Findings Citing § 200.305

Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.

Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.

Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.

Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.

Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.

Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.

Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.

Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.

Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.

Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.

Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.

Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.

Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.

Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.

Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.

Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.

Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.

Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.

Federal Funds Received Were Not Disbursed or Refunded Within Required Timeframe(Utah State University)Federal Agency: Department of EducationAssistance Listing Number and Title: VariousFederal Award Number: VariousQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFor one of the two tested advanced cash draws, Utah State University (University) did not disburse or refund $729,728 of $2,154,816 draw amount within required timeframe. 2 CFR 200.305(b) requires that payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury?and the disbursement by the non-Federal entity? 34 CFR 668.162(b)(3) further requires that these advance funds be disbursed within three business days, but the University did not disburse or refund the advanced amount of $729,728 until over a month later. In addition, the advanced fund that the University held after three business days did not meet the excess cash tolerance criteria as stated in 34 CFR 668.166(b) as excess cash exceeded 1% of total fiscal year 2021 draws and was not fully disbursed within the next seven calendar days. Therefore, the University ?must return immediately?any amount of excess cash?? to the U.S. Department of Education (ED) as required by this federal regulation. This issue was the result of University personnel not monitoring advance cash draws to ensure they were disbursed or refunded within the required timeframe. Due to noncompliance with federal regulations, the ED could revoke the University?s permission to request funds on an advance basis. Because the excess cash was either disbursed or refunded to ED before year-end, no costs were questioned.Recommendation:We recommend that the University monitor the amount of advance draws and disburse or refund advance funds within the required timeframe.University?s Response:We agree with the finding.

Assistance Listings number and name: 84.374 Teacher and School Leader Incentive GrantsAward number and year: U374A160041-20, October 1, 2020 through September 30, 2022Federal agency: U.S. Department of EducationCompliance requirement: Cash managementQuestioned costs: $925,524Condition?Contrary to federal regulation, the Maricopa County School Superintendent?s Office overdrew $1,370,113 of program monies for its May 2022 reimbursement request for program expenditures it did not incur, or 18 percent of the program?s total expenditures for the year.Effect?The Office risks having to return the $1,370,113 of program monies for expenditures that it had not incurred and was not eligible to receive, along with any interest it earned exceeding $500, to the federal grantor. However, the Office incurred additional program expenditures of $444,589 during the fiscal year for which it did not request reimbursement because it wanted to first resolve the $1,370,113 overdrawn amount. Therefore, the total questioned costs at fiscal year-end were $925,524, which the Office reported notifying the federal grantor of the error and requesting guidance on how to repay the federal monies. The federal program ended on September 30, 2022, and the Office will need to work with the federal grantor to resolve the overpayment during the grant?s close-out.Cause?The Office?s former Assistant Superintendent incorrectly based the May 2022 drawdown on the wrong time period?July 1, 2019 through May 2020 instead of the time period of July 1, 2021 through May 2022, resulting in a requested drawdown of $1,915,288 rather than the needed drawdown of $545,175?due to an apparent oversight. The Office?s policies and procedures did not require the reviewer to perform a reconciliation of the year?s program expenditures to the drawdown request prior to approving the request for submission to the federal grantor, and the assigned reviewer did not detect the error. Had the Office performed a more careful preparation and detailed review of the reimbursement request, it may have been able to detect and correct the error before submitting the reimbursement request to the federal grantor.Criteria?The Office?s federal award terms and federal Uniform Guidance require the Office to use the reimbursement method to administer the program, whereby the Office is reimbursed with federal program monies only after it spends its own monies for authorized program purposes and requests reimbursement from the federal grantor (2 Code of Federal Regulations [CFR] ?200.305[b][3]). Accordingly, both the Office and County-wide policies and procedures require an independent review and approval of federal program reimbursement requests and reports before submitting them to the grantor. Also, federal regulation requires the County and all its departments administering federal grants to establish and maintain effective internal control over federal awards that provides reasonable assurance that federal programs are being administered in accordance with all applicable laws, regulations, and award terms (2 CFR ?200.303).Recommendations?The Office should develop and implement policies and procedures for preparing and reviewing federal reimbursement requests that require:1. The assigned reimbursement request reviewer to review or reconcile program expenditures recorded on the County?s financial accounting system to the drawdown request before approving the request to be submitted to the federal grantor.2. The Office to continue to work with the federal grantor to repay award amounts exceeding what the Office was eligible to receive, if any such amounts exist during the grant's close-out.The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.

SIGNIFICANT DEFICIENCYFinding Number: 2022-001Prior Year Finding Number: N/ACompliance Requirement: Cash ManagementProgram: Teacher and School Leader Incentive ProgramFederal Assistance Listing Number: 84.374AAward #: S374A200044Award Year: 7/1/2021 ? 6/30/2022Governing Department/Agency: United States Department of EducationCriteria: The Uniform Guidance in 2 CFR section 200.305(b)(3) requires that program costs must be paid by non-federal entity funds before submitting a payment request for reimbursement.Condition: Based on testing performed over cash management, we noted that for all twelve months during the year, management requested funds for an amount that was different and often more than actual expenditures for the given month. Specifically, during November 2021, the grant team noted that the budgeted fringe rates differed from actuals. This was brought to the attention of the finance department who was unable to explain the discrepancy. Rather than requesting reimbursement based on actual expenditures, the team kept track of the discrepancy and requested reimbursement based on the budgeted amounts. Upon investigating further, it was deemed that the difference was due to the grant team miscalculating the fringe benefit due to pre-tax contributions, and therefore, the Organization requested reimbursement for an amount more than what was actually expended.Cause: Although program management has controls in place for the grant analyst to perform a reconciliation between the budgeted amounts and actual expenditures each month prior to requesting for reimbursement, discrepancies noted are not fully investigated prior to requesting funds for reimbursement. In addition, the error occurred during the period of time when the Organization?s CFO had resigned. Once a new CFO was in place, the error was identified and resolved.Effect: Without adequate controls in place to ensure that discrepancies between budget to actual expenditures are being fully investigated and resolved prior to requests for reimbursements being made, non-compliance with cash management requirements could occur and not be detected by management.Questioned Costs ? Known: $7,793.78Related Noncompliance ? NoncomplianceRecommendation: Management should strengthen the Organization?s internal controls to ensure that program staff are timely investigating and resolving all differences noted in the monthly reconciliation and only requesting reimbursement for those costs that have been expended during the month.

