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.
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.
(2022-069) Title: Internal control over subrecipient cash management needs improvement Prior Year Findings: See Schedule of Findings and Questioned Costs for chart/table State Department: Health and Human Services State Bureau: Division of Contract Management Federal Agency: U.S. Department of Health and Human Services U.S. Department of Agriculture Assistance Listing Title: Temporary Assistance for Needy Families (TANF) (COVID-19) Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) (COVID-19) Immunization Cooperative Agreements (COVID-19) Assistance Listing Number: 93.558; 10.557; 93.268 Federal Award Identification Number: 1901METANF, 2001METANF, 2101METANF; 194ME743W5003, 204ME743W5003, 214ME743W5003, 224ME743W5003, 228ME000M2003, 214ME701W1003, 214ME701W1006, 224ME701W1003, 224ME701W1006, 214ME721W6003, 214ME721W6006, 214ME752W7003; NH23IP922604 Compliance Area: Cash management Subrecipient monitoring Type of Finding: Material weakness Material noncompliance Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.305 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department is required to monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes is minimized. Condition: The Department did not monitor subrecipients to ensure they were drawing Federal funds in accordance with cash management requirements. For cost-settled subawards, Department procedures include making equal advance monthly payments and then reconciling those amounts to the quarterly financial reports submitted by the subrecipient. This procedure does not take into consideration the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes. For ?cost-settled by invoice? (reimbursement) subawards, Department procedures do not require obtaining documentation to support the monthly invoices submitted by the subrecipient for costs that were already paid by the subrecipient, thus verifying it was for reimbursement and not advance payment. Context: In fiscal year 2022, the Department provided: ? $17.9 million to subrecipients from TANF grant funds of $81.9 million. TANF?s subawards are either cost-settled, cost-settled by invoice, or fee for service. ? $3.6 million to subrecipients from WIC grant funds of $15 million. All of WIC?s subawards are cost-settled. ? $2.5 million to subrecipients from Immunization Cooperative Agreements grant funds of $23 million. Immunization Cooperative Agreement?s subawards are either cost-settled or cost-settled by invoice. Cause: ? Misinterpretation of Federal regulations. 2 CFR 200.305(b)(1) references that the timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity. The Department interpreted this Federal requirement to mean it applied to the State; however, the requirement is directed towards non-Federal entities other than states. ? Lack of adequate subrecipient monitoring procedures. In addition to monitoring the total amount paid to subrecipients, the Department is required to monitor the timing between when the subrecipient receives Federal funds from the Department and when the subrecipient disburses those funds for program purposes. Effect: ? Noncompliance with subrecipient cash management requirements ? Federal programs may not be effectively and efficiently administered. ? The Federal government may require the implementation of more stringent subrecipient cash management procedures. Recommendation: We recommend that the Department implement monitoring procedures to ensure that: ? the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes is minimized for cost-settled subawards. ? the payment of Federal funds to the subrecipient is for reimbursement purposes, and not for advance payment, for ?cost-settled by invoice? subawards. Corrective Action Plan: See F-25 Management?s Response: The Department disagrees with this finding. The Department reviews budgeted expenses to determine their timing and nature (one time, recurring, allowability); reviews quarterly expense reports and alters payments to meet immediate cash needs, and finally, monitors subrecipient single audits to ensure there are no cash management findings. The Department?s approach is administratively reasonable and does minimize the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes given administrative and operational needs. We believe we have procedures in place that can be corroborated by the fact that our subrecipients do not receive single audit findings related to cash management. Contact: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075 Auditor?s Concluding Remarks: The subrecipient monitoring procedures outlined in Management?s Response do not ensure that subrecipients are drawing funds in accordance with Federal cash management requirements, as follows: ? Reviewing budgeted expenses is not monitoring the subrecipient?s compliance with cash management requirements as the subrecipient has not disbursed the funds yet. ? The Department does not obtain documentation to support the timing of the subrecipient?s expenditures reported on the quarterly expense reports and to substantiate compliance. ? Though reviewing the subrecipient?s Single Audits for findings is beneficial: o the Single Audit is usually completed towards the end or after the grant award period. o it is not guaranteed that cash management will be selected for testing by the subrecipient?s auditor; therefore, relying on the subrecipient?s auditor to discover cash management issues is not an adequate procedure to monitor the subrecipient?s compliance with that requirement. Therefore, the Department was noncompliant with Federal regulation 2 CFR 200.305 that requires monitoring cash drawdowns of subrecipients to ensure that the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes is minimized. The finding remains as stated. (State Number: 22-1111-04)
(2022-069) Title: Internal control over subrecipient cash management needs improvement Prior Year Findings: See Schedule of Findings and Questioned Costs for chart/table State Department: Health and Human Services State Bureau: Division of Contract Management Federal Agency: U.S. Department of Health and Human Services U.S. Department of Agriculture Assistance Listing Title: Temporary Assistance for Needy Families (TANF) (COVID-19) Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) (COVID-19) Immunization Cooperative Agreements (COVID-19) Assistance Listing Number: 93.558; 10.557; 93.268 Federal Award Identification Number: 1901METANF, 2001METANF, 2101METANF; 194ME743W5003, 204ME743W5003, 214ME743W5003, 224ME743W5003, 228ME000M2003, 214ME701W1003, 214ME701W1006, 224ME701W1003, 224ME701W1006, 214ME721W6003, 214ME721W6006, 214ME752W7003; NH23IP922604 Compliance Area: Cash management Subrecipient monitoring Type of Finding: Material weakness Material noncompliance Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.305 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department is required to monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes is minimized. Condition: The Department did not monitor subrecipients to ensure they were drawing Federal funds in accordance with cash management requirements. For cost-settled subawards, Department procedures include making equal advance monthly payments and then reconciling those amounts to the quarterly financial reports submitted by the subrecipient. This procedure does not take into consideration the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes. For ?cost-settled by invoice? (reimbursement) subawards, Department procedures do not require obtaining documentation to support the monthly invoices submitted by the subrecipient for costs that were already paid by the subrecipient, thus verifying it was for reimbursement and not advance payment. Context: In fiscal year 2022, the Department provided: ? $17.9 million to subrecipients from TANF grant funds of $81.9 million. TANF?s subawards are either cost-settled, cost-settled by invoice, or fee for service. ? $3.6 million to subrecipients from WIC grant funds of $15 million. All of WIC?s subawards are cost-settled. ? $2.5 million to subrecipients from Immunization Cooperative Agreements grant funds of $23 million. Immunization Cooperative Agreement?s subawards are either cost-settled or cost-settled by invoice. Cause: ? Misinterpretation of Federal regulations. 