Finding 2020-007 Lack of Internal Control Over Cash Management Federal Agencies: U.S. Department of the Treasury Federal Programs: Coronavirus Relief Fund CFDA Numbers: 21.019 Award Number: SLT0591/0845/1405 Award Year: 2020 Type of Finding: Material weakness in internal control over compliance and material noncompliance. Criteria: The requirement for cash management, as contained in 2 CFR 200.305, states advanced cash payments must be used only for applicable grant programs. Condition and Context: Procedures related to cash management were inadequate to ensure that funds drawn down were not used for other grant expenditures. The Community’s cash balances at December 31, 2020 were $401,474 and total unearned revenue was $2,427,781, leading to a cash shortfall of $2,026,307. This resulted from the temporary borrowing of federal funds to pay expenses in the General Fund and other federal award programs. Deferred revenue as of December 31, 2020 was $631,800 in the Coronavirus Relief Fund. Cause: Lack of internal controls over cash management. Effect: The Community was not in compliance with 2 CFR 200.305 related to cash management requirements. Deposits were used to fund other programs of the Community. Questioned costs: $2,026,307, which is the shortfall between cash balances and unearned revenue balances. Repeat finding: This is a repeat of Finding 2019-007; therefore, we believe this to be a systemic issue. Recommendation: We recommend the Community monitor grant budgets and drawdowns throughout the year and ensure that program funds are not being lent or borrowed between programs in an effort to ensure that unearned revenue balances do not exceed total cash. Management Response: Management agrees with this finding, see Corrective Action Plan.
The Organization did not establish written procedures as required by 2 CFR section 200.305 (Federal payment ‐ advances) [2 CFR section 200.302(b)(6)].
The Organization did not establish written procedures as required by 2 CFR section 200.305 (Federal payment ‐ advances) [2 CFR section 200.302(b)(6)].
MW2020-008 FEDERAL DRAWDOWNS IN ADVANCE OF EXPENDITURES (REPEAT FINDING) (PREVIOUSLY REPORTED AS MW2019-009) Condition Subsequent to the year ended December 31, 2019, CUAHSI drew down approximately $1,300,000 from National Science Foundation (“NSF”) based on information that there was going to be a government shutdown. Federal funds are required to be to be drawn down on a reimbursement basis and not in advance of the expenditures. The funds were not returned to NSF after it became clear that there would not be a government shutdown. 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. Cause CUAHSI had insufficient funds available to “float” operating expenses. 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.Recommendation The auditor recommends that CUAHSI develops and implements controls over policies consistent with 2 CFR 200.35. Current Year Status This condition still exists for the year ended December 31, 2020. During the completion of the audit, the auditor noted that during 2020, CUAHSI had advance drawdowns totaling $3,610,240 from the NSF. Of this amount, CUAHSI incurred $2,521,926 in eligible expenses for the year ended December 31, 2020. This resulted in $1,088,314 in federal advances as of year-end. The draw downs in excess of revenue recognized during the year ended December 31, 2020 is reported as part of deferred revenue in the accompanying Statement of Financial Position. 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 MW2020-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF EXPENDITURES 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 2020, CUAHSI had advance drawdowns totaling $3,610,240 from the NSF. Of this amount, CUAHSI incurred $2,521,926 in eligible expenses for the year ended December 31, 2020. This resulted in $1,088,314 in excess federal advances as of year-end. The draw downs in excess of revenue recognized during the year ended December 31, 2020 are reported as part of deferred revenue in the accompanying Statement of Financial Position. Cause & Context In anticipation of a government shut down due to COVID-19, 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 MW2019-009. 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 MW2020-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF EXPENDITURES 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 2020, CUAHSI had advance drawdowns totaling $3,610,240 from the NSF. Of this amount, CUAHSI incurred $2,521,926 in eligible expenses for the year ended December 31, 2020. This resulted in $1,088,314 in excess federal advances as of year-end. The draw downs in excess of revenue recognized during the year ended December 31, 2020 are reported as part of deferred revenue in the accompanying Statement of Financial Position. Cause & Context In anticipation of a government shut down due to COVID-19, 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 MW2019-009. 