The known unallowable costs identified in our sample items totaled $4,035. Management?s analysis identified a total of $51,803. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation We recommend that the University strengthen its processes and controls within the procurement office to ensure that all costs are paid prior to seeking reimbursement. View of Responsible Officials Management of the University takes no exception to this reported finding and has subsequently paid the applicable taxes and related interest. We have implemented the remedial actions as outlined in our Corrective Action Plan.
Finding No. 2022-003 Cash Management Federal Program Research and Development Cluster ALNs ALN 93.396, 93.279, 93.846 Federal Agencies Department of Health and Human Services Federal Award Years July 1, 2021 to June 30, 2022 Criteria or Requirement Per 2 CFR section 200.305(b)(3), non-federal entities that are funded under the reimbursement method are required to pay for the costs for which reimbursement was requested prior to the date of the reimbursement request. Condition and Context For 3 of the 40 samples tested, taxes were properly accrued as allowable costs but were drawn prior to payment by the University. While these costs are deemed allowable, they were not paid for prior to seeking reimbursement from the federal agency. The taxes drawn prior to payment totaled $4,035 out of a total of $784,941 tested in the sample of 40. Cause and Potential Effect The control to ensure that all costs were paid for prior to seeking reimbursement was not operating effectively to identify instances of noncompliance related to the applicable taxes. Questioned Cost The known unallowable costs identified in our sample items totaled $4,035. Management?s analysis identified a total of $51,803. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation We recommend that the University strengthen its processes and controls within the procurement office to ensure that all costs are paid prior to seeking reimbursement. View of Responsible Officials Management of the University takes no exception to this reported finding and has subsequently paid the applicable taxes and related interest. We have implemented the remedial actions as outlined in our Corrective Action Plan.
Finding 2022-020 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness and Noncompliance over Cash Management Repeat Finding: Yes Condition: For 1 out of 1 selection, we were unable to agree the drawdown amount to the general ledger to ensure funds were being expended prior to requesting the reimbursement. Criteria: In accordance with 2 CFR 200.303: Internal Control, 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. In accordance with 2 CFR 200.305, if unearned revenue balances are identified, balances must be consistent with the requirement to minimize the time between drawing and disbursing Federal funds. If advance payments are identified, verify that the non-Federal entity minimized the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-Federal entity. Under the reimbursement method, ascertain if the entity paid for the costs for which reimbursement was requested prior to the date of the reimbursement request. When a program receives program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries, or interest earned on such funds; ascertain if these funds were disbursed before requesting additional Federal cash draws. Review records to determine if interest in excess of $500 per year was earned on Federal cash draws. If so, determine if it was remitted annually to the Department of Health and Human Services, Payment Management System. According to AM 413-60, Grant Documentation, Grant Manager/Program Manager/Director Conducts ongoing monitoring and control of all reimbursement receipts and deposits until grant ends; as well as all program and sub-recipient (when applicable) documentation, to include: (1) program documentation; (2) timesheets; (3) deliverables; (4) activities; (5) vendor payments; (6) program data/charts/numbers; and (7) financial and compliance report. According to AM 413-61, Grant Management Financial Reporting, Grant Manager/Program Manager/Director maintains all documentation, either electronic or hard copy, for all Federally funded grants for the term of the grant for a minimum of seven years for review and audit by the granting agency or its designee. Finding 2022-020 (continued) Cause: The agency did not reconcile information presented in the expenditure report to the underlying records. Finance and the agency use different parameters for generating reports and there was no documentation of the reconciling differences. Effect: Expenditures reported to the Federal government could be inaccurate. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with reporting requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor?s Conclusion: Finding remains as stated.
Finding 2022-020 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness and Noncompliance over Cash Management Repeat Finding: Yes Condition: For 1 out of 1 selection, we were unable to agree the drawdown amount to the general ledger to ensure funds were being expended prior to requesting the reimbursement. Criteria: In accordance with 2 CFR 200.303: Internal Control, 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. In accordance with 2 CFR 200.305, if unearned revenue balances are identified, balances must be consistent with the requirement to minimize the time between drawing and disbursing Federal funds. If advance payments are identified, verify that the non-Federal entity minimized the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-Federal entity. Under the reimbursement method, ascertain if the entity paid for the costs for which reimbursement was requested prior to the date of the reimbursement request. When a program receives program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries, or interest earned on such funds; ascertain if these funds were disbursed before requesting additional Federal cash draws. Review records to determine if interest in excess of $500 per year was earned on Federal cash draws. If so, determine if it was remitted annually to the Department of Health and Human Services, Payment Management System. According to AM 413-60, Grant Documentation, Grant Manager/Program Manager/Director Conducts ongoing monitoring and control of all reimbursement receipts and deposits until grant ends; as well as all program and sub-recipient (when applicable) documentation, to include: (1) program documentation; (2) timesheets; (3) deliverables; (4) activities; (5) vendor payments; (6) program data/charts/numbers; and (7) financial and compliance report. According to AM 413-61, Grant Management Financial Reporting, Grant Manager/Program Manager/Director maintains all documentation, either electronic or hard copy, for all Federally funded grants for the term of the grant for a minimum of seven years for review and audit by the granting agency or its designee. Finding 2022-020 (continued) Cause: The agency did not reconcile information presented in the expenditure report to the underlying records. Finance and the agency use different parameters for generating reports and there was no documentation of the reconciling differences. Effect: Expenditures reported to the Federal government could be inaccurate. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with reporting requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor?s Conclusion: Finding remains as stated.
Finding 2022-021 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Material Weakness and Noncompliance over Cash Management Repeat Finding: Yes Condition: We were not able to agree the expenditure amount of expenditures per the drawdown request to the expenditure details per the general ledger. Criteria: In accordance with 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. In accordance with 2 CFR 200.305, if unearned revenue balances are identified, balances must be consistent with the requirement to minimize the time between drawing and disbursing Federal funds. If advance payments are identified, verify that the non-Federal entity minimized the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-Federal entity. Under the reimbursement method, ascertain if the entity paid for the costs for which reimbursement was requested prior to the date of the reimbursement request. When a program receives program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries, or interest earned on such funds; ascertain if these funds were disbursed before requesting additional Federal cash draws. Review records to determine if interest in excess of $500 per year was earned on Federal cash draws. If so, determine if it was remitted annually to the Department of Health and Human Services, Payment Management System. According to AM 413-60, Grant Documentation, Grant Manager/Program Manager/Director Conducts ongoing monitoring and control of all reimbursement receipts and deposits until grant ends; as well as all program and sub-recipient (when applicable) documentation, to include: (1) program documentation; (2) timesheets; (3) deliverables; (4) activities; (5) vendor payments; (6) program data/charts/numbers; and (7) financial and compliance report. According to AM 413-61, Grant Management Financial Reporting, Grant Manager/Program Manager/Director maintains all documentation, either electronic or hard copy, for all Federally funded grants for the term of the grant for a minimum of seven years for review and audit by the granting agency or its designee. Finding 2022-021 (continued) Cause: The agency did not reconcile information presented in the expenditure report to the underlying records. Finance and the agency use different parameters for generating reports and there was no documentation of the reconciling differences. Effect: The City may not be in compliance with the cash management requirements in accordance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with cash management requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor?s Conclusion: Finding remains as stated.
Finding 2022-021 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Material Weakness and Noncompliance over Cash Management Repeat Finding: Yes Condition: We were not able to agree the expenditure amount of expenditures per the drawdown request to the expenditure details per the general ledger. Criteria: In accordance with 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. In accordance with 2 CFR 200.305, if unearned revenue balances are identified, balances must be consistent with the requirement to minimize the time between drawing and disbursing Federal funds. If advance payments are identified, verify that the non-Federal entity minimized the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-Federal entity. Under the reimbursement method, ascertain if the entity paid for the costs for which reimbursement was requested prior to the date of the reimbursement request. When a program receives program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries, or interest earned on such funds; ascertain if these funds were disbursed before requesting additional Federal cash draws. Review records to determine if interest in excess of $500 per year was earned on Federal cash draws. If so, determine if it was remitted annually to the Department of Health and Human Services, Payment Management System. According to AM 413-60, Grant Documentation, Grant Manager/Program Manager/Director Conducts ongoing monitoring and control of all reimbursement receipts and deposits until grant ends; as well as all program and sub-recipient (when applicable) documentation, to include: (1) program documentation; (2) timesheets; (3) deliverables; (4) activities; (5) vendor payments; (6) program data/charts/numbers; and (7) financial and compliance report. According to AM 413-61, Grant Management Financial Reporting, Grant Manager/Program Manager/Director maintains all documentation, either electronic or hard copy, for all Federally funded grants for the term of the grant for a minimum of seven years for review and audit by the granting agency or its designee. Finding 2022-021 (continued) Cause: The agency did not reconcile information presented in the expenditure report to the underlying records. Finance and the agency use different parameters for generating reports and there was no documentation of the reconciling differences. Effect: The City may not be in compliance with the cash management requirements in accordance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with cash management requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor?s Conclusion: Finding remains as stated.