Cash Management Criteria or specific requirement: 2 CFR § 200.305 Federal payment stipulates a non-federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. 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. Condition and Context: The Title IIIB funds drawn in advance were not limited to immediate cash requirements. Cause: Due to the improper reconciliation of deferred revenue liability, although the college was drawing for immediate current payments, some of the construction related payments included in the current drawdowns had previously been obligated and included in the computation of the previous year’s expenditures and earned revenue. Effect: The School has drawn down funds above its immediate cash requirements. Questioned costs: None Recommendation The Institution follow controls to properly ensure that funds drawn have been used before drawing additional funds in order to minimize the time between receipt of funds from the granting agency and disbursement of those funds. The institution also needs to compute interest earned on advance funds and remit it to the grantor when required.

Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Cash Management Federal Award Identification Assistance Listing Program Title: Formula Grants for Rural Areas Assistance Listing Program Number: 20.509 Federal Award ID Number and Year: Various Federal Agency: U.S. Department of Transportation Pass-Through Entity: Nebraska Department of Transportation Criteria The Organization must establish and maintain effective internal control over the Federal award that provides reasonable assurance that they are managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award (2 CFR 200.303). Costs must be adequately documented. (2 CFR 200.403(g)). Costs must be paid for prior to the date of the reimbursement request. (2 CFR 200.305(b)(3)). Condition The Organization lacked adequate documentation to support: - That certain expenditures followed an approval process before being paid. - That certain expenditures were for allowable activities and in accordance with allowable cost principles. The Organization requested reimbursement for expenses that had not yet been paid. Repeat Finding No. Cause Procedures within the Organization were inadequate to ensure that expenditures follow a review and approval process prior to being paid, that costs were in accordance with Federal requirements and that only costs which had been paid for were requested for reimbursement. Effect or Potential Effect Increased potential for errors or misuse of funds. Questioned Costs Known $35,806 Statistical Sample No. Context During the fiscal year, the Organization requested a monthly reimbursement from the pass-through entity. Auditor selected three of these monthly reimbursement requests (September 2021, May 2022, and June 2022) for testing, reviewing all non-payroll-related expenses, resulting in testing approximately 90 different line items composing many more individual transactions. Within this sample, auditor noted: - Multiple instances where no documentation existed to support a system of internal control whereby expenditures were approved by a competent individual prior to their being paid. - Multiple instances where documentation provided did not include sufficient detail to determine if products and/or services provided meet the definition of allowable activity, resulting in questioned costs of $2,921. - One expenditure for which reimbursement was requested in May 2022 and again in June 2022 amounting to $1,283 (questioned cost amount included in previous point). - For June 2022, an inability to crosswalk between the Organization’s internal fuel summary report and the related vendor statements, resulting in questioned costs of $32,885. Additionally, we noted both character and line transposition errors between the fuel summary report and the reimbursement request. Similarly, auditor was unable to obtain evidence that fuel expenditures were paid prior to the Organization requesting reimbursement. - Multiple instances of expenditure misclassification in violation of the invoicing and documentation guidelines issued by the pass-through entity, resulting in no additional questioned costs. Recommendation We recommend the Organization establish a system of internal control consisting of policies and procedures whereby all expenditures are properly explained with supporting documentation and are reviewed and approved prior to payment. Additionally, that only those expenditures which have been paid for are requested for reimbursement. Views of Responsible Officials See Corrective Action Plan, below.

Cash Management Federal Program Name Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria According to the 2 CFR 200.305(b) non-federal entities must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Also, CRRSAA HEERF II and ARP HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Institutional Aid Portion, (a)(2), and (a)(3) funds should be disbursed within 3 calendar days of the drawdown from G5. Condition During our examination, we found the following instances on which the Institution did not disbursed funds in an expedite matter: Fund Instances Average of days late 84.425F 106 7 84.425L 5 31 Cause The delay in disbursements responds to several situations: remote work, lack of banking or information from suppliers, multiplicity of tasks under the responsibility of the Administration and Operations Director, which affected the dates of sending the payments. Effect As a result of this condition, the USDE may issue warnings and/or impose penalties to the Institution. Questioned Cost None Context During our examination, we noted one hundred six (106) instances from one hundred thirty-six (136) of the HEERF Institutional portion and five (5) instances from five (5) from Minority, on which the Institution did not disbursed funds within 3 calendar days of the drawdown from G5. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation The management of the Institution should reinforce its cash management procedures and internal controls to ensure the disbursement of funds in the required time frame after the drawdowns from G5. Views of Responsible Officials of the Auditee and Planned Corrective Actions The management of the Institution agrees with this finding. Please refer to the corrective action plan on pages 22-26.