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 MW2020-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF EXPENDITURES 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 2020, CUAHSI had advance drawdowns totaling $3,610,240 from the NSF. Of this amount, CUAHSI incurred $2,521,926 in eligible expenses for the year ended December 31, 2020. This resulted in $1,088,314 in excess federal advances as of year-end. The draw downs in excess of revenue recognized during the year ended December 31, 2020 are reported as part of deferred revenue in the accompanying Statement of Financial Position. Cause & Context In anticipation of a government shut down due to COVID-19, 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 MW2019-009. 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 MW2020-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF EXPENDITURES 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 2020, CUAHSI had advance drawdowns totaling $3,610,240 from the NSF. Of this amount, CUAHSI incurred $2,521,926 in eligible expenses for the year ended December 31, 2020. This resulted in $1,088,314 in excess federal advances as of year-end. The draw downs in excess of revenue recognized during the year ended December 31, 2020 are reported as part of deferred revenue in the accompanying Statement of Financial Position. Cause & Context In anticipation of a government shut down due to COVID-19, 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 MW2019-009. 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 MW2020-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF EXPENDITURES 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 2020, CUAHSI had advance drawdowns totaling $3,610,240 from the NSF. Of this amount, CUAHSI incurred $2,521,926 in eligible expenses for the year ended December 31, 2020. This resulted in $1,088,314 in excess federal advances as of year-end. The draw downs in excess of revenue recognized during the year ended December 31, 2020 are reported as part of deferred revenue in the accompanying Statement of Financial Position. Cause & Context In anticipation of a government shut down due to COVID-19, 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 MW2019-009. 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.
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Grantor: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster: Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID-19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program CFDA Numbers: 93.224 and 93.527 Criteria In accordance with §200.305, Federal payment, Grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of Federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None. Context We selected 6 drawdowns to test controls over cash management. We noted there was no formal approval or evidence of review for these drawdowns. Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
2020-011 Timely Grant Draws Material Weakness Condition: Grant dollars were not drawn in a timely fashion during the year to cover current grant expenditures. The Housing Authority’s grant funded cost reimbursable program was carrying in excess of 60 days operating capital in grants receivable. Criteria: The Housing Authority does not have written policies to address the timeliness of grant draw procedures. Grant funds should be drawn as grant expenditures occur. Carrying anything in excess of 60 days operating capital in grants receivable is considered untimely and indicates that the expenditures carried within these grant funded cost reimbursable programs are being “floated” by the general fund. 2 CFR section 200.305 of the Uniform Guidance states that “For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means.” Cause: Lack of a written grant draw policy and procedures as well as a lack of staff “hands-on” training in those necessary areas. Effect: The Housing Authority’s general fund dollars and liabilities are being used to carry (“float”) these grant program expenditures until the grant funds are actually received. Recommendation: The Housing Authority should adopt written grant draw policies into its financial policies and procedures manual. Financials should be reviewed monthly, and drawdowns made as needed.
2020-011 Timely Grant Draws Material Weakness Condition: Grant dollars were not drawn in a timely fashion during the year to cover current grant expenditures. The Housing Authority’s grant funded cost reimbursable program was carrying in excess of 60 days operating capital in grants receivable. Criteria: The Housing Authority does not have written policies to address the timeliness of grant draw procedures. Grant funds should be drawn as grant expenditures occur. Carrying anything in excess of 60 days operating capital in grants receivable is considered untimely and indicates that the expenditures carried within these grant funded cost reimbursable programs are being “floated” by the general fund. 2 CFR section 200.305 of the Uniform Guidance states that “For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means.” Cause: Lack of a written grant draw policy and procedures as well as a lack of staff “hands-on” training in those necessary areas. Effect: The Housing Authority’s general fund dollars and liabilities are being used to carry (“float”) these grant program expenditures until the grant funds are actually received. Recommendation: The Housing Authority should adopt written grant draw policies into its financial policies and procedures manual. Financials should be reviewed monthly, and drawdowns made as needed.