Finding 2022-021 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Material Weakness and Noncompliance over Cash Management Repeat Finding: Yes Condition: We were not able to agree the expenditure amount of expenditures per the drawdown request to the expenditure details per the general ledger. Criteria: In accordance with 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. In accordance with 2 CFR 200.305, if unearned revenue balances are identified, balances must be consistent with the requirement to minimize the time between drawing and disbursing Federal funds. If advance payments are identified, verify that the non-Federal entity minimized the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-Federal entity. Under the reimbursement method, ascertain if the entity paid for the costs for which reimbursement was requested prior to the date of the reimbursement request. When a program receives program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries, or interest earned on such funds; ascertain if these funds were disbursed before requesting additional Federal cash draws. Review records to determine if interest in excess of $500 per year was earned on Federal cash draws. If so, determine if it was remitted annually to the Department of Health and Human Services, Payment Management System. According to AM 413-60, Grant Documentation, Grant Manager/Program Manager/Director Conducts ongoing monitoring and control of all reimbursement receipts and deposits until grant ends; as well as all program and sub-recipient (when applicable) documentation, to include: (1) program documentation; (2) timesheets; (3) deliverables; (4) activities; (5) vendor payments; (6) program data/charts/numbers; and (7) financial and compliance report. According to AM 413-61, Grant Management Financial Reporting, Grant Manager/Program Manager/Director maintains all documentation, either electronic or hard copy, for all Federally funded grants for the term of the grant for a minimum of seven years for review and audit by the granting agency or its designee. Finding 2022-021 (continued) Cause: The agency did not reconcile information presented in the expenditure report to the underlying records. Finance and the agency use different parameters for generating reports and there was no documentation of the reconciling differences. Effect: The City may not be in compliance with the cash management requirements in accordance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with cash management requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor?s Conclusion: Finding remains as stated.
Finding 2022-021 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Material Weakness and Noncompliance over Cash Management Repeat Finding: Yes Condition: We were not able to agree the expenditure amount of expenditures per the drawdown request to the expenditure details per the general ledger. Criteria: In accordance with 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. In accordance with 2 CFR 200.305, if unearned revenue balances are identified, balances must be consistent with the requirement to minimize the time between drawing and disbursing Federal funds. If advance payments are identified, verify that the non-Federal entity minimized the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-Federal entity. Under the reimbursement method, ascertain if the entity paid for the costs for which reimbursement was requested prior to the date of the reimbursement request. When a program receives program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries, or interest earned on such funds; ascertain if these funds were disbursed before requesting additional Federal cash draws. Review records to determine if interest in excess of $500 per year was earned on Federal cash draws. If so, determine if it was remitted annually to the Department of Health and Human Services, Payment Management System. According to AM 413-60, Grant Documentation, Grant Manager/Program Manager/Director Conducts ongoing monitoring and control of all reimbursement receipts and deposits until grant ends; as well as all program and sub-recipient (when applicable) documentation, to include: (1) program documentation; (2) timesheets; (3) deliverables; (4) activities; (5) vendor payments; (6) program data/charts/numbers; and (7) financial and compliance report. According to AM 413-61, Grant Management Financial Reporting, Grant Manager/Program Manager/Director maintains all documentation, either electronic or hard copy, for all Federally funded grants for the term of the grant for a minimum of seven years for review and audit by the granting agency or its designee. Finding 2022-021 (continued) Cause: The agency did not reconcile information presented in the expenditure report to the underlying records. Finance and the agency use different parameters for generating reports and there was no documentation of the reconciling differences. Effect: The City may not be in compliance with the cash management requirements in accordance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with cash management requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor?s Conclusion: Finding remains as stated.
Statement of condition: For the Coronavirus State and Local Fiscal Recovery Funds, there were no written policies and procedures. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) 200.302 (b)(6) and (7) states that the non-federal entity must establish written procedures to implement the requirements of 2 CFR 200.305 and written procedures for determining the allowability of costs in accordance with 2 CFR 200 Subpart E as well as terms and conditions of the Federal award. Cause of condition: No controls to establish written policies and procedures when Federal awards are received. Effect of condition: During testing, it was noted that there were no written policies and procedures regarding the Federal award. Context: Policies and procedures were verbally communicated or written during fieldwork to assist with testing. Recommendation: To establish written policies and procedures for Federal awards.
2 CFR ? 400 gives regulatory effect to the Department of Agriculture for 2 CFR ? 200.305(b) which requires that for non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity 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)(3) states reimbursement is the preferred method when the requirements in this paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.208, or when the non-Federal entity requests payment by reimbursement or when the non-Federal entity requests payment by reimbursement. 7 CFR ? 210 relates to the implementation of the National School Lunch Program where the Department provides States with general and special cash assistance and donations of foods acquired by the Department to be used to assist schools in serving nutritious lunches to children each school day. 7 CFR ? 210.7(c) states to be entitled to reimbursement under this part, each school food authority shall ensure that Claims for Reimbursement are limited to the number of free, reduced price and paid lunches and meal supplements that are served to children eligible for free, reduced price and paid lunches and meal supplements, respectively, for each day of operation. Claims for reimbursement should be based on lunch counts, taken daily at the point of service, which correctly identify the number of free, reduced price and paid lunches served to eligible children. Each school food authority should correctly record, consolidate, and report those lunch and supplement counts on the Claim for Reimbursement. The District completed the required site claim forms; however, due to lack of controls over review of the forms for accuracy, the January 2022 site claim form was overstated by 15 meals. The site claim form was used for federal reimbursement to the District and thus resulted in more reimbursements ($68) than the District was entitled to based on free, reduced, and paid lunches. Failure to properly report meals for reimbursement can result in loss of revenue, excess reimbursements, and/or federal questioned costs. The District should establish and implement procedures to verify the accuracy of reimbursement site claim forms.
2 CFR ? 400 gives regulatory effect to the Department of Agriculture for 2 CFR ? 200.305(b) which requires that for non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity 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)(3) states reimbursement is the preferred method when the requirements in this paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.208, or when the non-Federal entity requests payment by reimbursement or when the non-Federal entity requests payment by reimbursement. 7 CFR ? 210 relates to the implementation of the National School Lunch Program where the Department provides States with general and special cash assistance and donations of foods acquired by the Department to be used to assist schools in serving nutritious lunches to children each school day. 7 CFR ? 210.7(c) states to be entitled to reimbursement under this part, each school food authority shall ensure that Claims for Reimbursement are limited to the number of free, reduced price and paid lunches and meal supplements that are served to children eligible for free, reduced price and paid lunches and meal supplements, respectively, for each day of operation. Claims for reimbursement should be based on lunch counts, taken daily at the point of service, which correctly identify the number of free, reduced price and paid lunches served to eligible children. Each school food authority should correctly record, consolidate, and report those lunch and supplement counts on the Claim for Reimbursement. The District completed the required site claim forms; however, due to lack of controls over review of the forms for accuracy, the January 2022 site claim form was overstated by 15 meals. The site claim form was used for federal reimbursement to the District and thus resulted in more reimbursements ($68) than the District was entitled to based on free, reduced, and paid lunches. Failure to properly report meals for reimbursement can result in loss of revenue, excess reimbursements, and/or federal questioned costs. The District should establish and implement procedures to verify the accuracy of reimbursement site claim forms.
2 CFR ? 400 gives regulatory effect to the Department of Agriculture for 2 CFR ? 200.305(b) which requires that for non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity 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)(3) states reimbursement is the preferred method when the requirements in this paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.208, or when the non-Federal entity requests payment by reimbursement or when the non-Federal entity requests payment by reimbursement. 7 CFR ? 210 relates to the implementation of the National School Lunch Program where the Department provides States with general and special cash assistance and donations of foods acquired by the Department to be used to assist schools in serving nutritious lunches to children each school day. 7 CFR ? 210.7(c) states to be entitled to reimbursement under this part, each school food authority shall ensure that Claims for Reimbursement are limited to the number of free, reduced price and paid lunches and meal supplements that are served to children eligible for free, reduced price and paid lunches and meal supplements, respectively, for each day of operation. Claims for reimbursement should be based on lunch counts, taken daily at the point of service, which correctly identify the number of free, reduced price and paid lunches served to eligible children. Each school food authority should correctly record, consolidate, and report those lunch and supplement counts on the Claim for Reimbursement. The District completed the required site claim forms; however, due to lack of controls over review of the forms for accuracy, the January 2022 site claim form was overstated by 15 meals. The site claim form was used for federal reimbursement to the District and thus resulted in more reimbursements ($68) than the District was entitled to based on free, reduced, and paid lunches. Failure to properly report meals for reimbursement can result in loss of revenue, excess reimbursements, and/or federal questioned costs. The District should establish and implement procedures to verify the accuracy of reimbursement site claim forms.
2 CFR ? 400 gives regulatory effect to the Department of Agriculture for 2 CFR ? 200.305(b) which requires that for non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity 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)(3) states reimbursement is the preferred method when the requirements in this paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ?200.208, or when the non-Federal entity requests payment by reimbursement or when the non-Federal entity requests payment by reimbursement. 7 CFR ? 210 relates to the implementation of the National School Lunch Program where the Department provides States with general and special cash assistance and donations of foods acquired by the Department to be used to assist schools in serving nutritious lunches to children each school day. 7 CFR ? 210.7(c) states to be entitled to reimbursement under this part, each school food authority shall ensure that Claims for Reimbursement are limited to the number of free, reduced price and paid lunches and meal supplements that are served to children eligible for free, reduced price and paid lunches and meal supplements, respectively, for each day of operation. Claims for reimbursement should be based on lunch counts, taken daily at the point of service, which correctly identify the number of free, reduced price and paid lunches served to eligible children. Each school food authority should correctly record, consolidate, and report those lunch and supplement counts on the Claim for Reimbursement. The District completed the required site claim forms; however, due to lack of controls over review of the forms for accuracy, the January 2022 site claim form was overstated by 15 meals. The site claim form was used for federal reimbursement to the District and thus resulted in more reimbursements ($68) than the District was entitled to based on free, reduced, and paid lunches. Failure to properly report meals for reimbursement can result in loss of revenue, excess reimbursements, and/or federal questioned costs. The District should establish and implement procedures to verify the accuracy of reimbursement site claim forms.