2 CFR 200.305(b)(1) references that the timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity. The Department interpreted this Federal requirement to mean it applied to the State; however, the requirement is directed towards non-Federal entities other than states. ? Lack of adequate subrecipient monitoring procedures. In addition to monitoring the total amount paid to subrecipients, the Department is required to monitor the timing between when the subrecipient receives Federal funds from the Department and when the subrecipient disburses those funds for program purposes. Effect: ? Noncompliance with subrecipient cash management requirements ? Federal programs may not be effectively and efficiently administered. ? The Federal government may require the implementation of more stringent subrecipient cash management procedures. Recommendation: We recommend that the Department implement monitoring procedures to ensure that: ? the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes is minimized for cost-settled subawards. ? the payment of Federal funds to the subrecipient is for reimbursement purposes, and not for advance payment, for ?cost-settled by invoice? subawards. Corrective Action Plan: See F-25 Management?s Response: The Department disagrees with this finding. The Department reviews budgeted expenses to determine their timing and nature (one time, recurring, allowability); reviews quarterly expense reports and alters payments to meet immediate cash needs, and finally, monitors subrecipient single audits to ensure there are no cash management findings. The Department?s approach is administratively reasonable and does minimize the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes given administrative and operational needs. We believe we have procedures in place that can be corroborated by the fact that our subrecipients do not receive single audit findings related to cash management. Contact: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075 Auditor?s Concluding Remarks: The subrecipient monitoring procedures outlined in Management?s Response do not ensure that subrecipients are drawing funds in accordance with Federal cash management requirements, as follows: ? Reviewing budgeted expenses is not monitoring the subrecipient?s compliance with cash management requirements as the subrecipient has not disbursed the funds yet. ? The Department does not obtain documentation to support the timing of the subrecipient?s expenditures reported on the quarterly expense reports and to substantiate compliance. ? Though reviewing the subrecipient?s Single Audits for findings is beneficial: o the Single Audit is usually completed towards the end or after the grant award period. o it is not guaranteed that cash management will be selected for testing by the subrecipient?s auditor; therefore, relying on the subrecipient?s auditor to discover cash management issues is not an adequate procedure to monitor the subrecipient?s compliance with that requirement. Therefore, the Department was noncompliant with Federal regulation 2 CFR 200.305 that requires monitoring cash drawdowns of subrecipients to ensure that the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes is minimized. The finding remains as stated. (State Number: 22-1111-04)
(2022-069) Title: Internal control over subrecipient cash management needs improvement Prior Year Findings: See Schedule of Findings and Questioned Costs for chart/table State Department: Health and Human Services State Bureau: Division of Contract Management Federal Agency: U.S. Department of Health and Human Services U.S. Department of Agriculture Assistance Listing Title: Temporary Assistance for Needy Families (TANF) (COVID-19) Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) (COVID-19) Immunization Cooperative Agreements (COVID-19) Assistance Listing Number: 93.558; 10.557; 93.268 Federal Award Identification Number: 1901METANF, 2001METANF, 2101METANF; 194ME743W5003, 204ME743W5003, 214ME743W5003, 224ME743W5003, 228ME000M2003, 214ME701W1003, 214ME701W1006, 224ME701W1003, 224ME701W1006, 214ME721W6003, 214ME721W6006, 214ME752W7003; NH23IP922604 Compliance Area: Cash management Subrecipient monitoring Type of Finding: Material weakness Material noncompliance Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.305 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department is required to monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes is minimized. Condition: The Department did not monitor subrecipients to ensure they were drawing Federal funds in accordance with cash management requirements. For cost-settled subawards, Department procedures include making equal advance monthly payments and then reconciling those amounts to the quarterly financial reports submitted by the subrecipient. This procedure does not take into consideration the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes. For ?cost-settled by invoice? (reimbursement) subawards, Department procedures do not require obtaining documentation to support the monthly invoices submitted by the subrecipient for costs that were already paid by the subrecipient, thus verifying it was for reimbursement and not advance payment. Context: In fiscal year 2022, the Department provided: ? $17.9 million to subrecipients from TANF grant funds of $81.9 million. TANF?s subawards are either cost-settled, cost-settled by invoice, or fee for service. ? $3.6 million to subrecipients from WIC grant funds of $15 million. All of WIC?s subawards are cost-settled. ? $2.5 million to subrecipients from Immunization Cooperative Agreements grant funds of $23 million. Immunization Cooperative Agreement?s subawards are either cost-settled or cost-settled by invoice. Cause: ? Misinterpretation of Federal regulations. 2 CFR 200.305(b)(1) references that the timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity. The Department interpreted this Federal requirement to mean it applied to the State; however, the requirement is directed towards non-Federal entities other than states. ? Lack of adequate subrecipient monitoring procedures. In addition to monitoring the total amount paid to subrecipients, the Department is required to monitor the timing between when the subrecipient receives Federal funds from the Department and when the subrecipient disburses those funds for program purposes. Effect: ? Noncompliance with subrecipient cash management requirements ? Federal programs may not be effectively and efficiently administered. ? The Federal government may require the implementation of more stringent subrecipient cash management procedures. Recommendation: We recommend that the Department implement monitoring procedures to ensure that: ? the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes is minimized for cost-settled subawards. ? the payment of Federal funds to the subrecipient is for reimbursement purposes, and not for advance payment, for ?cost-settled by invoice? subawards. Corrective Action Plan: See F-25 Management?s Response: The Department disagrees with this finding. The Department reviews budgeted expenses to determine their timing and nature (one time, recurring, allowability); reviews quarterly expense reports and alters payments to meet immediate cash needs, and finally, monitors subrecipient single audits to ensure there are no cash management findings. The Department?s approach is administratively reasonable and does minimize the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes given administrative and operational needs. We believe we have procedures in place that can be corroborated by the fact that our subrecipients do not receive single audit findings related to cash management. Contact: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075 Auditor?s Concluding Remarks: The subrecipient monitoring procedures outlined in Management?s Response do not ensure that subrecipients are drawing funds in accordance with Federal cash management requirements, as follows: ? Reviewing budgeted expenses is not monitoring the subrecipient?s compliance with cash management requirements as the subrecipient has not disbursed the funds yet. ? The Department does not obtain documentation to support the timing of the subrecipient?s expenditures reported on the quarterly expense reports and to substantiate compliance. ? Though reviewing the subrecipient?s Single Audits for findings is beneficial: o the Single Audit is usually completed towards the end or after the grant award period. o it is not guaranteed that cash management will be selected for testing by the subrecipient?s auditor; therefore, relying on the subrecipient?s auditor to discover cash management issues is not an adequate procedure to monitor the subrecipient?s compliance with that requirement. Therefore, the Department was noncompliant with Federal regulation 2 CFR 200.305 that requires monitoring cash drawdowns of subrecipients to ensure that the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes is minimized. The finding remains as stated. (State Number: 22-1111-04)