2019 Management retained the funds in lieu of redeposit resulting in the ACM$ drawdown being halted for the impacted award for 10 months before resuming draw downs. New 2023 Management has put internal controls in place with SF-270 submission for all drawdowns and source backup for all allowable expenses and procedures to ensure 2 CFR Part 200.305 compliance.
2019 Management retained the funds in lieu of redeposit resulting in the ACM$ drawdown being halted for the impacted award for 10 months before resuming draw downs. New 2023 Management has put internal controls in place with SF-270 submission for all drawdowns and source backup for all allowable expenses and procedures to ensure 2 CFR Part 200.305 compliance.
Finding 2019-007 Lack of Internal Control Over Cash Management Federal Agencies: U.S. Department of the Interior and U.S. Department of Health and Human Services Federal Programs: Consolidated Tribal Government (CTG) and Indian Self-Determination (ISD), respectively CFDA Numbers: 15.021 and 93.441, respectively Award Numbers: A16AV00375 and A19AV00503 (CTG), and 243-12-0006 (ISD), respectively Award Years: 2016 and 2019 (CTG), and 2019 and 2020 (ISD) Type of Finding: Material weakness in internal control over compliance and material noncompliance. Criteria: The requirement for cash management, as contained in 2 CFR 200.305, states advanced cash payments must be used only for applicable grant programs. Condition and Context: Procedures related to cash management were inadequate to ensure that funds drawn down were not used for other grant expenditures. The Community’s cash balances at December 31, 2019 were $48,998 and total unearned revenue was $1,661,466, leading to a cash shortfall of $1,612,468. This resulted from the temporary borrowing of federal funds to pay expenses in the General Fund and other federal award programs. Deferred revenue as of December 31, 2019 in the CTG Program was $91,645 and $885,809 in the ISD Program. Cause: Lack of internal controls over cash management. Effect: The Community was not in compliance with 2 CFR 200.305 related to cash management requirements. Deposits were used to fund other programs of the Community. Questioned costs: $1,612,468, which is the shortfall between cash balances and unearned revenue balances. Repeat finding: This is a repeat of Finding 2018-006; therefore, we believe this to be a systemic issue. Recommendation: We recommend the Community monitor grant budgets and drawdowns throughout the year and ensure that program funds are not being lent or borrowed between programs in an effort to ensure that unearned revenue balances do not exceed total cash. Management Response: Management agrees with this finding, see Corrective Action Plan.
Finding 2019-007 Lack of Internal Control Over Cash Management Federal Agencies: U.S. Department of the Interior and U.S. Department of Health and Human Services Federal Programs: Consolidated Tribal Government (CTG) and Indian Self-Determination (ISD), respectively CFDA Numbers: 15.021 and 93.441, respectively Award Numbers: A16AV00375 and A19AV00503 (CTG), and 243-12-0006 (ISD), respectively Award Years: 2016 and 2019 (CTG), and 2019 and 2020 (ISD) Type of Finding: Material weakness in internal control over compliance and material noncompliance. Criteria: The requirement for cash management, as contained in 2 CFR 200.305, states advanced cash payments must be used only for applicable grant programs. Condition and Context: Procedures related to cash management were inadequate to ensure that funds drawn down were not used for other grant expenditures. The Community’s cash balances at December 31, 2019 were $48,998 and total unearned revenue was $1,661,466, leading to a cash shortfall of $1,612,468. This resulted from the temporary borrowing of federal funds to pay expenses in the General Fund and other federal award programs. Deferred revenue as of December 31, 2019 in the CTG Program was $91,645 and $885,809 in the ISD Program. Cause: Lack of internal controls over cash management. Effect: The Community was not in compliance with 2 CFR 200.305 related to cash management requirements. Deposits were used to fund other programs of the Community. Questioned costs: $1,612,468, which is the shortfall between cash balances and unearned revenue balances. Repeat finding: This is a repeat of Finding 2018-006; therefore, we believe this to be a systemic issue. Recommendation: We recommend the Community monitor grant budgets and drawdowns throughout the year and ensure that program funds are not being lent or borrowed between programs in an effort to ensure that unearned revenue balances do not exceed total cash. Management Response: Management agrees with this finding, see Corrective Action Plan.