Finding number: 2022 001 Type of finding: Material weakness in internal control and noncompliance Federal program: Research and Development Cluster ? various Assistance Listing numbers Federal agency: Various Pass through entity: Various Federal award year: July 1, 2021 to June 30, 2022 Compliance Requirement: Cash management Criteria The requirements for cash management are contained in Section 200.305 of Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), the A 102 Common Rule (?_.21), 0MB Circular A 110 (2 CFR section 215.22), Treasury regulations at 31 CFR part 205, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. When entities are funded on a reimbursement basis, program costs must be paid for by entity funds before reimbursement is requested from the Federal Government. Additionally, Section 200.303 of the Uniform Guidance indicates that the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Uniform Guidance also indicates that these internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? (Green Book) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Office of Management and Budget (OMB) has clarified that the references to the Green Book and COSO were only provided as best practices and not requirements. Condition During our test work over the Research and Development Cluster, we selected a sample of expenditures and cash draws/issued invoices to sponsors to verify the expenditures were paid prior to the date of the reimbursement request. We also verified the cash draw was supported by a detail of expenditures that reconciled. For the Research and Development Cluster, we noted 7 expenditures that totaled $4,061 of our sample of 40 expenditures that totaled $95,703 were not paid prior to the reimbursement request. Additionally, we noted 7 draws of our sample of 25 where the draw was over drawn. The total overdraw was $20,298 of the total cash draws tested of $601,919. Additionally, we noted 3 draws were not supported by a detail of expenditures that reconciled. The variance difference was $466. Cause UAMS did not maintain adequate support for cash draws causing unreconciled variances in the draw request detail. Additionally, cash draws were not appropriately reviewed to ensure that the expenditures were paid prior to the reimbursement requests. Effect Failure to properly complete cash draws may prevent UAMS from being in compliance with the requirements set forth by the Uniform Guidance. Questioned costs $463 related to interest on the over draw $466 related to unreconciled variances between the cash draw and the expenditure detail $929 total questioned costs Questioned costs related to the instances where the expenditure was not paid prior to the reimbursement request are not determinable. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding was reported in prior year audit. Recommendation We recommend that management design and implement internal controls that will ensure that program costs are paid before a request for reimbursement is made. Additionally, we recommend that management keep records of what expenditures make up each draw. View of responsible officials We concur with the finding. The instances where expenditures were not paid prior to the reimbursement request was noted in the prior year audit and was corrected as soon as the finding was communicated to management. The exceptions identified in the current year audit were prior to the control process changes made by management to ensure all expenses are paid before reimbursement is requested. There were no exceptions noted after the date of the change from the prior year audit. During the fiscal year, the grants accounting office experienced a significant turnover in staff and leadership in addition to implementing a new financial system. With the new director and staff in place and completing the implementation of the financial system, we believe adequate controls have been established and are working properly to ensure compliance with cash management regulations.
Finding number: 2022 001 Type of finding: Material weakness in internal control and noncompliance Federal program: Research and Development Cluster ? various Assistance Listing numbers Federal agency: Various Pass through entity: Various Federal award year: July 1, 2021 to June 30, 2022 Compliance Requirement: Cash management Criteria The requirements for cash management are contained in Section 200.305 of Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), the A 102 Common Rule (?_.21), 0MB Circular A 110 (2 CFR section 215.22), Treasury regulations at 31 CFR part 205, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. When entities are funded on a reimbursement basis, program costs must be paid for by entity funds before reimbursement is requested from the Federal Government. Additionally, Section 200.303 of the Uniform Guidance indicates that the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Uniform Guidance also indicates that these internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? (Green Book) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Office of Management and Budget (OMB) has clarified that the references to the Green Book and COSO were only provided as best practices and not requirements. Condition During our test work over the Research and Development Cluster, we selected a sample of expenditures and cash draws/issued invoices to sponsors to verify the expenditures were paid prior to the date of the reimbursement request. We also verified the cash draw was supported by a detail of expenditures that reconciled. For the Research and Development Cluster, we noted 7 expenditures that totaled $4,061 of our sample of 40 expenditures that totaled $95,703 were not paid prior to the reimbursement request. Additionally, we noted 7 draws of our sample of 25 where the draw was over drawn. The total overdraw was $20,298 of the total cash draws tested of $601,919. Additionally, we noted 3 draws were not supported by a detail of expenditures that reconciled. The variance difference was $466. Cause UAMS did not maintain adequate support for cash draws causing unreconciled variances in the draw request detail. Additionally, cash draws were not appropriately reviewed to ensure that the expenditures were paid prior to the reimbursement requests. Effect Failure to properly complete cash draws may prevent UAMS from being in compliance with the requirements set forth by the Uniform Guidance. Questioned costs $463 related to interest on the over draw $466 related to unreconciled variances between the cash draw and the expenditure detail $929 total questioned costs Questioned costs related to the instances where the expenditure was not paid prior to the reimbursement request are not determinable. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding was reported in prior year audit. Recommendation We recommend that management design and implement internal controls that will ensure that program costs are paid before a request for reimbursement is made. Additionally, we recommend that management keep records of what expenditures make up each draw. View of responsible officials We concur with the finding. The instances where expenditures were not paid prior to the reimbursement request was noted in the prior year audit and was corrected as soon as the finding was communicated to management. The exceptions identified in the current year audit were prior to the control process changes made by management to ensure all expenses are paid before reimbursement is requested. There were no exceptions noted after the date of the change from the prior year audit. During the fiscal year, the grants accounting office experienced a significant turnover in staff and leadership in addition to implementing a new financial system. With the new director and staff in place and completing the implementation of the financial system, we believe adequate controls have been established and are working properly to ensure compliance with cash management regulations.
Finding number: 2022 001 Type of finding: Material weakness in internal control and noncompliance Federal program: Research and Development Cluster ? various Assistance Listing numbers Federal agency: Various Pass through entity: Various Federal award year: July 1, 2021 to June 30, 2022 Compliance Requirement: Cash management Criteria The requirements for cash management are contained in Section 200.305 of Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), the A 102 Common Rule (?_.21), 0MB Circular A 110 (2 CFR section 215.22), Treasury regulations at 31 CFR part 205, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. When entities are funded on a reimbursement basis, program costs must be paid for by entity funds before reimbursement is requested from the Federal Government. Additionally, Section 200.303 of the Uniform Guidance indicates that the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Uniform Guidance also indicates that these internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? (Green Book) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Office of Management and Budget (OMB) has clarified that the references to the Green Book and COSO were only provided as best practices and not requirements. Condition During our test work over the Research and Development Cluster, we selected a sample of expenditures and cash draws/issued invoices to sponsors to verify the expenditures were paid prior to the date of the reimbursement request. We also verified the cash draw was supported by a detail of expenditures that reconciled. For the Research and Development Cluster, we noted 7 expenditures that totaled $4,061 of our sample of 40 expenditures that totaled $95,703 were not paid prior to the reimbursement request. Additionally, we noted 7 draws of our sample of 25 where the draw was over drawn. The total overdraw was $20,298 of the total cash draws tested of $601,919. Additionally, we noted 3 draws were not supported by a detail of expenditures that reconciled. The variance difference was $466. Cause UAMS did not maintain adequate support for cash draws causing unreconciled variances in the draw request detail. Additionally, cash draws were not appropriately reviewed to ensure that the expenditures were paid prior to the reimbursement requests. Effect Failure to properly complete cash draws may prevent UAMS from being in compliance with the requirements set forth by the Uniform Guidance. Questioned costs $463 related to interest on the over draw $466 related to unreconciled variances between the cash draw and the expenditure detail $929 total questioned costs Questioned costs related to the instances where the expenditure was not paid prior to the reimbursement request are not determinable. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding was reported in prior year audit. Recommendation We recommend that management design and implement internal controls that will ensure that program costs are paid before a request for reimbursement is made. Additionally, we recommend that management keep records of what expenditures make up each draw. View of responsible officials We concur with the finding. The instances where expenditures were not paid prior to the reimbursement request was noted in the prior year audit and was corrected as soon as the finding was communicated to management. The exceptions identified in the current year audit were prior to the control process changes made by management to ensure all expenses are paid before reimbursement is requested. There were no exceptions noted after the date of the change from the prior year audit. During the fiscal year, the grants accounting office experienced a significant turnover in staff and leadership in addition to implementing a new financial system. With the new director and staff in place and completing the implementation of the financial system, we believe adequate controls have been established and are working properly to ensure compliance with cash management regulations.