(2022-069) Title: Internal control over subrecipient cash management needs improvement Prior Year Findings: See Schedule of Findings and Questioned Costs for chart/table State Department: Health and Human Services State Bureau: Division of Contract Management Federal Agency: U.S. Department of Health and Human Services U.S. Department of Agriculture Assistance Listing Title: Temporary Assistance for Needy Families (TANF) (COVID-19) Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) (COVID-19) Immunization Cooperative Agreements (COVID-19) Assistance Listing Number: 93.558; 10.557; 93.268 Federal Award Identification Number: 1901METANF, 2001METANF, 2101METANF; 194ME743W5003, 204ME743W5003, 214ME743W5003, 224ME743W5003, 228ME000M2003, 214ME701W1003, 214ME701W1006, 224ME701W1003, 224ME701W1006, 214ME721W6003, 214ME721W6006, 214ME752W7003; NH23IP922604 Compliance Area: Cash management Subrecipient monitoring Type of Finding: Material weakness Material noncompliance Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.305 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department is required to monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes is minimized. Condition: The Department did not monitor subrecipients to ensure they were drawing Federal funds in accordance with cash management requirements. For cost-settled subawards, Department procedures include making equal advance monthly payments and then reconciling those amounts to the quarterly financial reports submitted by the subrecipient. This procedure does not take into consideration the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes. For ?cost-settled by invoice? (reimbursement) subawards, Department procedures do not require obtaining documentation to support the monthly invoices submitted by the subrecipient for costs that were already paid by the subrecipient, thus verifying it was for reimbursement and not advance payment. Context: In fiscal year 2022, the Department provided: ? $17.9 million to subrecipients from TANF grant funds of $81.9 million. TANF?s subawards are either cost-settled, cost-settled by invoice, or fee for service. ? $3.6 million to subrecipients from WIC grant funds of $15 million. All of WIC?s subawards are cost-settled. ? $2.5 million to subrecipients from Immunization Cooperative Agreements grant funds of $23 million. Immunization Cooperative Agreement?s subawards are either cost-settled or cost-settled by invoice. Cause: ? Misinterpretation of Federal regulations. 2 CFR 200.305(b)(1) references that the timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity. The Department interpreted this Federal requirement to mean it applied to the State; however, the requirement is directed towards non-Federal entities other than states. ? Lack of adequate subrecipient monitoring procedures. In addition to monitoring the total amount paid to subrecipients, the Department is required to monitor the timing between when the subrecipient receives Federal funds from the Department and when the subrecipient disburses those funds for program purposes. Effect: ? Noncompliance with subrecipient cash management requirements ? Federal programs may not be effectively and efficiently administered. ? The Federal government may require the implementation of more stringent subrecipient cash management procedures. Recommendation: We recommend that the Department implement monitoring procedures to ensure that: ? the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes is minimized for cost-settled subawards. ? the payment of Federal funds to the subrecipient is for reimbursement purposes, and not for advance payment, for ?cost-settled by invoice? subawards. Corrective Action Plan: See F-25 Management?s Response: The Department disagrees with this finding. The Department reviews budgeted expenses to determine their timing and nature (one time, recurring, allowability); reviews quarterly expense reports and alters payments to meet immediate cash needs, and finally, monitors subrecipient single audits to ensure there are no cash management findings. The Department?s approach is administratively reasonable and does minimize the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes given administrative and operational needs. We believe we have procedures in place that can be corroborated by the fact that our subrecipients do not receive single audit findings related to cash management. Contact: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075 Auditor?s Concluding Remarks: The subrecipient monitoring procedures outlined in Management?s Response do not ensure that subrecipients are drawing funds in accordance with Federal cash management requirements, as follows: ? Reviewing budgeted expenses is not monitoring the subrecipient?s compliance with cash management requirements as the subrecipient has not disbursed the funds yet. ? The Department does not obtain documentation to support the timing of the subrecipient?s expenditures reported on the quarterly expense reports and to substantiate compliance. ? Though reviewing the subrecipient?s Single Audits for findings is beneficial: o the Single Audit is usually completed towards the end or after the grant award period. o it is not guaranteed that cash management will be selected for testing by the subrecipient?s auditor; therefore, relying on the subrecipient?s auditor to discover cash management issues is not an adequate procedure to monitor the subrecipient?s compliance with that requirement. Therefore, the Department was noncompliant with Federal regulation 2 CFR 200.305 that requires monitoring cash drawdowns of subrecipients to ensure that the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes is minimized. The finding remains as stated. (State Number: 22-1111-04)
(2022-069) Title: Internal control over subrecipient cash management needs improvement Prior Year Findings: See Schedule of Findings and Questioned Costs for chart/table State Department: Health and Human Services State Bureau: Division of Contract Management Federal Agency: U.S. Department of Health and Human Services U.S. Department of Agriculture Assistance Listing Title: Temporary Assistance for Needy Families (TANF) (COVID-19) Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) (COVID-19) Immunization Cooperative Agreements (COVID-19) Assistance Listing Number: 93.558; 10.557; 93.268 Federal Award Identification Number: 1901METANF, 2001METANF, 2101METANF; 194ME743W5003, 204ME743W5003, 214ME743W5003, 224ME743W5003, 228ME000M2003, 214ME701W1003, 214ME701W1006, 224ME701W1003, 224ME701W1006, 214ME721W6003, 214ME721W6006, 214ME752W7003; NH23IP922604 Compliance Area: Cash management Subrecipient monitoring Type of Finding: Material weakness Material noncompliance Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.305 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department is required to monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes is minimized. Condition: The Department did not monitor subrecipients to ensure they were drawing Federal funds in accordance with cash management requirements. For cost-settled subawards, Department procedures include making equal advance monthly payments and then reconciling those amounts to the quarterly financial reports submitted by the subrecipient. This procedure does not take into consideration the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes. For ?cost-settled by invoice? (reimbursement) subawards, Department procedures do not require obtaining documentation to support the monthly invoices submitted by the subrecipient for costs that were already paid by the subrecipient, thus verifying it was for reimbursement and not advance payment. Context: In fiscal year 2022, the Department provided: ? $17.9 million to subrecipients from TANF grant funds of $81.9 million. TANF?s subawards are either cost-settled, cost-settled by invoice, or fee for service. ? $3.6 million to subrecipients from WIC grant funds of $15 million. All of WIC?s subawards are cost-settled. ? $2.5 million to subrecipients from Immunization Cooperative Agreements grant funds of $23 million. Immunization Cooperative Agreement?s subawards are either cost-settled or cost-settled by invoice. Cause: ? Misinterpretation of Federal regulations. 2 CFR 200.305(b)(1) references that the timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity. The Department interpreted this Federal requirement to mean it applied to the State; however, the requirement is directed towards non-Federal entities other than states. ? Lack of adequate subrecipient monitoring procedures. In addition to monitoring the total amount paid to subrecipients, the Department is required to monitor the timing between when the subrecipient receives Federal funds from the Department and when the subrecipient disburses those funds for program purposes. Effect: ? Noncompliance with subrecipient cash management requirements ? Federal programs may not be effectively and efficiently administered. ? The Federal government may require the implementation of more stringent subrecipient cash management procedures. Recommendation: We recommend that the Department implement monitoring procedures to ensure that: ? the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes is minimized for cost-settled subawards. ? the payment of Federal funds to the subrecipient is for reimbursement purposes, and not for advance payment, for ?cost-settled by invoice? subawards. Corrective Action Plan: See F-25 Management?s Response: The Department disagrees with this finding. The Department reviews budgeted expenses to determine their timing and nature (one time, recurring, allowability); reviews quarterly expense reports and alters payments to meet immediate cash needs, and finally, monitors subrecipient single audits to ensure there are no cash management findings. The Department?s approach is administratively reasonable and does minimize the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes given administrative and operational needs. We believe we have procedures in place that can be corroborated by the fact that our subrecipients do not receive single audit findings related to cash management. Contact: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075 Auditor?s Concluding Remarks: The subrecipient monitoring procedures outlined in Management?s Response do not ensure that subrecipients are drawing funds in accordance with Federal cash management requirements, as follows: ? Reviewing budgeted expenses is not monitoring the subrecipient?s compliance with cash management requirements as the subrecipient has not disbursed the funds yet. ? The Department does not obtain documentation to support the timing of the subrecipient?s expenditures reported on the quarterly expense reports and to substantiate compliance. ? Though reviewing the subrecipient?s Single Audits for findings is beneficial: o the Single Audit is usually completed towards the end or after the grant award period. o it is not guaranteed that cash management will be selected for testing by the subrecipient?s auditor; therefore, relying on the subrecipient?s auditor to discover cash management issues is not an adequate procedure to monitor the subrecipient?s compliance with that requirement. Therefore, the Department was noncompliant with Federal regulation 2 CFR 200.305 that requires monitoring cash drawdowns of subrecipients to ensure that the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes is minimized. The finding remains as stated. (State Number: 22-1111-04)