2019 Management retained the funds in lieu of redeposit resulting in the ACM$ drawdown being halted for the impacted award for 10 months before resuming draw downs. New 2023 Management has put internal controls in place with SF-270 submission for all drawdowns and source backup for all allowable expenses and procedures to ensure 2 CFR Part 200.305 compliance.
2019 Management retained the funds in lieu of redeposit resulting in the ACM$ drawdown being halted for the impacted award for 10 months before resuming draw downs. New 2023 Management has put internal controls in place with SF-270 submission for all drawdowns and source backup for all allowable expenses and procedures to ensure 2 CFR Part 200.305 compliance.
Finding 2019-007 Lack of Internal Control Over Cash Management Federal Agencies: U.S. Department of the Interior and U.S. Department of Health and Human Services Federal Programs: Consolidated Tribal Government (CTG) and Indian Self-Determination (ISD), respectively CFDA Numbers: 15.021 and 93.441, respectively Award Numbers: A16AV00375 and A19AV00503 (CTG), and 243-12-0006 (ISD), respectively Award Years: 2016 and 2019 (CTG), and 2019 and 2020 (ISD) Type of Finding: Material weakness in internal control over compliance and material noncompliance. Criteria: The requirement for cash management, as contained in 2 CFR 200.305, states advanced cash payments must be used only for applicable grant programs. Condition and Context: Procedures related to cash management were inadequate to ensure that funds drawn down were not used for other grant expenditures. The Community’s cash balances at December 31, 2019 were $48,998 and total unearned revenue was $1,661,466, leading to a cash shortfall of $1,612,468. This resulted from the temporary borrowing of federal funds to pay expenses in the General Fund and other federal award programs. Deferred revenue as of December 31, 2019 in the CTG Program was $91,645 and $885,809 in the ISD Program. Cause: Lack of internal controls over cash management. Effect: The Community was not in compliance with 2 CFR 200.305 related to cash management requirements. Deposits were used to fund other programs of the Community. Questioned costs: $1,612,468, which is the shortfall between cash balances and unearned revenue balances. Repeat finding: This is a repeat of Finding 2018-006; therefore, we believe this to be a systemic issue. Recommendation: We recommend the Community monitor grant budgets and drawdowns throughout the year and ensure that program funds are not being lent or borrowed between programs in an effort to ensure that unearned revenue balances do not exceed total cash. Management Response: Management agrees with this finding, see Corrective Action Plan.
Finding 2019-007 Lack of Internal Control Over Cash Management Federal Agencies: U.S. Department of the Interior and U.S. Department of Health and Human Services Federal Programs: Consolidated Tribal Government (CTG) and Indian Self-Determination (ISD), respectively CFDA Numbers: 15.021 and 93.441, respectively Award Numbers: A16AV00375 and A19AV00503 (CTG), and 243-12-0006 (ISD), respectively Award Years: 2016 and 2019 (CTG), and 2019 and 2020 (ISD) Type of Finding: Material weakness in internal control over compliance and material noncompliance. Criteria: The requirement for cash management, as contained in 2 CFR 200.305, states advanced cash payments must be used only for applicable grant programs. Condition and Context: Procedures related to cash management were inadequate to ensure that funds drawn down were not used for other grant expenditures. The Community’s cash balances at December 31, 2019 were $48,998 and total unearned revenue was $1,661,466, leading to a cash shortfall of $1,612,468. This resulted from the temporary borrowing of federal funds to pay expenses in the General Fund and other federal award programs. Deferred revenue as of December 31, 2019 in the CTG Program was $91,645 and $885,809 in the ISD Program. Cause: Lack of internal controls over cash management. Effect: The Community was not in compliance with 2 CFR 200.305 related to cash management requirements. Deposits were used to fund other programs of the Community. Questioned costs: $1,612,468, which is the shortfall between cash balances and unearned revenue balances. Repeat finding: This is a repeat of Finding 2018-006; therefore, we believe this to be a systemic issue. Recommendation: We recommend the Community monitor grant budgets and drawdowns throughout the year and ensure that program funds are not being lent or borrowed between programs in an effort to ensure that unearned revenue balances do not exceed total cash. Management Response: Management agrees with this finding, see Corrective Action Plan.