Finding number: 2022 001 Type of finding: Material weakness in internal control and noncompliance Federal program: Research and Development Cluster ? various Assistance Listing numbers Federal agency: Various Pass through entity: Various Federal award year: July 1, 2021 to June 30, 2022 Compliance Requirement: Cash management Criteria The requirements for cash management are contained in Section 200.305 of Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), the A 102 Common Rule (?_.21), 0MB Circular A 110 (2 CFR section 215.22), Treasury regulations at 31 CFR part 205, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. When entities are funded on a reimbursement basis, program costs must be paid for by entity funds before reimbursement is requested from the Federal Government. Additionally, Section 200.303 of the Uniform Guidance indicates that the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Uniform Guidance also indicates that these internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? (Green Book) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Office of Management and Budget (OMB) has clarified that the references to the Green Book and COSO were only provided as best practices and not requirements. Condition During our test work over the Research and Development Cluster, we selected a sample of expenditures and cash draws/issued invoices to sponsors to verify the expenditures were paid prior to the date of the reimbursement request. We also verified the cash draw was supported by a detail of expenditures that reconciled. For the Research and Development Cluster, we noted 7 expenditures that totaled $4,061 of our sample of 40 expenditures that totaled $95,703 were not paid prior to the reimbursement request. Additionally, we noted 7 draws of our sample of 25 where the draw was over drawn. The total overdraw was $20,298 of the total cash draws tested of $601,919. Additionally, we noted 3 draws were not supported by a detail of expenditures that reconciled. The variance difference was $466. Cause UAMS did not maintain adequate support for cash draws causing unreconciled variances in the draw request detail. Additionally, cash draws were not appropriately reviewed to ensure that the expenditures were paid prior to the reimbursement requests. Effect Failure to properly complete cash draws may prevent UAMS from being in compliance with the requirements set forth by the Uniform Guidance. Questioned costs $463 related to interest on the over draw $466 related to unreconciled variances between the cash draw and the expenditure detail $929 total questioned costs Questioned costs related to the instances where the expenditure was not paid prior to the reimbursement request are not determinable. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding was reported in prior year audit. Recommendation We recommend that management design and implement internal controls that will ensure that program costs are paid before a request for reimbursement is made. Additionally, we recommend that management keep records of what expenditures make up each draw. View of responsible officials We concur with the finding. The instances where expenditures were not paid prior to the reimbursement request was noted in the prior year audit and was corrected as soon as the finding was communicated to management. The exceptions identified in the current year audit were prior to the control process changes made by management to ensure all expenses are paid before reimbursement is requested. There were no exceptions noted after the date of the change from the prior year audit. During the fiscal year, the grants accounting office experienced a significant turnover in staff and leadership in addition to implementing a new financial system. With the new director and staff in place and completing the implementation of the financial system, we believe adequate controls have been established and are working properly to ensure compliance with cash management regulations.
Finding number: 2022 001 Type of finding: Material weakness in internal control and noncompliance Federal program: Research and Development Cluster ? various Assistance Listing numbers Federal agency: Various Pass through entity: Various Federal award year: July 1, 2021 to June 30, 2022 Compliance Requirement: Cash management Criteria The requirements for cash management are contained in Section 200.305 of Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), the A 102 Common Rule (?_.21), 0MB Circular A 110 (2 CFR section 215.22), Treasury regulations at 31 CFR part 205, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. When entities are funded on a reimbursement basis, program costs must be paid for by entity funds before reimbursement is requested from the Federal Government. Additionally, Section 200.303 of the Uniform Guidance indicates that the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Uniform Guidance also indicates that these internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? (Green Book) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Office of Management and Budget (OMB) has clarified that the references to the Green Book and COSO were only provided as best practices and not requirements. Condition During our test work over the Research and Development Cluster, we selected a sample of expenditures and cash draws/issued invoices to sponsors to verify the expenditures were paid prior to the date of the reimbursement request. We also verified the cash draw was supported by a detail of expenditures that reconciled. For the Research and Development Cluster, we noted 7 expenditures that totaled $4,061 of our sample of 40 expenditures that totaled $95,703 were not paid prior to the reimbursement request. Additionally, we noted 7 draws of our sample of 25 where the draw was over drawn. The total overdraw was $20,298 of the total cash draws tested of $601,919. Additionally, we noted 3 draws were not supported by a detail of expenditures that reconciled. The variance difference was $466. Cause UAMS did not maintain adequate support for cash draws causing unreconciled variances in the draw request detail. Additionally, cash draws were not appropriately reviewed to ensure that the expenditures were paid prior to the reimbursement requests. Effect Failure to properly complete cash draws may prevent UAMS from being in compliance with the requirements set forth by the Uniform Guidance. Questioned costs $463 related to interest on the over draw $466 related to unreconciled variances between the cash draw and the expenditure detail $929 total questioned costs Questioned costs related to the instances where the expenditure was not paid prior to the reimbursement request are not determinable. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding was reported in prior year audit. Recommendation We recommend that management design and implement internal controls that will ensure that program costs are paid before a request for reimbursement is made. Additionally, we recommend that management keep records of what expenditures make up each draw. View of responsible officials We concur with the finding. The instances where expenditures were not paid prior to the reimbursement request was noted in the prior year audit and was corrected as soon as the finding was communicated to management. The exceptions identified in the current year audit were prior to the control process changes made by management to ensure all expenses are paid before reimbursement is requested. There were no exceptions noted after the date of the change from the prior year audit. During the fiscal year, the grants accounting office experienced a significant turnover in staff and leadership in addition to implementing a new financial system. With the new director and staff in place and completing the implementation of the financial system, we believe adequate controls have been established and are working properly to ensure compliance with cash management regulations.
Finding number: 2022 001 Type of finding: Material weakness in internal control and noncompliance Federal program: Research and Development Cluster ? various Assistance Listing numbers Federal agency: Various Pass through entity: Various Federal award year: July 1, 2021 to June 30, 2022 Compliance Requirement: Cash management Criteria The requirements for cash management are contained in Section 200.305 of Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), the A 102 Common Rule (?_.21), 0MB Circular A 110 (2 CFR section 215.22), Treasury regulations at 31 CFR part 205, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. When entities are funded on a reimbursement basis, program costs must be paid for by entity funds before reimbursement is requested from the Federal Government. Additionally, Section 200.303 of the Uniform Guidance indicates that the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Uniform Guidance also indicates that these internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? (Green Book) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Office of Management and Budget (OMB) has clarified that the references to the Green Book and COSO were only provided as best practices and not requirements. Condition During our test work over the Research and Development Cluster, we selected a sample of expenditures and cash draws/issued invoices to sponsors to verify the expenditures were paid prior to the date of the reimbursement request. We also verified the cash draw was supported by a detail of expenditures that reconciled. For the Research and Development Cluster, we noted 7 expenditures that totaled $4,061 of our sample of 40 expenditures that totaled $95,703 were not paid prior to the reimbursement request. Additionally, we noted 7 draws of our sample of 25 where the draw was over drawn. The total overdraw was $20,298 of the total cash draws tested of $601,919. Additionally, we noted 3 draws were not supported by a detail of expenditures that reconciled. The variance difference was $466. Cause UAMS did not maintain adequate support for cash draws causing unreconciled variances in the draw request detail. Additionally, cash draws were not appropriately reviewed to ensure that the expenditures were paid prior to the reimbursement requests. Effect Failure to properly complete cash draws may prevent UAMS from being in compliance with the requirements set forth by the Uniform Guidance. Questioned costs $463 related to interest on the over draw $466 related to unreconciled variances between the cash draw and the expenditure detail $929 total questioned costs Questioned costs related to the instances where the expenditure was not paid prior to the reimbursement request are not determinable. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding was reported in prior year audit. Recommendation We recommend that management design and implement internal controls that will ensure that program costs are paid before a request for reimbursement is made. Additionally, we recommend that management keep records of what expenditures make up each draw. View of responsible officials We concur with the finding. The instances where expenditures were not paid prior to the reimbursement request was noted in the prior year audit and was corrected as soon as the finding was communicated to management. The exceptions identified in the current year audit were prior to the control process changes made by management to ensure all expenses are paid before reimbursement is requested. There were no exceptions noted after the date of the change from the prior year audit. During the fiscal year, the grants accounting office experienced a significant turnover in staff and leadership in addition to implementing a new financial system. With the new director and staff in place and completing the implementation of the financial system, we believe adequate controls have been established and are working properly to ensure compliance with cash management regulations.
Finding number: 2022 001 Type of finding: Material weakness in internal control and noncompliance Federal program: Research and Development Cluster ? various Assistance Listing numbers Federal agency: Various Pass through entity: Various Federal award year: July 1, 2021 to June 30, 2022 Compliance Requirement: Cash management Criteria The requirements for cash management are contained in Section 200.305 of Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), the A 102 Common Rule (?_.21), 0MB Circular A 110 (2 CFR section 215.22), Treasury regulations at 31 CFR part 205, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. When entities are funded on a reimbursement basis, program costs must be paid for by entity funds before reimbursement is requested from the Federal Government. Additionally, Section 200.303 of the Uniform Guidance indicates that the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Uniform Guidance also indicates that these internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? (Green Book) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Office of Management and Budget (OMB) has clarified that the references to the Green Book and COSO were only provided as best practices and not requirements. Condition During our test work over the Research and Development Cluster, we selected a sample of expenditures and cash draws/issued invoices to sponsors to verify the expenditures were paid prior to the date of the reimbursement request. We also verified the cash draw was supported by a detail of expenditures that reconciled. For the Research and Development Cluster, we noted 7 expenditures that totaled $4,061 of our sample of 40 expenditures that totaled $95,703 were not paid prior to the reimbursement request. Additionally, we noted 7 draws of our sample of 25 where the draw was over drawn. The total overdraw was $20,298 of the total cash draws tested of $601,919. Additionally, we noted 3 draws were not supported by a detail of expenditures that reconciled. The variance difference was $466. Cause UAMS did not maintain adequate support for cash draws causing unreconciled variances in the draw request detail. Additionally, cash draws were not appropriately reviewed to ensure that the expenditures were paid prior to the reimbursement requests. Effect Failure to properly complete cash draws may prevent UAMS from being in compliance with the requirements set forth by the Uniform Guidance. Questioned costs $463 related to interest on the over draw $466 related to unreconciled variances between the cash draw and the expenditure detail $929 total questioned costs Questioned costs related to the instances where the expenditure was not paid prior to the reimbursement request are not determinable. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding was reported in prior year audit. Recommendation We recommend that management design and implement internal controls that will ensure that program costs are paid before a request for reimbursement is made. Additionally, we recommend that management keep records of what expenditures make up each draw. View of responsible officials We concur with the finding. The instances where expenditures were not paid prior to the reimbursement request was noted in the prior year audit and was corrected as soon as the finding was communicated to management. The exceptions identified in the current year audit were prior to the control process changes made by management to ensure all expenses are paid before reimbursement is requested. There were no exceptions noted after the date of the change from the prior year audit. During the fiscal year, the grants accounting office experienced a significant turnover in staff and leadership in addition to implementing a new financial system. With the new director and staff in place and completing the implementation of the financial system, we believe adequate controls have been established and are working properly to ensure compliance with cash management regulations.