(2022-069) Title: Internal control over subrecipient cash management needs improvement Prior Year Findings: See Schedule of Findings and Questioned Costs for chart/table State Department: Health and Human Services State Bureau: Division of Contract Management Federal Agency: U.S. Department of Health and Human Services U.S. Department of Agriculture Assistance Listing Title: Temporary Assistance for Needy Families (TANF) (COVID-19) Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) (COVID-19) Immunization Cooperative Agreements (COVID-19) Assistance Listing Number: 93.558; 10.557; 93.268 Federal Award Identification Number: 1901METANF, 2001METANF, 2101METANF; 194ME743W5003, 204ME743W5003, 214ME743W5003, 224ME743W5003, 228ME000M2003, 214ME701W1003, 214ME701W1006, 224ME701W1003, 224ME701W1006, 214ME721W6003, 214ME721W6006, 214ME752W7003; NH23IP922604 Compliance Area: Cash management Subrecipient monitoring Type of Finding: Material weakness Material noncompliance Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.305 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department is required to monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes is minimized. Condition: The Department did not monitor subrecipients to ensure they were drawing Federal funds in accordance with cash management requirements. For cost-settled subawards, Department procedures include making equal advance monthly payments and then reconciling those amounts to the quarterly financial reports submitted by the subrecipient. This procedure does not take into consideration the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes. For ?cost-settled by invoice? (reimbursement) subawards, Department procedures do not require obtaining documentation to support the monthly invoices submitted by the subrecipient for costs that were already paid by the subrecipient, thus verifying it was for reimbursement and not advance payment. Context: In fiscal year 2022, the Department provided: ? $17.9 million to subrecipients from TANF grant funds of $81.9 million. TANF?s subawards are either cost-settled, cost-settled by invoice, or fee for service. ? $3.6 million to subrecipients from WIC grant funds of $15 million. All of WIC?s subawards are cost-settled. ? $2.5 million to subrecipients from Immunization Cooperative Agreements grant funds of $23 million. Immunization Cooperative Agreement?s subawards are either cost-settled or cost-settled by invoice. Cause: ? Misinterpretation of Federal regulations. 2 CFR 200.305(b)(1) references that the timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity. The Department interpreted this Federal requirement to mean it applied to the State; however, the requirement is directed towards non-Federal entities other than states. ? Lack of adequate subrecipient monitoring procedures. In addition to monitoring the total amount paid to subrecipients, the Department is required to monitor the timing between when the subrecipient receives Federal funds from the Department and when the subrecipient disburses those funds for program purposes. Effect: ? Noncompliance with subrecipient cash management requirements ? Federal programs may not be effectively and efficiently administered. ? The Federal government may require the implementation of more stringent subrecipient cash management procedures. Recommendation: We recommend that the Department implement monitoring procedures to ensure that: ? the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes is minimized for cost-settled subawards. ? the payment of Federal funds to the subrecipient is for reimbursement purposes, and not for advance payment, for ?cost-settled by invoice? subawards. Corrective Action Plan: See F-25 Management?s Response: The Department disagrees with this finding. The Department reviews budgeted expenses to determine their timing and nature (one time, recurring, allowability); reviews quarterly expense reports and alters payments to meet immediate cash needs, and finally, monitors subrecipient single audits to ensure there are no cash management findings. The Department?s approach is administratively reasonable and does minimize the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes given administrative and operational needs. We believe we have procedures in place that can be corroborated by the fact that our subrecipients do not receive single audit findings related to cash management. Contact: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075 Auditor?s Concluding Remarks: The subrecipient monitoring procedures outlined in Management?s Response do not ensure that subrecipients are drawing funds in accordance with Federal cash management requirements, as follows: ? Reviewing budgeted expenses is not monitoring the subrecipient?s compliance with cash management requirements as the subrecipient has not disbursed the funds yet. ? The Department does not obtain documentation to support the timing of the subrecipient?s expenditures reported on the quarterly expense reports and to substantiate compliance. ? Though reviewing the subrecipient?s Single Audits for findings is beneficial: o the Single Audit is usually completed towards the end or after the grant award period. o it is not guaranteed that cash management will be selected for testing by the subrecipient?s auditor; therefore, relying on the subrecipient?s auditor to discover cash management issues is not an adequate procedure to monitor the subrecipient?s compliance with that requirement. Therefore, the Department was noncompliant with Federal regulation 2 CFR 200.305 that requires monitoring cash drawdowns of subrecipients to ensure that the time elapsing between the payment of Federal funds to the subrecipient and the subrecipient?s actual disbursement for program purposes is minimized. The finding remains as stated. (State Number: 22-1111-04)
Criteria and Condition: The Organization is required to properly retain and store documentation surrounding grant reimbursements. The Organization should have strong policies and internal controls in place to ensure reimbursement requests are in line with 2 CFR 200.305(b)(3). Cause: This was caused by inadequate policies and weakened internal controls. Effect: The lack of adequate documentation may result in the Organization being non-compliant with 2 CFR 200.305(b)(3). Not having strong policies in place and weakened internal controls could result in questioned costs. Questioned Costs: There are no questioned costs as a result of this finding. Perspective Information: The finding is a systemic program and was identified in all cases of the testing sample. The sample was a statistically valid sample. Recommendation: We recommend the Organization implement policies and procedures that outline the process for requesting reimbursement in line with 2 CFR 200.305(b)(3). Pursuant to 2 CFR 200.305(b)(3), program costs must be paid by non-federal entity funds before submitting a payment request. Uniform Guidance states that a non-federal entity must distribute funds for program purposes before requesting payment from the federal awarding agency or pass through entity. We recommend the Organization ensure proper documentation is retained to serve as proof for a reimbursement request. Views of Responsible Officials: The Organization agrees with the finding and will adhere to the planned corrective action.
MATERIAL WEAKNESSES 2022-001 - Procurement, Suspension and Debarment Federal Program Information: US Department of Agriculture - ALN# - 10.555/10.559/10.582 - Child Nutrition Cluster Criteria: The following CFR(s) apply to this finding: 2 CFR 200.514(c), 2 CFR section 200.305(b)(3). Condition: During audit procedures, it was identified that the Unit was not completing procurement documentation for all purchases being made outside of the Food Directors Management Contract. Cause: The Unit does not have the necessary internal controls over compliance. Effect: Not completing this documentation could result in purchasing from vendors who have been debarred. Identification of Questioned Costs: None identified. Context: Not all of the samples tested had the appropriate procurement form attached. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the Unit implement internal control processes and procedures to ensure that federal procurement form is completed for any vendors used outside of the Food Directors Management Contract. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the Green Mountain Unified School District.