Finding No.: 2019-009 Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 5U79SP020710-04 Area: Cash Management Questioned Costs: $-0- Criteria: In accordance with 2 CFR Section 200.305(b)(1), non-Federal entities other than states, payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Condition: Of five subrecipient disbursements tested for cash management requirement, aggregating $175,000 of a total population of $468,864, for five (or 100%), documentation of procedures performed to ensure that the time elapsed between the transfer of federal funds to the subrecipients and the disbursement of such funds by the subrecipients were not provided. No questioned costs as amounts questioned at Finding No. 2019-012, Condition 1 are for the same subrecipients, for which the total FY2019 expenditures under the subrecipient agreements were questioned. Cause: CHCC did not enforce monitoring controls over compliance with applicable cash management requirements over subrecipients. Finding No.: 2019-009, continued Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 5U79SP020710-04 Area: Cash Management Questioned Costs: $-0- Effect: CHCC is in incompliance with applicable cash management requirements over subrecipients. Recommendation: CHCC should establish and implement procedures to ensure that the time elapsing between the transfer of Federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient is minimized. Views of Responsible Officials: CHCC’s Corrective Action Plan provides a detailed rationale for disagreement with the finding. Auditor Response: Documentations of procedures performed to ensure that the time elapsed between the transfer of federal funds to the subrecipients and the disbursement of such funds by the subrecipients were not provided. In addition, initial draft reports were provided to CHCC on 09/06/24 and 09/24/24. It was also agreed during the 09/06/24 and 10/04/24 meetings for CHCC to provide corresponding underlying accounting records to resolve the finding; however, no documentations were provided within the agreed timeline. Accordingly, finding is sustained.
Finding No.: 2019-009 Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 5U79SP020710-04 Area: Cash Management Questioned Costs: $-0- Criteria: In accordance with 2 CFR Section 200.305(b)(1), non-Federal entities other than states, payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Condition: Of five subrecipient disbursements tested for cash management requirement, aggregating $175,000 of a total population of $468,864, for five (or 100%), documentation of procedures performed to ensure that the time elapsed between the transfer of federal funds to the subrecipients and the disbursement of such funds by the subrecipients were not provided. No questioned costs as amounts questioned at Finding No. 2019-012, Condition 1 are for the same subrecipients, for which the total FY2019 expenditures under the subrecipient agreements were questioned. Cause: CHCC did not enforce monitoring controls over compliance with applicable cash management requirements over subrecipients. Finding No.: 2019-009, continued Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 5U79SP020710-04 Area: Cash Management Questioned Costs: $-0- Effect: CHCC is in incompliance with applicable cash management requirements over subrecipients. Recommendation: CHCC should establish and implement procedures to ensure that the time elapsing between the transfer of Federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient is minimized. Views of Responsible Officials: CHCC’s Corrective Action Plan provides a detailed rationale for disagreement with the finding. Auditor Response: Documentations of procedures performed to ensure that the time elapsed between the transfer of federal funds to the subrecipients and the disbursement of such funds by the subrecipients were not provided. In addition, initial draft reports were provided to CHCC on 09/06/24 and 09/24/24. It was also agreed during the 09/06/24 and 10/04/24 meetings for CHCC to provide corresponding underlying accounting records to resolve the finding; however, no documentations were provided within the agreed timeline. Accordingly, finding is sustained.