Finding number: 2022 001 Type of finding: Material weakness in internal control and noncompliance Federal program: Research and Development Cluster ? various Assistance Listing numbers Federal agency: Various Pass through entity: Various Federal award year: July 1, 2021 to June 30, 2022 Compliance Requirement: Cash management Criteria The requirements for cash management are contained in Section 200.305 of Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), the A 102 Common Rule (?_.21), 0MB Circular A 110 (2 CFR section 215.22), Treasury regulations at 31 CFR part 205, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. When entities are funded on a reimbursement basis, program costs must be paid for by entity funds before reimbursement is requested from the Federal Government. Additionally, Section 200.303 of the Uniform Guidance indicates that the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Uniform Guidance also indicates that these internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? (Green Book) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Office of Management and Budget (OMB) has clarified that the references to the Green Book and COSO were only provided as best practices and not requirements. Condition During our test work over the Research and Development Cluster, we selected a sample of expenditures and cash draws/issued invoices to sponsors to verify the expenditures were paid prior to the date of the reimbursement request. We also verified the cash draw was supported by a detail of expenditures that reconciled. For the Research and Development Cluster, we noted 7 expenditures that totaled $4,061 of our sample of 40 expenditures that totaled $95,703 were not paid prior to the reimbursement request. Additionally, we noted 7 draws of our sample of 25 where the draw was over drawn. The total overdraw was $20,298 of the total cash draws tested of $601,919. Additionally, we noted 3 draws were not supported by a detail of expenditures that reconciled. The variance difference was $466. Cause UAMS did not maintain adequate support for cash draws causing unreconciled variances in the draw request detail. Additionally, cash draws were not appropriately reviewed to ensure that the expenditures were paid prior to the reimbursement requests. Effect Failure to properly complete cash draws may prevent UAMS from being in compliance with the requirements set forth by the Uniform Guidance. Questioned costs $463 related to interest on the over draw $466 related to unreconciled variances between the cash draw and the expenditure detail $929 total questioned costs Questioned costs related to the instances where the expenditure was not paid prior to the reimbursement request are not determinable. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding was reported in prior year audit. Recommendation We recommend that management design and implement internal controls that will ensure that program costs are paid before a request for reimbursement is made. Additionally, we recommend that management keep records of what expenditures make up each draw. View of responsible officials We concur with the finding. The instances where expenditures were not paid prior to the reimbursement request was noted in the prior year audit and was corrected as soon as the finding was communicated to management. The exceptions identified in the current year audit were prior to the control process changes made by management to ensure all expenses are paid before reimbursement is requested. There were no exceptions noted after the date of the change from the prior year audit. During the fiscal year, the grants accounting office experienced a significant turnover in staff and leadership in addition to implementing a new financial system. With the new director and staff in place and completing the implementation of the financial system, we believe adequate controls have been established and are working properly to ensure compliance with cash management regulations.
Finding number: 2022 001 Type of finding: Material weakness in internal control and noncompliance Federal program: Research and Development Cluster ? various Assistance Listing numbers Federal agency: Various Pass through entity: Various Federal award year: July 1, 2021 to June 30, 2022 Compliance Requirement: Cash management Criteria The requirements for cash management are contained in Section 200.305 of Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), the A 102 Common Rule (?_.21), 0MB Circular A 110 (2 CFR section 215.22), Treasury regulations at 31 CFR part 205, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. When entities are funded on a reimbursement basis, program costs must be paid for by entity funds before reimbursement is requested from the Federal Government. Additionally, Section 200.303 of the Uniform Guidance indicates that the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Uniform Guidance also indicates that these internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? (Green Book) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Office of Management and Budget (OMB) has clarified that the references to the Green Book and COSO were only provided as best practices and not requirements. Condition During our test work over the Research and Development Cluster, we selected a sample of expenditures and cash draws/issued invoices to sponsors to verify the expenditures were paid prior to the date of the reimbursement request. We also verified the cash draw was supported by a detail of expenditures that reconciled. For the Research and Development Cluster, we noted 7 expenditures that totaled $4,061 of our sample of 40 expenditures that totaled $95,703 were not paid prior to the reimbursement request. Additionally, we noted 7 draws of our sample of 25 where the draw was over drawn. The total overdraw was $20,298 of the total cash draws tested of $601,919. Additionally, we noted 3 draws were not supported by a detail of expenditures that reconciled. The variance difference was $466. Cause UAMS did not maintain adequate support for cash draws causing unreconciled variances in the draw request detail. Additionally, cash draws were not appropriately reviewed to ensure that the expenditures were paid prior to the reimbursement requests. Effect Failure to properly complete cash draws may prevent UAMS from being in compliance with the requirements set forth by the Uniform Guidance. Questioned costs $463 related to interest on the over draw $466 related to unreconciled variances between the cash draw and the expenditure detail $929 total questioned costs Questioned costs related to the instances where the expenditure was not paid prior to the reimbursement request are not determinable. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding was reported in prior year audit. Recommendation We recommend that management design and implement internal controls that will ensure that program costs are paid before a request for reimbursement is made. Additionally, we recommend that management keep records of what expenditures make up each draw. View of responsible officials We concur with the finding. The instances where expenditures were not paid prior to the reimbursement request was noted in the prior year audit and was corrected as soon as the finding was communicated to management. The exceptions identified in the current year audit were prior to the control process changes made by management to ensure all expenses are paid before reimbursement is requested. There were no exceptions noted after the date of the change from the prior year audit. During the fiscal year, the grants accounting office experienced a significant turnover in staff and leadership in addition to implementing a new financial system. With the new director and staff in place and completing the implementation of the financial system, we believe adequate controls have been established and are working properly to ensure compliance with cash management regulations.
Finding number: 2022 001 Type of finding: Material weakness in internal control and noncompliance Federal program: Research and Development Cluster ? various Assistance Listing numbers Federal agency: Various Pass through entity: Various Federal award year: July 1, 2021 to June 30, 2022 Compliance Requirement: Cash management Criteria The requirements for cash management are contained in Section 200.305 of Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), the A 102 Common Rule (?_.21), 0MB Circular A 110 (2 CFR section 215.22), Treasury regulations at 31 CFR part 205, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. When entities are funded on a reimbursement basis, program costs must be paid for by entity funds before reimbursement is requested from the Federal Government. Additionally, Section 200.303 of the Uniform Guidance indicates that the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Uniform Guidance also indicates that these internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? (Green Book) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Office of Management and Budget (OMB) has clarified that the references to the Green Book and COSO were only provided as best practices and not requirements. Condition During our test work over the Research and Development Cluster, we selected a sample of expenditures and cash draws/issued invoices to sponsors to verify the expenditures were paid prior to the date of the reimbursement request. We also verified the cash draw was supported by a detail of expenditures that reconciled. For the Research and Development Cluster, we noted 7 expenditures that totaled $4,061 of our sample of 40 expenditures that totaled $95,703 were not paid prior to the reimbursement request. Additionally, we noted 7 draws of our sample of 25 where the draw was over drawn. The total overdraw was $20,298 of the total cash draws tested of $601,919. Additionally, we noted 3 draws were not supported by a detail of expenditures that reconciled. The variance difference was $466. Cause UAMS did not maintain adequate support for cash draws causing unreconciled variances in the draw request detail. Additionally, cash draws were not appropriately reviewed to ensure that the expenditures were paid prior to the reimbursement requests. Effect Failure to properly complete cash draws may prevent UAMS from being in compliance with the requirements set forth by the Uniform Guidance. Questioned costs $463 related to interest on the over draw $466 related to unreconciled variances between the cash draw and the expenditure detail $929 total questioned costs Questioned costs related to the instances where the expenditure was not paid prior to the reimbursement request are not determinable. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding was reported in prior year audit. Recommendation We recommend that management design and implement internal controls that will ensure that program costs are paid before a request for reimbursement is made. Additionally, we recommend that management keep records of what expenditures make up each draw. View of responsible officials We concur with the finding. The instances where expenditures were not paid prior to the reimbursement request was noted in the prior year audit and was corrected as soon as the finding was communicated to management. The exceptions identified in the current year audit were prior to the control process changes made by management to ensure all expenses are paid before reimbursement is requested. There were no exceptions noted after the date of the change from the prior year audit. During the fiscal year, the grants accounting office experienced a significant turnover in staff and leadership in addition to implementing a new financial system. With the new director and staff in place and completing the implementation of the financial system, we believe adequate controls have been established and are working properly to ensure compliance with cash management regulations.