MATERIAL WEAKNESSES 2022-001 - Procurement, Suspension and Debarment Federal Program Information: US Department of Agriculture - ALN# - 10.555/10.559/10.582 - Child Nutrition Cluster Criteria: The following CFR(s) apply to this finding: 2 CFR 200.514(c), 2 CFR section 200.305(b)(3). Condition: During audit procedures, it was identified that the Unit was not completing procurement documentation for all purchases being made outside of the Food Directors Management Contract. Cause: The Unit does not have the necessary internal controls over compliance. Effect: Not completing this documentation could result in purchasing from vendors who have been debarred. Identification of Questioned Costs: None identified. Context: Not all of the samples tested had the appropriate procurement form attached. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the Unit implement internal control processes and procedures to ensure that federal procurement form is completed for any vendors used outside of the Food Directors Management Contract. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the Green Mountain Unified School District.
MATERIAL WEAKNESSES 2022-001 - Procurement, Suspension and Debarment Federal Program Information: US Department of Agriculture - ALN# - 10.555/10.559/10.582 - Child Nutrition Cluster Criteria: The following CFR(s) apply to this finding: 2 CFR 200.514(c), 2 CFR section 200.305(b)(3). Condition: During audit procedures, it was identified that the Unit was not completing procurement documentation for all purchases being made outside of the Food Directors Management Contract. Cause: The Unit does not have the necessary internal controls over compliance. Effect: Not completing this documentation could result in purchasing from vendors who have been debarred. Identification of Questioned Costs: None identified. Context: Not all of the samples tested had the appropriate procurement form attached. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the Unit implement internal control processes and procedures to ensure that federal procurement form is completed for any vendors used outside of the Food Directors Management Contract. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the Green Mountain Unified School District.
MATERIAL WEAKNESSES 2022-001 - Procurement, Suspension and Debarment Federal Program Information: US Department of Agriculture - ALN# - 10.555/10.559/10.582 - Child Nutrition Cluster Criteria: The following CFR(s) apply to this finding: 2 CFR 200.514(c), 2 CFR section 200.305(b)(3). Condition: During audit procedures, it was identified that the Unit was not completing procurement documentation for all purchases being made outside of the Food Directors Management Contract. Cause: The Unit does not have the necessary internal controls over compliance. Effect: Not completing this documentation could result in purchasing from vendors who have been debarred. Identification of Questioned Costs: None identified. Context: Not all of the samples tested had the appropriate procurement form attached. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the Unit implement internal control processes and procedures to ensure that federal procurement form is completed for any vendors used outside of the Food Directors Management Contract. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the Green Mountain Unified School District.
2 CFR Section 200.305(b) states in part 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. In addition to basic cash management principles, grant award notification terms and conditions state that in accordance with 2 CFR 200.305(b), which applies to the Higher Education Emergency Relief Fund (HEERF) program, grantees must minimize the time between drawing down funds from G5 and applying those funds to support the awards activities. Consistent with this requirement, grantees must maintain grant funds in interest-bearing accounts, and any interest earned on grant funds above $500 must be returned to the Federal government. Therefore, the Department requires grantees to only draw down the minimum amount of grant funds necessary, where they are able to be applied immediately, within 3 days, for the grant purposes, and to establish a distribution plan prior to drawing down grant funds. Also, 2 CFR Section 200.305(b) states interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS) through an electronic medium using either Automated Clearing House (ACH) network or a Fedwire Funds Service payment. Testing over the HEERF grant identified that $479,328 was drawn down on December 18, 2020, and still not fully expended as of June 30, 2022. At June 30, 2022, the balance in the fund was $75,068. Estimated interest earned on these funds during the fiscal that were not fully expended was $1224, therefore $724 should have been remitted to the Department of Health and Human Services. This is due to the Center not reviewing the guidance above to ensure advance monies are timely spent and interest earned on advance monies were properly remitted. Failure to minimize the time between drawing down funds and applying those funds to award activities and remittance of interest could result in improper spending and federal questioned costs, which could result in a loss of funding. The Center should maintain and follow written procedures that minimize the time lapsing between transfer of funds and their disbursement. Interest earned should be monitored and timely remitted when in excess of the allowable amount able to be retained. Financial management systems should meet the standards for fund control and accountability.
2 CFR Section 200.305(b) states in part 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. In addition to basic cash management principles, grant award notification terms and conditions state that in accordance with 2 CFR 200.305(b), which applies to the Higher Education Emergency Relief Fund (HEERF) program, grantees must minimize the time between drawing down funds from G5 and applying those funds to support the awards activities. Consistent with this requirement, grantees must maintain grant funds in interest-bearing accounts, and any interest earned on grant funds above $500 must be returned to the Federal government. Therefore, the Department requires grantees to only draw down the minimum amount of grant funds necessary, where they are able to be applied immediately, within 3 days, for the grant purposes, and to establish a distribution plan prior to drawing down grant funds. Also, 2 CFR Section 200.305(b) states interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS) through an electronic medium using either Automated Clearing House (ACH) network or a Fedwire Funds Service payment. Testing over the HEERF grant identified that $479,328 was drawn down on December 18, 2020, and still not fully expended as of June 30, 2022. At June 30, 2022, the balance in the fund was $75,068. Estimated interest earned on these funds during the fiscal that were not fully expended was $1224, therefore $724 should have been remitted to the Department of Health and Human Services. This is due to the Center not reviewing the guidance above to ensure advance monies are timely spent and interest earned on advance monies were properly remitted. Failure to minimize the time between drawing down funds and applying those funds to award activities and remittance of interest could result in improper spending and federal questioned costs, which could result in a loss of funding. The Center should maintain and follow written procedures that minimize the time lapsing between transfer of funds and their disbursement. Interest earned should be monitored and timely remitted when in excess of the allowable amount able to be retained. Financial management systems should meet the standards for fund control and accountability.
The University of Illinois Urbana-Champaign did not make a subrecipient payment timely under the Research and Development Cluster: Office of Science Financial Assistance Program and the University of Illinois Chicago did not make a subrecipient payment timely under the HIV-Related Training and Technical Assistance program. Out of six subrecipient payments made by the University of Illinois Urbana-Champaign, one payment (17%) was not submitted within 30 days after receipt of the billing from the subrecipient. The University of Illinois Urbana-Champaign made payment to the subrecipient 68 days after receipt of the billing from the subrecipient. Out of fourteen subrecipient payments made by the University of Illinois Chicago, one payment (7%) was not submitted within 30 days after receipt of the billing from the subrecipient. The University of Illinois Chicago made payment to the subrecipient 85 days after receipt of the billing from the subrecipient. Under Uniform 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. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. University officials stated in the latter half of 2021, a high-volume unit at the University of Illinois Urbana-Champaign experienced a staffing shortage. The payment was not made in a timely manner due to the delay in receiving approvals. University officials stated for the University of Illinois Chicago, a new fund code was established for the current budget period for expenditure tracking purposes. Delays occurred in associating the subaward to the new fund code. Without proper program cash management policies and procedures, late subrecipient payments could result in the loss of future funding. (Finding Code No. 2022-008) Recommendation: We recommend the University of Illinois of Urbana-Champaign and the University of Illinois Chicago review current processes, policies and procedures to ensure that payments to subrecipients minimize the time elapsing between the transfer of federal funds from the pass-through entity to the subrecipient. University Response: Accepted. The University will take steps to address the recommendation in this finding.