Cash Management Federal Program Name Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria According to the 2 CFR 200.305(b) non-federal entities must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Also, CRRSAA HEERF II and ARP HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Institutional Aid Portion, (a)(2), and (a)(3) funds should be disbursed within 3 calendar days of the drawdown from G5. Condition During our examination, we found the following instances on which the Institution did not disbursed funds in an expedite matter: Fund Instances Average of days late 84.425F 106 7 84.425L 5 31 Cause The delay in disbursements responds to several situations: remote work, lack of banking or information from suppliers, multiplicity of tasks under the responsibility of the Administration and Operations Director, which affected the dates of sending the payments. Effect As a result of this condition, the USDE may issue warnings and/or impose penalties to the Institution. Questioned Cost None Context During our examination, we noted one hundred six (106) instances from one hundred thirty-six (136) of the HEERF Institutional portion and five (5) instances from five (5) from Minority, on which the Institution did not disbursed funds within 3 calendar days of the drawdown from G5. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation The management of the Institution should reinforce its cash management procedures and internal controls to ensure the disbursement of funds in the required time frame after the drawdowns from G5. Views of Responsible Officials of the Auditee and Planned Corrective Actions The management of the Institution agrees with this finding. Please refer to the corrective action plan on pages 22-26.

FA 2022-003 Improve Controls over Cash Management Compliance Requirement: Cash Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: 84.010 –Title I Grants to Local Educational Agencies Federal Award Numbers: SO10A200010 (Year: 2021), S010A210010-21A (Year: 2022) Questioned Costs: None Identified 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 – 84.425W – American Rescue Plan Elementary and Secondary School Emergency Relief Fund – Homeless Children and Youth Federal Award Numbers: S425D210012 (Year: 2021), S425W210011 (Year: 2021) Questioned Costs: None Identified Repeat of Prior Year Findings: FA 2021-001, FA 2020-001, FA 2019-001, FA 2018-001, FA 2017-002, FA 2016-001, FA 2015-002, FA 2014-003 Description: The School District made cash drawdowns in excess of immediate cash needs for the Title I Grants to Local Educational Agencies and Elementary and Secondary School Emergency Relief Fund programs. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Background Information: The School District may request Title I Grants to Local Educational Agencies (Title I) and 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 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 $390,112 in Title I funds and a total of $498,996 in ESSER funds from GaDOE during 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 non-Federal entities other than states, payment methods must minimize the time elapsing between the transfer of funds… the pass-through entity and the disbursement by the non-Federal entity.” In addition, the Uniform Guidance Section 200.302(b)(6) requires the entity to develop written cash management procedures. Further, as noted in the Uniform Guidance Section 200.511, management is responsible for implementing reported corrective action to findings from previous audits. Condition: A review of all cash drawdowns and disbursements related to the Title I and ESSER programs was performed to determine if any excessive cash balances were maintained during the fiscal year under review. Cash balances in excess of program materiality were maintained for the Title I program for 365 days and the ESSER program for 121 days. Additionally, it was noted that the School District did not have appropriate internal controls in place over the cash drawdown process. Cause: In discussing this issue with the School District, they indicated that the lack of review of federal grants resulted in excess cash drawdown requests. 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 a requirement by GaDOE to submit invoices prior to being reimbursed for program expenditures. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Recommendation: The School District should establish procedures to accurately forecast the cash needs of the Title I and ESSER programs 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.

FA 2022-003 Improve Controls over Cash Management Compliance Requirement: Cash Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: 84.010 –Title I Grants to Local Educational Agencies Federal Award Numbers: SO10A200010 (Year: 2021), S010A210010-21A (Year: 2022) Questioned Costs: None Identified 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 – 84.425W – American Rescue Plan Elementary and Secondary School Emergency Relief Fund – Homeless Children and Youth Federal Award Numbers: S425D210012 (Year: 2021), S425W210011 (Year: 2021) Questioned Costs: None Identified Repeat of Prior Year Findings: FA 2021-001, FA 2020-001, FA 2019-001, FA 2018-001, FA 2017-002, FA 2016-001, FA 2015-002, FA 2014-003 Description: The School District made cash drawdowns in excess of immediate cash needs for the Title I Grants to Local Educational Agencies and Elementary and Secondary School Emergency Relief Fund programs. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Background Information: The School District may request Title I Grants to Local Educational Agencies (Title I) and 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 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 $390,112 in Title I funds and a total of $498,996 in ESSER funds from GaDOE during 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 non-Federal entities other than states, payment methods must minimize the time elapsing between the transfer of funds… the pass-through entity and the disbursement by the non-Federal entity.” In addition, the Uniform Guidance Section 200.302(b)(6) requires the entity to develop written cash management procedures. Further, as noted in the Uniform Guidance Section 200.511, management is responsible for implementing reported corrective action to findings from previous audits. Condition: A review of all cash drawdowns and disbursements related to the Title I and ESSER programs was performed to determine if any excessive cash balances were maintained during the fiscal year under review. Cash balances in excess of program materiality were maintained for the Title I program for 365 days and the ESSER program for 121 days. Additionally, it was noted that the School District did not have appropriate internal controls in place over the cash drawdown process. Cause: In discussing this issue with the School District, they indicated that the lack of review of federal grants resulted in excess cash drawdown requests. 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 a requirement by GaDOE to submit invoices prior to being reimbursed for program expenditures. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Recommendation: The School District should establish procedures to accurately forecast the cash needs of the Title I and ESSER programs 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.