Finding number: 2022 001 Type of finding: Material weakness in internal control and noncompliance Federal program: Research and Development Cluster ? various Assistance Listing numbers Federal agency: Various Pass through entity: Various Federal award year: July 1, 2021 to June 30, 2022 Compliance Requirement: Cash management Criteria The requirements for cash management are contained in Section 200.305 of Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), the A 102 Common Rule (?_.21), 0MB Circular A 110 (2 CFR section 215.22), Treasury regulations at 31 CFR part 205, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. When entities are funded on a reimbursement basis, program costs must be paid for by entity funds before reimbursement is requested from the Federal Government. Additionally, Section 200.303 of the Uniform Guidance indicates that the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Uniform Guidance also indicates that these internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? (Green Book) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Office of Management and Budget (OMB) has clarified that the references to the Green Book and COSO were only provided as best practices and not requirements. Condition During our test work over the Research and Development Cluster, we selected a sample of expenditures and cash draws/issued invoices to sponsors to verify the expenditures were paid prior to the date of the reimbursement request. We also verified the cash draw was supported by a detail of expenditures that reconciled. For the Research and Development Cluster, we noted 7 expenditures that totaled $4,061 of our sample of 40 expenditures that totaled $95,703 were not paid prior to the reimbursement request. Additionally, we noted 7 draws of our sample of 25 where the draw was over drawn. The total overdraw was $20,298 of the total cash draws tested of $601,919. Additionally, we noted 3 draws were not supported by a detail of expenditures that reconciled. The variance difference was $466. Cause UAMS did not maintain adequate support for cash draws causing unreconciled variances in the draw request detail. Additionally, cash draws were not appropriately reviewed to ensure that the expenditures were paid prior to the reimbursement requests. Effect Failure to properly complete cash draws may prevent UAMS from being in compliance with the requirements set forth by the Uniform Guidance. Questioned costs $463 related to interest on the over draw $466 related to unreconciled variances between the cash draw and the expenditure detail $929 total questioned costs Questioned costs related to the instances where the expenditure was not paid prior to the reimbursement request are not determinable. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding was reported in prior year audit. Recommendation We recommend that management design and implement internal controls that will ensure that program costs are paid before a request for reimbursement is made. Additionally, we recommend that management keep records of what expenditures make up each draw. View of responsible officials We concur with the finding. The instances where expenditures were not paid prior to the reimbursement request was noted in the prior year audit and was corrected as soon as the finding was communicated to management. The exceptions identified in the current year audit were prior to the control process changes made by management to ensure all expenses are paid before reimbursement is requested. There were no exceptions noted after the date of the change from the prior year audit. During the fiscal year, the grants accounting office experienced a significant turnover in staff and leadership in addition to implementing a new financial system. With the new director and staff in place and completing the implementation of the financial system, we believe adequate controls have been established and are working properly to ensure compliance with cash management regulations.
Finding number: 2022 001 Type of finding: Material weakness in internal control and noncompliance Federal program: Research and Development Cluster ? various Assistance Listing numbers Federal agency: Various Pass through entity: Various Federal award year: July 1, 2021 to June 30, 2022 Compliance Requirement: Cash management Criteria The requirements for cash management are contained in Section 200.305 of Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), the A 102 Common Rule (?_.21), 0MB Circular A 110 (2 CFR section 215.22), Treasury regulations at 31 CFR part 205, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. When entities are funded on a reimbursement basis, program costs must be paid for by entity funds before reimbursement is requested from the Federal Government. Additionally, Section 200.303 of the Uniform Guidance indicates that the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Uniform Guidance also indicates that these internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? (Green Book) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Office of Management and Budget (OMB) has clarified that the references to the Green Book and COSO were only provided as best practices and not requirements. Condition During our test work over the Research and Development Cluster, we selected a sample of expenditures and cash draws/issued invoices to sponsors to verify the expenditures were paid prior to the date of the reimbursement request. We also verified the cash draw was supported by a detail of expenditures that reconciled. For the Research and Development Cluster, we noted 7 expenditures that totaled $4,061 of our sample of 40 expenditures that totaled $95,703 were not paid prior to the reimbursement request. Additionally, we noted 7 draws of our sample of 25 where the draw was over drawn. The total overdraw was $20,298 of the total cash draws tested of $601,919. Additionally, we noted 3 draws were not supported by a detail of expenditures that reconciled. The variance difference was $466. Cause UAMS did not maintain adequate support for cash draws causing unreconciled variances in the draw request detail. Additionally, cash draws were not appropriately reviewed to ensure that the expenditures were paid prior to the reimbursement requests. Effect Failure to properly complete cash draws may prevent UAMS from being in compliance with the requirements set forth by the Uniform Guidance. Questioned costs $463 related to interest on the over draw $466 related to unreconciled variances between the cash draw and the expenditure detail $929 total questioned costs Questioned costs related to the instances where the expenditure was not paid prior to the reimbursement request are not determinable. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding was reported in prior year audit. Recommendation We recommend that management design and implement internal controls that will ensure that program costs are paid before a request for reimbursement is made. Additionally, we recommend that management keep records of what expenditures make up each draw. View of responsible officials We concur with the finding. The instances where expenditures were not paid prior to the reimbursement request was noted in the prior year audit and was corrected as soon as the finding was communicated to management. The exceptions identified in the current year audit were prior to the control process changes made by management to ensure all expenses are paid before reimbursement is requested. There were no exceptions noted after the date of the change from the prior year audit. During the fiscal year, the grants accounting office experienced a significant turnover in staff and leadership in addition to implementing a new financial system. With the new director and staff in place and completing the implementation of the financial system, we believe adequate controls have been established and are working properly to ensure compliance with cash management regulations.
Finding number: 2022 001 Type of finding: Material weakness in internal control and noncompliance Federal program: Research and Development Cluster ? various Assistance Listing numbers Federal agency: Various Pass through entity: Various Federal award year: July 1, 2021 to June 30, 2022 Compliance Requirement: Cash management Criteria The requirements for cash management are contained in Section 200.305 of Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), the A 102 Common Rule (?_.21), 0MB Circular A 110 (2 CFR section 215.22), Treasury regulations at 31 CFR part 205, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. When entities are funded on a reimbursement basis, program costs must be paid for by entity funds before reimbursement is requested from the Federal Government. Additionally, Section 200.303 of the Uniform Guidance indicates that the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Uniform Guidance also indicates that these internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? (Green Book) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Office of Management and Budget (OMB) has clarified that the references to the Green Book and COSO were only provided as best practices and not requirements. Condition During our test work over the Research and Development Cluster, we selected a sample of expenditures and cash draws/issued invoices to sponsors to verify the expenditures were paid prior to the date of the reimbursement request. We also verified the cash draw was supported by a detail of expenditures that reconciled. For the Research and Development Cluster, we noted 7 expenditures that totaled $4,061 of our sample of 40 expenditures that totaled $95,703 were not paid prior to the reimbursement request. Additionally, we noted 7 draws of our sample of 25 where the draw was over drawn. The total overdraw was $20,298 of the total cash draws tested of $601,919. Additionally, we noted 3 draws were not supported by a detail of expenditures that reconciled. The variance difference was $466. Cause UAMS did not maintain adequate support for cash draws causing unreconciled variances in the draw request detail. Additionally, cash draws were not appropriately reviewed to ensure that the expenditures were paid prior to the reimbursement requests. Effect Failure to properly complete cash draws may prevent UAMS from being in compliance with the requirements set forth by the Uniform Guidance. Questioned costs $463 related to interest on the over draw $466 related to unreconciled variances between the cash draw and the expenditure detail $929 total questioned costs Questioned costs related to the instances where the expenditure was not paid prior to the reimbursement request are not determinable. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding was reported in prior year audit. Recommendation We recommend that management design and implement internal controls that will ensure that program costs are paid before a request for reimbursement is made. Additionally, we recommend that management keep records of what expenditures make up each draw. View of responsible officials We concur with the finding. The instances where expenditures were not paid prior to the reimbursement request was noted in the prior year audit and was corrected as soon as the finding was communicated to management. The exceptions identified in the current year audit were prior to the control process changes made by management to ensure all expenses are paid before reimbursement is requested. There were no exceptions noted after the date of the change from the prior year audit. During the fiscal year, the grants accounting office experienced a significant turnover in staff and leadership in addition to implementing a new financial system. With the new director and staff in place and completing the implementation of the financial system, we believe adequate controls have been established and are working properly to ensure compliance with cash management regulations.