The University of Illinois Urbana-Champaign did not make a subrecipient payment timely under the Research and Development Cluster: Office of Science Financial Assistance Program and the University of Illinois Chicago did not make a subrecipient payment timely under the HIV-Related Training and Technical Assistance program. Out of six subrecipient payments made by the University of Illinois Urbana-Champaign, one payment (17%) was not submitted within 30 days after receipt of the billing from the subrecipient. The University of Illinois Urbana-Champaign made payment to the subrecipient 68 days after receipt of the billing from the subrecipient. Out of fourteen subrecipient payments made by the University of Illinois Chicago, one payment (7%) was not submitted within 30 days after receipt of the billing from the subrecipient. The University of Illinois Chicago made payment to the subrecipient 85 days after receipt of the billing from the subrecipient. Under Uniform 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. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. University officials stated in the latter half of 2021, a high-volume unit at the University of Illinois Urbana-Champaign experienced a staffing shortage. The payment was not made in a timely manner due to the delay in receiving approvals. University officials stated for the University of Illinois Chicago, a new fund code was established for the current budget period for expenditure tracking purposes. Delays occurred in associating the subaward to the new fund code. Without proper program cash management policies and procedures, late subrecipient payments could result in the loss of future funding. (Finding Code No. 2022-008) Recommendation: We recommend the University of Illinois of Urbana-Champaign and the University of Illinois Chicago review current processes, policies and procedures to ensure that payments to subrecipients minimize the time elapsing between the transfer of federal funds from the pass-through entity to the subrecipient. University Response: Accepted. The University will take steps to address the recommendation in this finding.
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2022-001 (repeat finding of 2021-002) Youth Homelessness Demonstration Program, CFDA #14.276 Condition and Criteria: According to 2 CFR Section 200.305(b)(3) all reimbursement requests should be based on supporting documentation that shows the cost was incurred before the request for payment and that the payment to vendor was made. All the cash drawdown reports did not have adequate supporting documentation for the drawdown request. Cause: The reason for the lack of support in the drawdowns is due to using budgeted or estimated grant amounts as a basis for the request instead of actual expenses. Effect: The effect is that the Organization could have either requested funds before actual expenses and not be in compliance with the cash management requirements under Uniform Grant Guidance or the Organization could be shorting themselves funds during the grant period and causing cash flow issues. Context: In reviewing all the cash drawdown requests, we could not find the supporting documentation to support the expense was incurred before the drawdown request. We also could not determine that the cash payment was made to the vendor before the Organization requested it from the vendor. Auditor?s Recommendation: We recommend that each reimbursement request agrees to what is allocated through the accounting system by grant or program for actual expenses. This will help support the request and, if needed, a method to provide the actual invoice for the expense being requested. Management response: This is now our policy. Each grant program has its own identifiable ?cost center? that both revenue and expenses are posted in our accounting system.
Criteria: The federal program noted above is a reimbursement-based grant. As required by the Uniform Guidance (2 CFR section 200.305(b)(3)), when non-federal entities are funded under the reimbursement method, the District is required to pay for the costs for which reimbursement is requested prior to the date of the reimbursement request. Condition and Context: Internal controls were not sufficient to ensure unspent funds were returned in a timely fashion, resulting in the District drawing down grant funds before expenditures had been occurred. Effect of Condition: The District?s system of internal control did not identify the issue noted above and as a result the District did not comply with the requirements. Cause: A lack of oversight by personnel over the federal program led to noncompliance with the requirement of Uniform Guidance as it pertains to the Cash Management Policy and in returning approximately $35,000 in unspent funds in a timely fashion. Questioned Costs: None Recommendation: Finance and management should be familiar with all aspects of the Cash Management Policy and ensure that it meets the requirements of the Uniform Guidance. View of Responsible Officials and Planned Corrective Action: The District agrees with the finding and management will take necessary steps to adopt a cash management policy that meets all the requirements.
Finding Reference Number: SA2022-005 - Cash Management ? Draw Down of Community Development Block Grant Funds in Advance of Expenditures Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant ? Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-21-MC-06-0042 COVID-19 ? B-20-MW-06-0042 CDBG Daly City Pass Through #Not Available Name of Pass-through Entity: City of Daly City Criteria: Under 2 CFR 200.305, a CDBG grantee is prohibited from drawing funds down from its line of credit in advance of cash need, and must minimize the time elapsing between the transfer of funds from its line of credit, and the disbursement of the funds. Advance payment must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the grantee or subrecipient carrying out an eligible activity. Condition: We selected eight non-payroll disbursements related to projects and subgrants for testing and noted one disbursement in April 2022 in the amount of $142,431 had been charged to the CDBG program in the amount of $149,927. The difference of $7,496 was the retention payable to the vendor, which was not paid in cash until after June 30, 2022. However, the City included the retention payable in the grant drawdown filed and received in April 2022. Cause: We understand that the retention was included in the grant drawdown due to staff oversight. Questioned Costs: We question costs in the amount of $7,496. Effect: Drawing down funds in advance does not minimize the time elapsing between receipt of funds and expenditures and is not in compliance with the cash management provisions of 2 CFR 200.305 and the CDBG program. Recommendation: The City should not draw down funds until expenditures have been paid in cash and in the event drawdowns occur prior to disbursement, ensure that the time elapsing between the draw down and the expenditure is minimized. The City should determine whether the interest earned on the grant funds advanced need to be returned to the grantor. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.
Finding Reference Number: SA2022-005 - Cash Management ? Draw Down of Community Development Block Grant Funds in Advance of Expenditures Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant ? Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-21-MC-06-0042 COVID-19 ? B-20-MW-06-0042 CDBG Daly City Pass Through #Not Available Name of Pass-through Entity: City of Daly City Criteria: Under 2 CFR 200.305, a CDBG grantee is prohibited from drawing funds down from its line of credit in advance of cash need, and must minimize the time elapsing between the transfer of funds from its line of credit, and the disbursement of the funds. Advance payment must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the grantee or subrecipient carrying out an eligible activity. Condition: We selected eight non-payroll disbursements related to projects and subgrants for testing and noted one disbursement in April 2022 in the amount of $142,431 had been charged to the CDBG program in the amount of $149,927. The difference of $7,496 was the retention payable to the vendor, which was not paid in cash until after June 30, 2022. However, the City included the retention payable in the grant drawdown filed and received in April 2022. Cause: We understand that the retention was included in the grant drawdown due to staff oversight. Questioned Costs: We question costs in the amount of $7,496. Effect: Drawing down funds in advance does not minimize the time elapsing between receipt of funds and expenditures and is not in compliance with the cash management provisions of 2 CFR 200.305 and the CDBG program. Recommendation: The City should not draw down funds until expenditures have been paid in cash and in the event drawdowns occur prior to disbursement, ensure that the time elapsing between the draw down and the expenditure is minimized. The City should determine whether the interest earned on the grant funds advanced need to be returned to the grantor. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.