FA 2022-003 Improve Controls over Cash Management Compliance Requirement: Cash Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: 84.010 –Title I Grants to Local Educational Agencies Federal Award Numbers: SO10A200010 (Year: 2021), S010A210010-21A (Year: 2022) Questioned Costs: None Identified 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 – 84.425W – American Rescue Plan Elementary and Secondary School Emergency Relief Fund – Homeless Children and Youth Federal Award Numbers: S425D210012 (Year: 2021), S425W210011 (Year: 2021) Questioned Costs: None Identified Repeat of Prior Year Findings: FA 2021-001, FA 2020-001, FA 2019-001, FA 2018-001, FA 2017-002, FA 2016-001, FA 2015-002, FA 2014-003 Description: The School District made cash drawdowns in excess of immediate cash needs for the Title I Grants to Local Educational Agencies and Elementary and Secondary School Emergency Relief Fund programs. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Background Information: The School District may request Title I Grants to Local Educational Agencies (Title I) and 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 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 $390,112 in Title I funds and a total of $498,996 in ESSER funds from GaDOE during 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 non-Federal entities other than states, payment methods must minimize the time elapsing between the transfer of funds… the pass-through entity and the disbursement by the non-Federal entity.” In addition, the Uniform Guidance Section 200.302(b)(6) requires the entity to develop written cash management procedures. Further, as noted in the Uniform Guidance Section 200.511, management is responsible for implementing reported corrective action to findings from previous audits. Condition: A review of all cash drawdowns and disbursements related to the Title I and ESSER programs was performed to determine if any excessive cash balances were maintained during the fiscal year under review. Cash balances in excess of program materiality were maintained for the Title I program for 365 days and the ESSER program for 121 days. Additionally, it was noted that the School District did not have appropriate internal controls in place over the cash drawdown process. Cause: In discussing this issue with the School District, they indicated that the lack of review of federal grants resulted in excess cash drawdown requests. 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 a requirement by GaDOE to submit invoices prior to being reimbursed for program expenditures. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Recommendation: The School District should establish procedures to accurately forecast the cash needs of the Title I and ESSER programs 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.

FA 2022-003 Improve Controls over Cash Management Compliance Requirement: Cash Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: 84.010 –Title I Grants to Local Educational Agencies Federal Award Numbers: SO10A200010 (Year: 2021), S010A210010-21A (Year: 2022) Questioned Costs: None Identified 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 – 84.425W – American Rescue Plan Elementary and Secondary School Emergency Relief Fund – Homeless Children and Youth Federal Award Numbers: S425D210012 (Year: 2021), S425W210011 (Year: 2021) Questioned Costs: None Identified Repeat of Prior Year Findings: FA 2021-001, FA 2020-001, FA 2019-001, FA 2018-001, FA 2017-002, FA 2016-001, FA 2015-002, FA 2014-003 Description: The School District made cash drawdowns in excess of immediate cash needs for the Title I Grants to Local Educational Agencies and Elementary and Secondary School Emergency Relief Fund programs. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Background Information: The School District may request Title I Grants to Local Educational Agencies (Title I) and 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 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 $390,112 in Title I funds and a total of $498,996 in ESSER funds from GaDOE during 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 non-Federal entities other than states, payment methods must minimize the time elapsing between the transfer of funds… the pass-through entity and the disbursement by the non-Federal entity.” In addition, the Uniform Guidance Section 200.302(b)(6) requires the entity to develop written cash management procedures. Further, as noted in the Uniform Guidance Section 200.511, management is responsible for implementing reported corrective action to findings from previous audits. Condition: A review of all cash drawdowns and disbursements related to the Title I and ESSER programs was performed to determine if any excessive cash balances were maintained during the fiscal year under review. Cash balances in excess of program materiality were maintained for the Title I program for 365 days and the ESSER program for 121 days. Additionally, it was noted that the School District did not have appropriate internal controls in place over the cash drawdown process. Cause: In discussing this issue with the School District, they indicated that the lack of review of federal grants resulted in excess cash drawdown requests. 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 a requirement by GaDOE to submit invoices prior to being reimbursed for program expenditures. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Recommendation: The School District should establish procedures to accurately forecast the cash needs of the Title I and ESSER programs 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.

Finding Reference Number: SA 2022-005 Cash Management – Drawdown of Grant Funds In Advance of Disbursement AL Number: 14.218 Assistance Listing Title: CDBG - Entitlement Grants Cluster – Community Development Block Grants/Entitlement Grants COVID-19 - Community Development Block Grants/Entitlement Grants-CV Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-14-MC-06-0037, B-15-MC-06-0037, B-16-MC-06-0037, B-17-MC-06-0037, B-18-MC-06-0037, B-19-MC-06-0037, B-20-MC-06-0037, B-20-MW-06-0037, B-21-MC-06-0037 Criteria: Under 2 CFR 200.305, a CDBG grantee is prohibited from drawing funds down from its line of credit in advance of cash needs, 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. The general rule is that CDBG funds must be used within three business days they are drawn down. Condition: We selected thirteen disbursements related to projects, subgrants and administrative expenditures and noted one disbursement on September 30, 2021 was included in a reimbursement request on September 9, 2021 and payment was received from HUD on September 13, 2021, which is seventeen days prior to payment to the vendor. Effect: Drawing down funds in advance and not disbursing the funds in three days or less 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. Cause: We understand the disbursement was requested prior to payment due to staff oversight. 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. In addition, the City should determine whether the interest earned on the grant funds advanced needs 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: SA 2022-005 Cash Management – Drawdown of Grant Funds In Advance of Disbursement AL Number: 14.218 Assistance Listing Title: CDBG - Entitlement Grants Cluster – Community Development Block Grants/Entitlement Grants COVID-19 - Community Development Block Grants/Entitlement Grants-CV Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-14-MC-06-0037, B-15-MC-06-0037, B-16-MC-06-0037, B-17-MC-06-0037, B-18-MC-06-0037, B-19-MC-06-0037, B-20-MC-06-0037, B-20-MW-06-0037, B-21-MC-06-0037 Criteria: Under 2 CFR 200.305, a CDBG grantee is prohibited from drawing funds down from its line of credit in advance of cash needs, 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. The general rule is that CDBG funds must be used within three business days they are drawn down. Condition: We selected thirteen disbursements related to projects, subgrants and administrative expenditures and noted one disbursement on September 30, 2021 was included in a reimbursement request on September 9, 2021 and payment was received from HUD on September 13, 2021, which is seventeen days prior to payment to the vendor. Effect: Drawing down funds in advance and not disbursing the funds in three days or less 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. Cause: We understand the disbursement was requested prior to payment due to staff oversight. 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. In addition, the City should determine whether the interest earned on the grant funds advanced needs to be returned to the grantor. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.