Finding number: 2022 001 Type of finding: Material weakness in internal control and noncompliance Federal program: Research and Development Cluster ? various Assistance Listing numbers Federal agency: Various Pass through entity: Various Federal award year: July 1, 2021 to June 30, 2022 Compliance Requirement: Cash management Criteria The requirements for cash management are contained in Section 200.305 of Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), the A 102 Common Rule (?_.21), 0MB Circular A 110 (2 CFR section 215.22), Treasury regulations at 31 CFR part 205, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. When entities are funded on a reimbursement basis, program costs must be paid for by entity funds before reimbursement is requested from the Federal Government. Additionally, Section 200.303 of the Uniform Guidance indicates that the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Uniform Guidance also indicates that these internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? (Green Book) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Office of Management and Budget (OMB) has clarified that the references to the Green Book and COSO were only provided as best practices and not requirements. Condition During our test work over the Research and Development Cluster, we selected a sample of expenditures and cash draws/issued invoices to sponsors to verify the expenditures were paid prior to the date of the reimbursement request. We also verified the cash draw was supported by a detail of expenditures that reconciled. For the Research and Development Cluster, we noted 7 expenditures that totaled $4,061 of our sample of 40 expenditures that totaled $95,703 were not paid prior to the reimbursement request. Additionally, we noted 7 draws of our sample of 25 where the draw was over drawn. The total overdraw was $20,298 of the total cash draws tested of $601,919. Additionally, we noted 3 draws were not supported by a detail of expenditures that reconciled. The variance difference was $466. Cause UAMS did not maintain adequate support for cash draws causing unreconciled variances in the draw request detail. Additionally, cash draws were not appropriately reviewed to ensure that the expenditures were paid prior to the reimbursement requests. Effect Failure to properly complete cash draws may prevent UAMS from being in compliance with the requirements set forth by the Uniform Guidance. Questioned costs $463 related to interest on the over draw $466 related to unreconciled variances between the cash draw and the expenditure detail $929 total questioned costs Questioned costs related to the instances where the expenditure was not paid prior to the reimbursement request are not determinable. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding was reported in prior year audit. Recommendation We recommend that management design and implement internal controls that will ensure that program costs are paid before a request for reimbursement is made. Additionally, we recommend that management keep records of what expenditures make up each draw. View of responsible officials We concur with the finding. The instances where expenditures were not paid prior to the reimbursement request was noted in the prior year audit and was corrected as soon as the finding was communicated to management. The exceptions identified in the current year audit were prior to the control process changes made by management to ensure all expenses are paid before reimbursement is requested. There were no exceptions noted after the date of the change from the prior year audit. During the fiscal year, the grants accounting office experienced a significant turnover in staff and leadership in addition to implementing a new financial system. With the new director and staff in place and completing the implementation of the financial system, we believe adequate controls have been established and are working properly to ensure compliance with cash management regulations.
Finding number: 2022 001 Type of finding: Material weakness in internal control and noncompliance Federal program: Research and Development Cluster ? various Assistance Listing numbers Federal agency: Various Pass through entity: Various Federal award year: July 1, 2021 to June 30, 2022 Compliance Requirement: Cash management Criteria The requirements for cash management are contained in Section 200.305 of Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), the A 102 Common Rule (?_.21), 0MB Circular A 110 (2 CFR section 215.22), Treasury regulations at 31 CFR part 205, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. When entities are funded on a reimbursement basis, program costs must be paid for by entity funds before reimbursement is requested from the Federal Government. Additionally, Section 200.303 of the Uniform Guidance indicates that the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Uniform Guidance also indicates that these internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? (Green Book) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Office of Management and Budget (OMB) has clarified that the references to the Green Book and COSO were only provided as best practices and not requirements. Condition During our test work over the Research and Development Cluster, we selected a sample of expenditures and cash draws/issued invoices to sponsors to verify the expenditures were paid prior to the date of the reimbursement request. We also verified the cash draw was supported by a detail of expenditures that reconciled. For the Research and Development Cluster, we noted 7 expenditures that totaled $4,061 of our sample of 40 expenditures that totaled $95,703 were not paid prior to the reimbursement request. Additionally, we noted 7 draws of our sample of 25 where the draw was over drawn. The total overdraw was $20,298 of the total cash draws tested of $601,919. Additionally, we noted 3 draws were not supported by a detail of expenditures that reconciled. The variance difference was $466. Cause UAMS did not maintain adequate support for cash draws causing unreconciled variances in the draw request detail. Additionally, cash draws were not appropriately reviewed to ensure that the expenditures were paid prior to the reimbursement requests. Effect Failure to properly complete cash draws may prevent UAMS from being in compliance with the requirements set forth by the Uniform Guidance. Questioned costs $463 related to interest on the over draw $466 related to unreconciled variances between the cash draw and the expenditure detail $929 total questioned costs Questioned costs related to the instances where the expenditure was not paid prior to the reimbursement request are not determinable. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding was reported in prior year audit. Recommendation We recommend that management design and implement internal controls that will ensure that program costs are paid before a request for reimbursement is made. Additionally, we recommend that management keep records of what expenditures make up each draw. View of responsible officials We concur with the finding. The instances where expenditures were not paid prior to the reimbursement request was noted in the prior year audit and was corrected as soon as the finding was communicated to management. The exceptions identified in the current year audit were prior to the control process changes made by management to ensure all expenses are paid before reimbursement is requested. There were no exceptions noted after the date of the change from the prior year audit. During the fiscal year, the grants accounting office experienced a significant turnover in staff and leadership in addition to implementing a new financial system. With the new director and staff in place and completing the implementation of the financial system, we believe adequate controls have been established and are working properly to ensure compliance with cash management regulations.
Finding number: 2022 001 Type of finding: Material weakness in internal control and noncompliance Federal program: Research and Development Cluster ? various Assistance Listing numbers Federal agency: Various Pass through entity: Various Federal award year: July 1, 2021 to June 30, 2022 Compliance Requirement: Cash management Criteria The requirements for cash management are contained in Section 200.305 of Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), the A 102 Common Rule (?_.21), 0MB Circular A 110 (2 CFR section 215.22), Treasury regulations at 31 CFR part 205, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. When entities are funded on a reimbursement basis, program costs must be paid for by entity funds before reimbursement is requested from the Federal Government. Additionally, Section 200.303 of the Uniform Guidance indicates that the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Uniform Guidance also indicates that these internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? (Green Book) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Office of Management and Budget (OMB) has clarified that the references to the Green Book and COSO were only provided as best practices and not requirements. Condition During our test work over the Research and Development Cluster, we selected a sample of expenditures and cash draws/issued invoices to sponsors to verify the expenditures were paid prior to the date of the reimbursement request. We also verified the cash draw was supported by a detail of expenditures that reconciled. For the Research and Development Cluster, we noted 7 expenditures that totaled $4,061 of our sample of 40 expenditures that totaled $95,703 were not paid prior to the reimbursement request. Additionally, we noted 7 draws of our sample of 25 where the draw was over drawn. The total overdraw was $20,298 of the total cash draws tested of $601,919. Additionally, we noted 3 draws were not supported by a detail of expenditures that reconciled. The variance difference was $466. Cause UAMS did not maintain adequate support for cash draws causing unreconciled variances in the draw request detail. Additionally, cash draws were not appropriately reviewed to ensure that the expenditures were paid prior to the reimbursement requests. Effect Failure to properly complete cash draws may prevent UAMS from being in compliance with the requirements set forth by the Uniform Guidance. Questioned costs $463 related to interest on the over draw $466 related to unreconciled variances between the cash draw and the expenditure detail $929 total questioned costs Questioned costs related to the instances where the expenditure was not paid prior to the reimbursement request are not determinable. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding was reported in prior year audit. Recommendation We recommend that management design and implement internal controls that will ensure that program costs are paid before a request for reimbursement is made. Additionally, we recommend that management keep records of what expenditures make up each draw. View of responsible officials We concur with the finding. The instances where expenditures were not paid prior to the reimbursement request was noted in the prior year audit and was corrected as soon as the finding was communicated to management. The exceptions identified in the current year audit were prior to the control process changes made by management to ensure all expenses are paid before reimbursement is requested. There were no exceptions noted after the date of the change from the prior year audit. During the fiscal year, the grants accounting office experienced a significant turnover in staff and leadership in addition to implementing a new financial system. With the new director and staff in place and completing the implementation of the financial system, we believe adequate controls have been established and are working properly to ensure compliance with cash management regulations.
Finding number: 2022 001 Type of finding: Material weakness in internal control and noncompliance Federal program: Research and Development Cluster ? various Assistance Listing numbers Federal agency: Various Pass through entity: Various Federal award year: July 1, 2021 to June 30, 2022 Compliance Requirement: Cash management Criteria The requirements for cash management are contained in Section 200.305 of Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), the A 102 Common Rule (?_.21), 0MB Circular A 110 (2 CFR section 215.22), Treasury regulations at 31 CFR part 205, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. When entities are funded on a reimbursement basis, program costs must be paid for by entity funds before reimbursement is requested from the Federal Government. Additionally, Section 200.303 of the Uniform Guidance indicates that the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Uniform Guidance also indicates that these internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? (Green Book) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Office of Management and Budget (OMB) has clarified that the references to the Green Book and COSO were only provided as best practices and not requirements. Condition During our test work over the Research and Development Cluster, we selected a sample of expenditures and cash draws/issued invoices to sponsors to verify the expenditures were paid prior to the date of the reimbursement request. We also verified the cash draw was supported by a detail of expenditures that reconciled. For the Research and Development Cluster, we noted 7 expenditures that totaled $4,061 of our sample of 40 expenditures that totaled $95,703 were not paid prior to the reimbursement request. Additionally, we noted 7 draws of our sample of 25 where the draw was over drawn. The total overdraw was $20,298 of the total cash draws tested of $601,919. Additionally, we noted 3 draws were not supported by a detail of expenditures that reconciled. The variance difference was $466. Cause UAMS did not maintain adequate support for cash draws causing unreconciled variances in the draw request detail. Additionally, cash draws were not appropriately reviewed to ensure that the expenditures were paid prior to the reimbursement requests. Effect Failure to properly complete cash draws may prevent UAMS from being in compliance with the requirements set forth by the Uniform Guidance. Questioned costs $463 related to interest on the over draw $466 related to unreconciled variances between the cash draw and the expenditure detail $929 total questioned costs Questioned costs related to the instances where the expenditure was not paid prior to the reimbursement request are not determinable. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding was reported in prior year audit. Recommendation We recommend that management design and implement internal controls that will ensure that program costs are paid before a request for reimbursement is made. Additionally, we recommend that management keep records of what expenditures make up each draw. View of responsible officials We concur with the finding. The instances where expenditures were not paid prior to the reimbursement request was noted in the prior year audit and was corrected as soon as the finding was communicated to management. The exceptions identified in the current year audit were prior to the control process changes made by management to ensure all expenses are paid before reimbursement is requested. There were no exceptions noted after the date of the change from the prior year audit. During the fiscal year, the grants accounting office experienced a significant turnover in staff and leadership in addition to implementing a new financial system. With the new director and staff in place and completing the implementation of the financial system, we believe adequate controls have been established and are working properly to ensure compliance with cash management regulations.