Finding Reference Number: SA2022-005 - Cash Management ? Draw Down of Community Development Block Grant Funds in Advance of Expenditures Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant ? Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-21-MC-06-0042 COVID-19 ? B-20-MW-06-0042 CDBG Daly City Pass Through #Not Available Name of Pass-through Entity: City of Daly City Criteria: Under 2 CFR 200.305, a CDBG grantee is prohibited from drawing funds down from its line of credit in advance of cash need, and must minimize the time elapsing between the transfer of funds from its line of credit, and the disbursement of the funds. Advance payment must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the grantee or subrecipient carrying out an eligible activity. Condition: We selected eight non-payroll disbursements related to projects and subgrants for testing and noted one disbursement in April 2022 in the amount of $142,431 had been charged to the CDBG program in the amount of $149,927. The difference of $7,496 was the retention payable to the vendor, which was not paid in cash until after June 30, 2022. However, the City included the retention payable in the grant drawdown filed and received in April 2022. Cause: We understand that the retention was included in the grant drawdown due to staff oversight. Questioned Costs: We question costs in the amount of $7,496. Effect: Drawing down funds in advance does not minimize the time elapsing between receipt of funds and expenditures and is not in compliance with the cash management provisions of 2 CFR 200.305 and the CDBG program. Recommendation: The City should not draw down funds until expenditures have been paid in cash and in the event drawdowns occur prior to disbursement, ensure that the time elapsing between the draw down and the expenditure is minimized. The City should determine whether the interest earned on the grant funds advanced need to be returned to the grantor. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.
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 reports including CN-6 and CN-7 reports and site claim forms; however, due to lack of controls over review of the forms for accuracy, the March 2022 site claim form was overstated by 1 lunch meal from the CN report. The site claim form was used for federal reimbursement to the District and thus resulted in $5 more reimbursements than the District was entitled 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 reports.
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 reports including CN-6 and CN-7 reports and site claim forms; however, due to lack of controls over review of the forms for accuracy, the March 2022 site claim form was overstated by 1 lunch meal from the CN report. The site claim form was used for federal reimbursement to the District and thus resulted in $5 more reimbursements than the District was entitled 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 reports.
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 reports including CN-6 and CN-7 reports and site claim forms; however, due to lack of controls over review of the forms for accuracy, the March 2022 site claim form was overstated by 1 lunch meal from the CN report. The site claim form was used for federal reimbursement to the District and thus resulted in $5 more reimbursements than the District was entitled 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 reports.
Criteria: The Uniform Guidance requires nonfederal entities that receive federal awards to establish written policies, procedures, or standards of conduct as described in the following sections: Financial management (2 CFR 200.302) Payment (2 CFR 200.305) General procurement standards (2 CFR 200.318) Competition (2 CFR 200.319) Methods of procurement to be followed (2 CFR 200.320) Compensation ? personal services (2 CFR 200.430) Compensation ? fringe benefits (2 CFR 200.431) Transportation costs (2 CFR 200.474) Condition: The Town did not have written policies, procedures, and standards of conduct relative to federal awards as required by the Uniform Guidance. Cause: The Town was not aware of these requirements. Effect: The Town is not in compliance with the Uniform Guidance with respect to these written policies. Recommendation: We recommend that the Town update its policies and procedures to comply with the Uniform Guidance requirements mentioned above. Management?s Response: We agree that our existing policies do not explicitly address federal award compliance requirements. We will be updating the Town?s procedures and policies to incorporate the requirements of Part 200 of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.
1. FINDING NUMBER: 2022- 003 4. THIS FINDING IS: X New Repeat from Prior year? 2. FINDING TYPE: Internal Control Year originally reported? 3. DEFICIENCY TYPE: Significant Deficiency COVID-19 - Elementary and Secondary School Emergency Relief - E2 3. Federal Program Name and Year: 4. Project No.: 21-4998-E2 5. AL No.: 84.425D 6. Passed Through: Illinois State Board of Education 7. Federal Agency: U.S. Department of Education 8. Criteria or specific requirement (including statutory, regulatory, or other citation) The Code of Federal Regulations (CFR) Title 2, part 200.305(b)(3) states that non-federal entities must disburse funds for program purposes before requesting payment from the federal awarding agency or pass-through entity. 9. Condition The District's expenditure report filed for June 30, 2022 included expenditures paid in July and August 2022. These amounts were not reported as committed or obligated. 10. Questioned Costs None 11. Context The District received federal reimbursement before expenditures were paid and did not label the expenditures as committed or obligated. 12. Effect The June 30, 2022 expenditure report was filed overstating cash basis expenditures. The expenditure report did not include the July and August 2022 paid expenditures as committed or obligated. These expenditures were later liquidated and the final expenditure claim is correct. 13. Cause Grant expenditures reported on the final June 30, 2022 expenditure report included $8,747 that should have been reported as obligated and not included with cash basis expenditures. 14. Recommendation Grant expenditure reports should be prepared on the cash basis and obligations reported. The liquidation of the obligations should be reported on subsequent liquidation reports. 15. Management's response There is no disagreement with this finding and management will monitor all future federal reimbursement requests. Committed and obligated expenditures will be reported appropriately, and will be paid within 90 days after project completion.
Reference Number: 2022-019 Prior Year Finding: No Federal Agency: Department of the Treasury State Agency: Agency of Commerce and Community Development Federal Program: COVID-19 ? Homeowner Assistance Fund Assistance Listing Number: 21.026 Award Number and Year: HAF0030 (5/3/2021 ? 9/30/2026) Compliance Requirement: Cash Management Type of Finding Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per 2 CFR 200.305(b)(9), interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS) through an electronic medium using either Automated Clearing House (ACH) network or a Fedwire Funds Service payment. Per the U.S. Treasury?s Homeowner Assistance Fund (HAF) Frequently Asked Questions on Reporting Requirements, Question 1.15, in accordance with 2 CFR 200.305(b)(9)(ii), HAF participants may retain up to $500 in earned interest annually. Any additional interest must be remitted annually to the Department of Health and Human Services Payment Management System (PMS) through an electronic medium using either Automated Clearing House (ACH) network or a Fedwire Funds Service payment. Control: Per 2 CFR section 200.303(a), a 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. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? 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). Condition: HAF Program funds transferred to the Agency of Commerce and Community Development (Agency) by the U.S. Treasury were deposited into an interest-bearing account, but interest earned over $500 per year was not remitted to the Department of Health and Human Services Payment Management System as required. Context: The Agency received two deposits from the U.S. Treasury for the program, $5,000,000 received on 8/27/2021 and $45,000,000 received on 2/1/2022 after approval of the HAF Plan. Funds were deposited into an interest-bearing account, but interest earned on HAF funds was not calculated. As a result of the audit, the Vermont State Treasurer?s Office calculated interest earned for the program during calendar year 2021 and calendar year 2022. Total interest earned in excess of $500 per year is $2,165 for 2021 and $325,564 for 2022. Cause: The Agency did not develop sufficient procedures and internal controls to calculate interest earned on program funds and was unaware that it had earned interest in excess of $500 per year which should have been remitted to the Department of Health and Human Services. Effect: The State of Vermont retained interest earned on program funds and did not remit earnings over $500 per year to the Department of Health and Human Services as required. Questioned costs: Undetermined. Recommendation: We recommend the Agency work with U.S. Treasury officials regarding resolution of this matter. Views of responsible officials: Management agrees with the finding.