2022-001 ? Housing Quality Standards Inspections Federal Program Information: U.S. Department of Housing and Urban Development - Housing Choice Voucher: AL - 14.871 Section 8 Housing Choice Voucher 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?s inspections were being completed but if there was a failure, re-inspections were not completed as required within the 30-day period. Cause: The Unit does not have the necessary internal controls over compliance. Effect: The Unit is not effectively reinspecting units. Identification of Questioned Costs: None identified. Context: The population of 40 tenants were examine and there was 14 that had a failed inspection with no reinspection. 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 reimbursements requests are submitted on a timely basis. Views of Responsible Officials and Corrective Action Plan: Catherine Bowler, Director of Finance and Operations is the responsible Official and please see the Corrective Action Plan issued by the Laconia Housing and Redevelopment Authority.

2022-001 ? Housing Quality Standards Inspections Federal Program Information: U.S. Department of Housing and Urban Development - Housing Choice Voucher: AL - 14.871 Section 8 Housing Choice Voucher 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?s inspections were being completed but if there was a failure, re-inspections were not completed as required within the 30-day period. Cause: The Unit does not have the necessary internal controls over compliance. Effect: The Unit is not effectively reinspecting units. Identification of Questioned Costs: None identified. Context: The population of 40 tenants were examine and there was 14 that had a failed inspection with no reinspection. 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 reimbursements requests are submitted on a timely basis. Views of Responsible Officials and Corrective Action Plan: Catherine Bowler, Director of Finance and Operations is the responsible Official and please see the Corrective Action Plan issued by the Laconia Housing and Redevelopment Authority.

Federal Program Information: Funding Agency: U.S Department of Health and Human Services FALN: 93.926 Federal Award Identification Number: 5 H49MC00119‐21‐00 / 6 H49MC00119‐20‐01 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2020‐2024 Criteria: Under 2 CFR Section 200.303(a), non‐federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally regulations require the reimbursement payment method may be used on a Federal award for activities as specified in 2 CFR section 200.305(b)(3), program costs must be paid by non‐ Federal entity funds before submitting a payment request (2 CFR section 200.305(b)(3)), i.e., the non‐ Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass‐through entity. Condition: The Organization has a policy which in includes thee Fiscal/Grant Manager and/or the CEO review all drawdown requests to ensure costs are paid before reimbursement is requested. However of the sixteen (16) drawdown requests that we tested, there was no evidence of review and approval for payment. Effect: Management possibly did not expend funds in accordance with the federal award due to lack of evidence of oversight/review of drawdowns and after reimbursable expenses have been incurred. Cause: Management did not document evidence of review and approval of drawdown requests. This was due in part to lack of oversight. Also there were several changes in personnel within the accounting area and overall limited number of personnel for certain functions and lack of board oversight. Questioned costs: None Recommendation: We recommend that internal controls be strengthened and processes implemented to ensure all draw down requests are reviewed and approved to ensure costs were accurately reported and paid before requesting reimbursement.

Federal Program Information: Funding Agency: U.S Department of Health and Human Services FALN: 93.926 Federal Award Identification Number: 5 H49MC00119‐21‐00 / 6 H49MC00119‐20‐01 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2020‐2024 Criteria: Under 2 CFR Section 200.303(a), non‐federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally regulations require the reimbursement payment method may be used on a Federal award for activities as specified in 2 CFR section 200.305(b)(3), program costs must be paid by non‐ Federal entity funds before submitting a payment request (2 CFR section 200.305(b)(3)), i.e., the non‐ Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass‐through entity. Condition: The Organization has a policy which in includes thee Fiscal/Grant Manager and/or the CEO review all drawdown requests to ensure costs are paid before reimbursement is requested. However of the sixteen (16) drawdown requests that we tested, there was no evidence of review and approval for payment. Effect: Management possibly did not expend funds in accordance with the federal award due to lack of evidence of oversight/review of drawdowns and after reimbursable expenses have been incurred. Cause: Management did not document evidence of review and approval of drawdown requests. This was due in part to lack of oversight. Also there were several changes in personnel within the accounting area and overall limited number of personnel for certain functions and lack of board oversight. Questioned costs: None Recommendation: We recommend that internal controls be strengthened and processes implemented to ensure all draw down requests are reviewed and approved to ensure costs were accurately reported and paid before requesting reimbursement.