Finding number: 2022 001 Type of finding: Material weakness in internal control and noncompliance Federal program: Research and Development Cluster ? various Assistance Listing numbers Federal agency: Various Pass through entity: Various Federal award year: July 1, 2021 to June 30, 2022 Compliance Requirement: Cash management Criteria The requirements for cash management are contained in Section 200.305 of Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), the A 102 Common Rule (?_.21), 0MB Circular A 110 (2 CFR section 215.22), Treasury regulations at 31 CFR part 205, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. When entities are funded on a reimbursement basis, program costs must be paid for by entity funds before reimbursement is requested from the Federal Government. Additionally, Section 200.303 of the Uniform Guidance indicates that the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Uniform Guidance also indicates that these internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? (Green Book) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Office of Management and Budget (OMB) has clarified that the references to the Green Book and COSO were only provided as best practices and not requirements. Condition During our test work over the Research and Development Cluster, we selected a sample of expenditures and cash draws/issued invoices to sponsors to verify the expenditures were paid prior to the date of the reimbursement request. We also verified the cash draw was supported by a detail of expenditures that reconciled. For the Research and Development Cluster, we noted 7 expenditures that totaled $4,061 of our sample of 40 expenditures that totaled $95,703 were not paid prior to the reimbursement request. Additionally, we noted 7 draws of our sample of 25 where the draw was over drawn. The total overdraw was $20,298 of the total cash draws tested of $601,919. Additionally, we noted 3 draws were not supported by a detail of expenditures that reconciled. The variance difference was $466. Cause UAMS did not maintain adequate support for cash draws causing unreconciled variances in the draw request detail. Additionally, cash draws were not appropriately reviewed to ensure that the expenditures were paid prior to the reimbursement requests. Effect Failure to properly complete cash draws may prevent UAMS from being in compliance with the requirements set forth by the Uniform Guidance. Questioned costs $463 related to interest on the over draw $466 related to unreconciled variances between the cash draw and the expenditure detail $929 total questioned costs Questioned costs related to the instances where the expenditure was not paid prior to the reimbursement request are not determinable. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding was reported in prior year audit. Recommendation We recommend that management design and implement internal controls that will ensure that program costs are paid before a request for reimbursement is made. Additionally, we recommend that management keep records of what expenditures make up each draw. View of responsible officials We concur with the finding. The instances where expenditures were not paid prior to the reimbursement request was noted in the prior year audit and was corrected as soon as the finding was communicated to management. The exceptions identified in the current year audit were prior to the control process changes made by management to ensure all expenses are paid before reimbursement is requested. There were no exceptions noted after the date of the change from the prior year audit. During the fiscal year, the grants accounting office experienced a significant turnover in staff and leadership in addition to implementing a new financial system. With the new director and staff in place and completing the implementation of the financial system, we believe adequate controls have been established and are working properly to ensure compliance with cash management regulations.
Finding number: 2022 001 Type of finding: Material weakness in internal control and noncompliance Federal program: Research and Development Cluster ? various Assistance Listing numbers Federal agency: Various Pass through entity: Various Federal award year: July 1, 2021 to June 30, 2022 Compliance Requirement: Cash management Criteria The requirements for cash management are contained in Section 200.305 of Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), the A 102 Common Rule (?_.21), 0MB Circular A 110 (2 CFR section 215.22), Treasury regulations at 31 CFR part 205, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. When entities are funded on a reimbursement basis, program costs must be paid for by entity funds before reimbursement is requested from the Federal Government. Additionally, Section 200.303 of the Uniform Guidance indicates that the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Uniform Guidance also indicates that these internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? (Green Book) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Office of Management and Budget (OMB) has clarified that the references to the Green Book and COSO were only provided as best practices and not requirements. Condition During our test work over the Research and Development Cluster, we selected a sample of expenditures and cash draws/issued invoices to sponsors to verify the expenditures were paid prior to the date of the reimbursement request. We also verified the cash draw was supported by a detail of expenditures that reconciled. For the Research and Development Cluster, we noted 7 expenditures that totaled $4,061 of our sample of 40 expenditures that totaled $95,703 were not paid prior to the reimbursement request. Additionally, we noted 7 draws of our sample of 25 where the draw was over drawn. The total overdraw was $20,298 of the total cash draws tested of $601,919. Additionally, we noted 3 draws were not supported by a detail of expenditures that reconciled. The variance difference was $466. Cause UAMS did not maintain adequate support for cash draws causing unreconciled variances in the draw request detail. Additionally, cash draws were not appropriately reviewed to ensure that the expenditures were paid prior to the reimbursement requests. Effect Failure to properly complete cash draws may prevent UAMS from being in compliance with the requirements set forth by the Uniform Guidance. Questioned costs $463 related to interest on the over draw $466 related to unreconciled variances between the cash draw and the expenditure detail $929 total questioned costs Questioned costs related to the instances where the expenditure was not paid prior to the reimbursement request are not determinable. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding was reported in prior year audit. Recommendation We recommend that management design and implement internal controls that will ensure that program costs are paid before a request for reimbursement is made. Additionally, we recommend that management keep records of what expenditures make up each draw. View of responsible officials We concur with the finding. The instances where expenditures were not paid prior to the reimbursement request was noted in the prior year audit and was corrected as soon as the finding was communicated to management. The exceptions identified in the current year audit were prior to the control process changes made by management to ensure all expenses are paid before reimbursement is requested. There were no exceptions noted after the date of the change from the prior year audit. During the fiscal year, the grants accounting office experienced a significant turnover in staff and leadership in addition to implementing a new financial system. With the new director and staff in place and completing the implementation of the financial system, we believe adequate controls have been established and are working properly to ensure compliance with cash management regulations.
Finding number: 2022 001 Type of finding: Material weakness in internal control and noncompliance Federal program: Research and Development Cluster ? various Assistance Listing numbers Federal agency: Various Pass through entity: Various Federal award year: July 1, 2021 to June 30, 2022 Compliance Requirement: Cash management Criteria The requirements for cash management are contained in Section 200.305 of Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), the A 102 Common Rule (?_.21), 0MB Circular A 110 (2 CFR section 215.22), Treasury regulations at 31 CFR part 205, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. When entities are funded on a reimbursement basis, program costs must be paid for by entity funds before reimbursement is requested from the Federal Government. Additionally, Section 200.303 of the Uniform Guidance indicates that the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Uniform Guidance also indicates that these internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? (Green Book) issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Office of Management and Budget (OMB) has clarified that the references to the Green Book and COSO were only provided as best practices and not requirements. Condition During our test work over the Research and Development Cluster, we selected a sample of expenditures and cash draws/issued invoices to sponsors to verify the expenditures were paid prior to the date of the reimbursement request. We also verified the cash draw was supported by a detail of expenditures that reconciled. For the Research and Development Cluster, we noted 7 expenditures that totaled $4,061 of our sample of 40 expenditures that totaled $95,703 were not paid prior to the reimbursement request. Additionally, we noted 7 draws of our sample of 25 where the draw was over drawn. The total overdraw was $20,298 of the total cash draws tested of $601,919. Additionally, we noted 3 draws were not supported by a detail of expenditures that reconciled. The variance difference was $466. Cause UAMS did not maintain adequate support for cash draws causing unreconciled variances in the draw request detail. Additionally, cash draws were not appropriately reviewed to ensure that the expenditures were paid prior to the reimbursement requests. Effect Failure to properly complete cash draws may prevent UAMS from being in compliance with the requirements set forth by the Uniform Guidance. Questioned costs $463 related to interest on the over draw $466 related to unreconciled variances between the cash draw and the expenditure detail $929 total questioned costs Questioned costs related to the instances where the expenditure was not paid prior to the reimbursement request are not determinable. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding was reported in prior year audit. Recommendation We recommend that management design and implement internal controls that will ensure that program costs are paid before a request for reimbursement is made. Additionally, we recommend that management keep records of what expenditures make up each draw. View of responsible officials We concur with the finding. The instances where expenditures were not paid prior to the reimbursement request was noted in the prior year audit and was corrected as soon as the finding was communicated to management. The exceptions identified in the current year audit were prior to the control process changes made by management to ensure all expenses are paid before reimbursement is requested. There were no exceptions noted after the date of the change from the prior year audit. During the fiscal year, the grants accounting office experienced a significant turnover in staff and leadership in addition to implementing a new financial system. With the new director and staff in place and completing the implementation of the financial system, we believe adequate controls have been established and are working properly to ensure compliance with cash management regulations.