ALN Number, Federal Agency, and Program Name - COVID-19 Education Stabilization Fund - Higher Education Emergency Relief Fund - ALN 84.425F, ALN 84.425M Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - The College must minimize the elapsed time between the transfer of funds from the United States Treasury to the College and the disbursement of those funds, as outlined in CFR Section 200.305(b). In addition, CARES Act 18004(e) and CRRSA 314(e) require institutions receiving funds under HEERF I and HEERF Il submit a report to the secretary at such time and in such a manner as the secretary may require. ARP Act 2003 specifies that the same terms and conditions of CRRSA 314 apply to HEERF Ill funds. While the acts do not explicitly identity procedures by which institutions must report their uses of HEERF grant funds, pursuant to these requirements, the U.S. Department of Education required quarterly public reporting of student portion and institutional portion awards and an annual report. Condition - The College drew down an expected amount for the institutional expenditures. The actual expenditures charged to the grant differed from those expected, resulting in the timing of the drawdown to be outside of the cash management regulations. By extension, the institutional quarterly reporting was also incorrect, as it was based on the initial expenditures classifications. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The College drew down $2,725,815 for the institutional aid but did not spend the money within the required time frame allowed in accordance with cash management rules under 2 CFR Section 200.305(b). In addition, the drawdowns did not correspond With the quarterly reporting under CRRSA 314. Cause and Effect - The College used estimates to determine the amount that was eligible to perform the drawdowns through the period. The final expenditures claimed against the grant did not align with the cash drawdowns actually taken, causing exceptions within the cash management and reporting requirements. Recommendation - We recommend the College implement a process to minimize the time elapsed between the transfer of funds from the United States Treasury to the College and disbursement of those funds. In addition, we recommend management amend the quarterly reports to update the quarterly reporting to accurately reflect the changes made by management. Views of Responsible Officials and Corrective Action Plan - The College drew down funds based on expenditures that management deemed to be qualified however, at year-end, concluded to charge other expenditures to the grant causing the mismatch in the timing of drawdowns and final expenditures charged to the grant. Although HEERF and other COVID 19 Pandemic funding has ended, in the future, such expenditures will be discussed and documented prior to the drawing of funds.
ALN Number, Federal Agency, and Program Name - COVID-19 Education Stabilization Fund - Higher Education Emergency Relief Fund - ALN 84.425F, ALN 84.425M Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - The College must minimize the elapsed time between the transfer of funds from the United States Treasury to the College and the disbursement of those funds, as outlined in CFR Section 200.305(b). In addition, CARES Act 18004(e) and CRRSA 314(e) require institutions receiving funds under HEERF I and HEERF Il submit a report to the secretary at such time and in such a manner as the secretary may require. ARP Act 2003 specifies that the same terms and conditions of CRRSA 314 apply to HEERF Ill funds. While the acts do not explicitly identity procedures by which institutions must report their uses of HEERF grant funds, pursuant to these requirements, the U.S. Department of Education required quarterly public reporting of student portion and institutional portion awards and an annual report. Condition - The College drew down an expected amount for the institutional expenditures. The actual expenditures charged to the grant differed from those expected, resulting in the timing of the drawdown to be outside of the cash management regulations. By extension, the institutional quarterly reporting was also incorrect, as it was based on the initial expenditures classifications. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The College drew down $2,725,815 for the institutional aid but did not spend the money within the required time frame allowed in accordance with cash management rules under 2 CFR Section 200.305(b). In addition, the drawdowns did not correspond With the quarterly reporting under CRRSA 314. Cause and Effect - The College used estimates to determine the amount that was eligible to perform the drawdowns through the period. The final expenditures claimed against the grant did not align with the cash drawdowns actually taken, causing exceptions within the cash management and reporting requirements. Recommendation - We recommend the College implement a process to minimize the time elapsed between the transfer of funds from the United States Treasury to the College and disbursement of those funds. In addition, we recommend management amend the quarterly reports to update the quarterly reporting to accurately reflect the changes made by management. Views of Responsible Officials and Corrective Action Plan - The College drew down funds based on expenditures that management deemed to be qualified however, at year-end, concluded to charge other expenditures to the grant causing the mismatch in the timing of drawdowns and final expenditures charged to the grant. Although HEERF and other COVID 19 Pandemic funding has ended, in the future, such expenditures will be discussed and documented prior to the drawing of funds.
FA 2022-001 Improve Controls over Cash Management Compliance Requirement: Cash Management Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $195,559 Description: The School District made cash drawdowns in excess of the immediate cash needs of the Elementary and Secondary School Emergency Relief Fund program. Background Information: The School District may request Elementary and Secondary School Emergency Relief (ESSER) Fund program funds from the Georgia Department of Education (GaDOE) once per month. GaDOE requires the School District to submit DE-0147 ? Requests for Reimbursement of Monthly Cash Disbursements through the Grants Accounting Online Reporting System to receive program funds. When a DE-0147 request is submitted and approved, the ESSER program funds are typically disbursed to the School District through an electronic payment process the next week. The School District submitted DE-0147 requests to receive a total of $4,407,030 in ESSER program funds from GaDOE for the fiscal year under review. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance Section 200.305(b) state that for ?For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from? the pass-through entity and the disbursement by the non-Federal entity.? In addition, the Uniform Guidance Section 200.302(b)(6) requires that the entity develop written cash management procedures. Condition: Upon testing ESSER program revenues and expenditures recorded on the financial statements, potential deficiencies in the cash management process were identified. Therefore, a review of all cash drawdowns and disbursements related to the ESSER program was performed to determine if any excessive drawdowns were made during the year under review. Excessive drawdown requests totaling $195,559 were identified. Cause: Drawdowns in excess of expenditures were caused by an error made by School District personnel when requesting ESSER funds. These excessive drawdowns were primarily the result of the School District requesting reimbursement for expenditures that had not been incurred by year end. Effect: The School District was not in compliance with the Uniform Guidance and GaDOE guidance. In addition, the School District could potentially accrue an interest liability that would be owed back to the federal government. Furthermore, when the School District cannot meet the requirement to minimize the time elapsing between the transfer of funds and disbursement of those funds, provisions included in the Uniform Guidance allow GaDOE to change the method by which the School District is transferred funds and delay the School District?s receipt of these funds. This may include requirement by GaDOE to submit invoices prior to being reimbursed for ESSER program expenditures. Recommendation: The School District should establish procedures to accurately forecast the cash needs of the ESSER program and minimize the time elapsing between the transfer of funds from GaDOE and the disbursement of such funds by the School District. In addition, these procedures should be documented in writing in accordance with the Uniform Guidance Section 200.302(b)(6). Furthermore, management should develop and implement a monitoring process to ensure that these procedures are followed. Views of Responsible Officials: We concur with this finding.