Finding 2021-010 Program: Office for Coastal Management Federal Financial Assistance Listing: 11.473 Federal Grantor: U.S. Department of Commerce Passed-through: National Fish and Wildlife Foundation Award No. and Year: 0318.19.070225 (2020) Compliance Requirements: Cash Management / Subrecipient Monitoring Type of Finding: Material Non-Compliance/Material Weakness Criteria: 2 CFR 200.305 – establishes that payment methods must minimize the time elapsing between the transfer of funds from the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer or other means. The non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions. Whenever possible, advance payments must be consolidated to cover anticipated cash needs for all Federal awards made by the Federal awarding agency to the recipient. Non-Federal entities must be authorized to submit requests for advance payments and reimbursements at least monthly when electronic fund transfers are not used, and as often as they like when electronic transfers are used, in accordance with the provisions of the Electronic Fund Transfer Act. Reimbursement is the preferred method when the requirements above cannot be met. Condition: We identified the following: • For amounts advanced from granting agency to CFSC, we noted $559,110 of advances were not expended timely. The expenditures were incurred (or disbursed to subrecipients) between 21 and 50 days after advanced funds were received by CFSC. • For $733,637 of pass-through payments paid by CFSC, the timing of payment to subrecipients didn’t follow a reimbursement method. The agreements allowed for funds to be advanced, with a true-up required quarterly. Funds were frequently remitted to subrecipient more than 30 days in advance of the expenditure being incurred by the subrecipient. o For 5 transactions of 9 payments to subrecipients tested, funds were provided to subrecipients prior to eligible expenditures being incurred by the subrecipient. The number of days between date funds were advanced to subrecipient, and when an eligible expenditures were completely incurred by subrecipients were as follows:  8 days - $191,830 • Time between CFSC receipt of funds (from granting agency) and subsequent remittance to subrecipient was 59 days  34 days - $195,929 • Time between CFSC receipt of funds and subsequent remittance to subrecipient was 44 days  51 days - $100,000 • Time between CFSC receipt of funds and subsequent remittance to subrecipient was 59 days  79 days - $50,000 • time between CFSC receipt of funds and subsequent remittance to subrecipient was 107 days  86 days - $195,929 • time between CFSC receipt of funds and subsequent remittance to subrecipient was 121 days Questioned Costs: Advances received of $559,110 by CFSC, and subrecipient advances paid of $733,637, as detailed under the Condition above. Context/Sampling: Sampling was not used. For advances received, we tested 6 of 6 advances. We selected all three subrecipients for testing. The condition noted above was identified during our procedures over CFSC’s subrecipient monitoring provisions. Repeat Finding from Prior Year: Yes –2020-001 Effect: CFSC did not minimize the time elapsing between receiving advances and incurring eligible expenditures, including the timing of the subrecipients incurring the related eligible expenditures. Cause: CFSC’s procedures did not consistently ensure that subrecipient agreements followed the uniform guidance requirements related to advances, nor did their policies allow for appropriately minimizing the time elapsing on advances received. Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that cash management policies surrounding advances are in line with grant agreements and uniform guidance. Views of Responsible Officials and Planned Corrective Actions: See Separate Corrective Action Plan.

Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure & Integrative Activities AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC- 1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099 (09/01/2020 – 08/31/2021) Pass Through Entity: Utah State University & University of Cincinnati MW2021-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF EXPENDITURES Material Weakness Criteria CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the management of cash drawdowns and disbursements of federal funds. Federal funds should be disbursed in a timely manner for allowable costs that have been incurred. Cash advances must meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation. Condition CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation which details the requirements for advance fundings. During 2021, CUAHSI had advance drawdowns totaling $1,172,645 from the NSF. Of this amount, CUAHSI incurred $1,049,681 in eligible expenses for the year ended December 31, 2021. This resulted in $122,964 in excess federal advances as of year-end. The draw downs in excess of revenue recognized during the year ended December 31, 2021 are reported as part of deferred revenue in the accompanying Statement of Financial Position. Cause & Context CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter VIII.C.3 of the grant agreement. Effect Drawing down funds in advance of incurring eligible expenses could lead to non-compliance with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need to repay the funds, potential financial penalties, or disqualification from future federal funding. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2020-008. Recommendation The auditor recommends that CUAHSI develops and implements controls over policies consistent with 2 CFR 200.35. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure & Integrative Activities AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC- 1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099 (09/01/2020 – 08/31/2021) Pass Through Entity: Utah State University & University of Cincinnati MW2021-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF EXPENDITURES Material Weakness Criteria CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the management of cash drawdowns and disbursements of federal funds. Federal funds should be disbursed in a timely manner for allowable costs that have been incurred. Cash advances must meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation. Condition CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation which details the requirements for advance fundings. During 2021, CUAHSI had advance drawdowns totaling $1,172,645 from the NSF. Of this amount, CUAHSI incurred $1,049,681 in eligible expenses for the year ended December 31, 2021. This resulted in $122,964 in excess federal advances as of year-end. The draw downs in excess of revenue recognized during the year ended December 31, 2021 are reported as part of deferred revenue in the accompanying Statement of Financial Position. Cause & Context CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter VIII.C.3 of the grant agreement. Effect Drawing down funds in advance of incurring eligible expenses could lead to non-compliance with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need to repay the funds, potential financial penalties, or disqualification from future federal funding. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2020-008. Recommendation The auditor recommends that CUAHSI develops and implements controls over policies consistent with 2 CFR 200.35. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure & Integrative Activities AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC- 1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099 (09/01/2020 – 08/31/2021) Pass Through Entity: Utah State University & University of Cincinnati MW2021-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF EXPENDITURES Material Weakness Criteria CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the management of cash drawdowns and disbursements of federal funds. Federal funds should be disbursed in a timely manner for allowable costs that have been incurred. Cash advances must meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation. Condition CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation which details the requirements for advance fundings. During 2021, CUAHSI had advance drawdowns totaling $1,172,645 from the NSF. Of this amount, CUAHSI incurred $1,049,681 in eligible expenses for the year ended December 31, 2021. This resulted in $122,964 in excess federal advances as of year-end. The draw downs in excess of revenue recognized during the year ended December 31, 2021 are reported as part of deferred revenue in the accompanying Statement of Financial Position. Cause & Context CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter VIII.C.3 of the grant agreement. Effect Drawing down funds in advance of incurring eligible expenses could lead to non-compliance with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need to repay the funds, potential financial penalties, or disqualification from future federal funding. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2020-008. Recommendation The auditor recommends that CUAHSI develops and implements controls over policies consistent with 2 CFR 200.35. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure & Integrative Activities AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC- 1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099 (09/01/2020 – 08/31/2021) Pass Through Entity: Utah State University & University of Cincinnati MW2021-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF EXPENDITURES Material Weakness Criteria CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the management of cash drawdowns and disbursements of federal funds. Federal funds should be disbursed in a timely manner for allowable costs that have been incurred. Cash advances must meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation. Condition CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation which details the requirements for advance fundings. During 2021, CUAHSI had advance drawdowns totaling $1,172,645 from the NSF. Of this amount, CUAHSI incurred $1,049,681 in eligible expenses for the year ended December 31, 2021. This resulted in $122,964 in excess federal advances as of year-end. The draw downs in excess of revenue recognized during the year ended December 31, 2021 are reported as part of deferred revenue in the accompanying Statement of Financial Position. Cause & Context CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter VIII.C.3 of the grant agreement. Effect Drawing down funds in advance of incurring eligible expenses could lead to non-compliance with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need to repay the funds, potential financial penalties, or disqualification from future federal funding. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2020-008. Recommendation The auditor recommends that CUAHSI develops and implements controls over policies consistent with 2 CFR 200.35. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure & Integrative Activities AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC- 1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099 (09/01/2020 – 08/31/2021) Pass Through Entity: Utah State University & University of Cincinnati MW2021-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF EXPENDITURES Material Weakness Criteria CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the management of cash drawdowns and disbursements of federal funds. Federal funds should be disbursed in a timely manner for allowable costs that have been incurred. Cash advances must meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation. Condition CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation which details the requirements for advance fundings. During 2021, CUAHSI had advance drawdowns totaling $1,172,645 from the NSF. Of this amount, CUAHSI incurred $1,049,681 in eligible expenses for the year ended December 31, 2021. This resulted in $122,964 in excess federal advances as of year-end. The draw downs in excess of revenue recognized during the year ended December 31, 2021 are reported as part of deferred revenue in the accompanying Statement of Financial Position. Cause & Context CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter VIII.C.3 of the grant agreement. Effect Drawing down funds in advance of incurring eligible expenses could lead to non-compliance with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need to repay the funds, potential financial penalties, or disqualification from future federal funding. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2020-008. Recommendation The auditor recommends that CUAHSI develops and implements controls over policies consistent with 2 CFR 200.35. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

1. Provide staff training on proper cash management and documentation standards under 2 CFR § 200.305.

1. Provide staff training on proper cash management and documentation standards under 2 CFR § 200.305.

1. Provide staff training on proper cash management and documentation standards under 2 CFR § 200.305.

2021-008 – CASH MANAGEMENT Federal Program Information: Federal Agency Federal Program Name Assistance Listing Number Grant Award(s) Unique Identifier(s) Department of Defense Basic Scientific Research 12.431 W15QKN-14-1-0001 W15QKN-20-1-1000 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award.” These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.305 requires that 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. The non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions. Condition: The National Center for the Advancement of STEM Education, Inc. drew down 49 payment advances totaling $5,870,068 from the basic scientific research grants for the fiscal year ended December 31, 2021. Of this amount, $1,031,698 was returned to the grantor. However, there was a lack of adequate documentation which demonstrated amounts advanced were expended and/or returned in a timely fashion. Questioned Costs: Not applicable. SECTION III – FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (Continued) 2021-008 – CASH MANAGEMENT (Continued) Federal Program Information: Federal Agency Federal Program Name Assistance Listing Number Grant Award(s) Unique Identifier(s) Department of Defense Basic Scientific Research 12.431 W15QKN-14-1-0001 W15QKN-20-1-1000 Context: The total amount of advances received during the year were $5,870,068. Expenditures of the federal award were $6,477,348 for the fiscal year. Cause: Internal controls and procedures related to the cash management were not effectively designed or performed. Effect: The National Center for the Advancement of STEM Education, Inc. did not comply with the cash management compliance requirement. Recommendation: Management should establish proper policies and procedures which ensure compliance with federal guidelines. Views of Responsible Officials: Management concurs with the finding and has developed a plan to correct the finding.

Federal Program Information: Funding Agency: U.S Department of Health and Human Services FALN: 93.926 Federal Award Identification Number: 5 H49MC00119‐21‐00 / 6 H49MC00119‐20‐01 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2020‐2024 Criteria: Under 2 CFR Section 200.303(a), non‐federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally regulations require the reimbursement payment method may be used on a Federal award for activities as specified in 2 CFR section 200.305(b)(3), program costs must be paid by non‐ Federal entity funds before submitting a payment request (2 CFR section 200.305(b)(3)), i.e., the non‐ Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass‐through entity. Condition: The Organization has a policy which in includes thee Fiscal/Grant Manager and/or the CEO review all drawdown requests to ensure costs are paid before reimbursement is requested. However of the sixteen (16) drawdown requests that we tested, there was no evidence of review and approval for payment. Effect: Management possibly did not expend funds in accordance with the federal award due to lack of evidence of oversight/review of drawdowns and after reimbursable expenses have been incurred. Cause: Management did not document evidence of review and approval of drawdown requests. This was due in part to lack of oversight. Also there were several changes in personnel within the accounting area and overall limited number of personnel for certain functions and lack of board oversight. Questioned costs: None Recommendation: We recommend that internal controls be strengthened and processes implemented to ensure all draw down requests are reviewed and approved to ensure costs were accurately reported and paid before requesting reimbursement.

Federal Program Information: Funding Agency: U.S Department of Health and Human Services FALN: 93.926 Federal Award Identification Number: 5 H49MC00119‐21‐00 / 6 H49MC00119‐20‐01 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2020‐2024 Criteria: Under 2 CFR Section 200.303(a), non‐federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally regulations require the reimbursement payment method may be used on a Federal award for activities as specified in 2 CFR section 200.305(b)(3), program costs must be paid by non‐ Federal entity funds before submitting a payment request (2 CFR section 200.305(b)(3)), i.e., the non‐ Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass‐through entity. Condition: The Organization has a policy which in includes thee Fiscal/Grant Manager and/or the CEO review all drawdown requests to ensure costs are paid before reimbursement is requested. However of the sixteen (16) drawdown requests that we tested, there was no evidence of review and approval for payment. Effect: Management possibly did not expend funds in accordance with the federal award due to lack of evidence of oversight/review of drawdowns and after reimbursable expenses have been incurred. Cause: Management did not document evidence of review and approval of drawdown requests. This was due in part to lack of oversight. Also there were several changes in personnel within the accounting area and overall limited number of personnel for certain functions and lack of board oversight. Questioned costs: None Recommendation: We recommend that internal controls be strengthened and processes implemented to ensure all draw down requests are reviewed and approved to ensure costs were accurately reported and paid before requesting reimbursement.

Finding 2021-010 Program: Office for Coastal Management Federal Financial Assistance Listing: 11.473 Federal Grantor: U.S. Department of Commerce Passed-through: National Fish and Wildlife Foundation Award No. and Year: 0318.19.070225 (2020) Compliance Requirements: Cash Management / Subrecipient Monitoring Type of Finding: Material Non-Compliance/Material Weakness Criteria: 2 CFR 200.305 – establishes that payment methods must minimize the time elapsing between the transfer of funds from the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer or other means. The non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions. Whenever possible, advance payments must be consolidated to cover anticipated cash needs for all Federal awards made by the Federal awarding agency to the recipient. Non-Federal entities must be authorized to submit requests for advance payments and reimbursements at least monthly when electronic fund transfers are not used, and as often as they like when electronic transfers are used, in accordance with the provisions of the Electronic Fund Transfer Act. Reimbursement is the preferred method when the requirements above cannot be met. Condition: We identified the following: • For amounts advanced from granting agency to CFSC, we noted $559,110 of advances were not expended timely. The expenditures were incurred (or disbursed to subrecipients) between 21 and 50 days after advanced funds were received by CFSC. • For $733,637 of pass-through payments paid by CFSC, the timing of payment to subrecipients didn’t follow a reimbursement method. The agreements allowed for funds to be advanced, with a true-up required quarterly. Funds were frequently remitted to subrecipient more than 30 days in advance of the expenditure being incurred by the subrecipient. o For 5 transactions of 9 payments to subrecipients tested, funds were provided to subrecipients prior to eligible expenditures being incurred by the subrecipient. The number of days between date funds were advanced to subrecipient, and when an eligible expenditures were completely incurred by subrecipients were as follows:  8 days - $191,830 • Time between CFSC receipt of funds (from granting agency) and subsequent remittance to subrecipient was 59 days  34 days - $195,929 • Time between CFSC receipt of funds and subsequent remittance to subrecipient was 44 days  51 days - $100,000 • Time between CFSC receipt of funds and subsequent remittance to subrecipient was 59 days  79 days - $50,000 • time between CFSC receipt of funds and subsequent remittance to subrecipient was 107 days  86 days - $195,929 • time between CFSC receipt of funds and subsequent remittance to subrecipient was 121 days Questioned Costs: Advances received of $559,110 by CFSC, and subrecipient advances paid of $733,637, as detailed under the Condition above. Context/Sampling: Sampling was not used. For advances received, we tested 6 of 6 advances. We selected all three subrecipients for testing. The condition noted above was identified during our procedures over CFSC’s subrecipient monitoring provisions. Repeat Finding from Prior Year: Yes –2020-001 Effect: CFSC did not minimize the time elapsing between receiving advances and incurring eligible expenditures, including the timing of the subrecipients incurring the related eligible expenditures. Cause: CFSC’s procedures did not consistently ensure that subrecipient agreements followed the uniform guidance requirements related to advances, nor did their policies allow for appropriately minimizing the time elapsing on advances received. Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that cash management policies surrounding advances are in line with grant agreements and uniform guidance. Views of Responsible Officials and Planned Corrective Actions: See Separate Corrective Action Plan.

Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure & Integrative Activities AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC- 1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099 (09/01/2020 – 08/31/2021) Pass Through Entity: Utah State University & University of Cincinnati MW2021-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF EXPENDITURES Material Weakness Criteria CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the management of cash drawdowns and disbursements of federal funds. Federal funds should be disbursed in a timely manner for allowable costs that have been incurred. Cash advances must meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation. Condition CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation which details the requirements for advance fundings. During 2021, CUAHSI had advance drawdowns totaling $1,172,645 from the NSF. Of this amount, CUAHSI incurred $1,049,681 in eligible expenses for the year ended December 31, 2021. This resulted in $122,964 in excess federal advances as of year-end. The draw downs in excess of revenue recognized during the year ended December 31, 2021 are reported as part of deferred revenue in the accompanying Statement of Financial Position. Cause & Context CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter VIII.C.3 of the grant agreement. Effect Drawing down funds in advance of incurring eligible expenses could lead to non-compliance with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need to repay the funds, potential financial penalties, or disqualification from future federal funding. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2020-008. Recommendation The auditor recommends that CUAHSI develops and implements controls over policies consistent with 2 CFR 200.35. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.

Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering, Office of Cyber Infrastructure & Integrative Activities AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC- 1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654 (05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099 (09/01/2020 – 08/31/2021) Pass Through Entity: Utah State University & University of Cincinnati MW2021-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF EXPENDITURES Material Weakness Criteria CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the management of cash drawdowns and disbursements of federal funds. Federal funds should be disbursed in a timely manner for allowable costs that have been incurred. Cash advances must meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation. Condition CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation which details the requirements for advance fundings. During 2021, CUAHSI had advance drawdowns totaling $1,172,645 from the NSF. Of this amount, CUAHSI incurred $1,049,681 in eligible expenses for the year ended December 31, 2021. This resulted in $122,964 in excess federal advances as of year-end. The draw downs in excess of revenue recognized during the year ended December 31, 2021 are reported as part of deferred revenue in the accompanying Statement of Financial Position. Cause & Context CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter VIII.C.3 of the grant agreement. Effect Drawing down funds in advance of incurring eligible expenses could lead to non-compliance with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need to repay the funds, potential financial penalties, or disqualification from future federal funding. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2020-008. Recommendation The auditor recommends that CUAHSI develops and implements controls over policies consistent with 2 CFR 200.35. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.