Findings Citing § 200.305

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Federal Government Federal Program Name: Research & Development Assistance Listing Number: 10.205, 10.216, 12.630, 93.859 Federal Award Identification Number and Year: Multiple Award Period: 7/1/2023-6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: N/A Context: CLA tested a sample of 19 subrecipient payments and discovered that 7 of the 19 payments had exceptions. Cause: The University did not have an effective control in place to ensure subrecipient payments were paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat Finding: Yes, 2023-014. Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely. Views of responsible officials: There is no disagreement with the audit finding.

Assistance Listing, Federal Agency, and Program Name - 93.566, U.S. Department of Health and Human Services, Refugee and Entrant Assistance State/ Replacement Designee Administered Programs Federal Award Identification Number and Year - FCSAK00843 2024 Pass-through Entity - Illinois Department of Human Services Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - In accordance with 2 CFR 200.305 2(b), for nonfederal 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 nonfederal entity whether the payment is made by electronic funds transfers or issuance or redemption of checks, warrants, or payments by other means. In accordance with 2 CFR 200.305(3), when the reimbursement method is used, the federal awarding agency or pass through entity must make payment within 30 calendar days after receipt of billing, unless it is believed the request to be improper. Condition - Controls in place did not minimize the time elapsing between the transfer receipt of billing from the subrecipient and disbursement of federal dollars to the subrecipient in accordance with the guidance above. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable as there are no questioned costs. Context - Of the four transactions tested, none of the subrecipients were paid within 30 days of receipt of billing. Cause and Effect - Policies, procedures, and related internal internal controls did not ensure compliance with federal payment requirements under Uniform Guidance. Recommendation - We recommend the Federation review its procedures and controls to ensure disbursement of funds to its subrecipients is consistent with applicable laws and regulations. Views of Responsible Officials and Corrective Action Plan - As a pass through recipient, the Federation relies on the timeliness of the State for reimbursement. In all transactions tested, the Federation reimbursed the subrecipients within 30 days of receipt of funds from the State. However, as a pass through entity the Federation understands the requirement to reimburse subrecipients within 30 calendar days after receipt of a billing. The Federation will work with the State to address the time elapsed.

Item 2024-002 - Capital Fund Drawn not Expended in Three Days Program: 14.872 - Capital Funds Criteria: 2 CFR 200.305 requires PHAs to minimize the time federal funds are drawn down to expenditure. The Capital Fund Program provides guidelines of three business days from draw down to expenditure to minimize the interest accrued by the PHA. 24 CFR 905.310 states the PHA shall initiate a fund requisition from HUD only when funds are due and payable, unless HUD approves another payment schedule as authorized by 2 CFR 200.305. Condition: The Housing Authority had drawn down Capital Funds and did not expend within three days. Cause: The Housing Authority was not aware that Capital Funds drawn needed to be expended within three days. Questioned Costs: Not applicable. Effect: The Housing Authority is not in compliance with cash management requirements. Prior Year Finding: N/A Information: Isolated instance. Recommendation: It is recommended that the Housing Authority implements appropriate controls over voucher draws to ensure compliance with Public Housing Capital Fund cash management requirements. Management’s Response: Management concurs with the recommendation to implement timely LOCCS fundings that coincides with our normal accounting cycle and when directed by HUD to circumvent the rules to get that in writing not just verbal.

Criteria or Specific Requirement: For recipients of research and development grants, payment methods 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. When the reimbursement method is used, the Federal agency or pass-through entity must make payment within 30 calendar days after receipt of the payment request unless the Federal agency or pass-through entity reasonably believes the request to be improper (2 CFR 200.305(b)(3)). The University must develop its own control activities. Requests for reimbursement are to be reviewed and authorized prior to submission by reviewing supporting documents/schedules/reports to ensure amounts have been paid with the University's funds prior to the reimbursement request. Condition/Context: During our testing of 5 reimbursement requests made during the fiscal year, we noted 4 instances that did not include documentation of review and approval by a representative of the University. Questioned Costs: None. Cause: The University’s internal controls did not include a control for review and approval by an individual other than the person performing the drawdown calculation and request from the federal agency. Effect: Incorrect drawdown requests could be made of the federal agency. Repeat Finding: No. Recommendation: We recommend the University review its internal controls around the reimbursement process for all federal grants to ensure the necessary review and approval controls are in place and performed by an individual other than the one performing the drawdown calculation and request from the federal agency. Views of Responsible Officials: Please refer to the attached corrective action plan.

Criteria or Specific Requirement: For recipients of research and development grants, payment methods 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. When the reimbursement method is used, the Federal agency or pass-through entity must make payment within 30 calendar days after receipt of the payment request unless the Federal agency or pass-through entity reasonably believes the request to be improper (2 CFR 200.305(b)(3)). The University must develop its own control activities. Requests for reimbursement are to be reviewed and authorized prior to submission by reviewing supporting documents/schedules/reports to ensure amounts have been paid with the University's funds prior to the reimbursement request. Condition/Context: During our testing of 5 reimbursement requests made during the fiscal year, we noted 4 instances that did not include documentation of review and approval by a representative of the University. Questioned Costs: None. Cause: The University’s internal controls did not include a control for review and approval by an individual other than the person performing the drawdown calculation and request from the federal agency. Effect: Incorrect drawdown requests could be made of the federal agency. Repeat Finding: No. Recommendation: We recommend the University review its internal controls around the reimbursement process for all federal grants to ensure the necessary review and approval controls are in place and performed by an individual other than the one performing the drawdown calculation and request from the federal agency. Views of Responsible Officials: Please refer to the attached corrective action plan.

Criteria or Specific Requirement: For recipients of research and development grants, payment methods 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. When the reimbursement method is used, the Federal agency or pass-through entity must make payment within 30 calendar days after receipt of the payment request unless the Federal agency or pass-through entity reasonably believes the request to be improper (2 CFR 200.305(b)(3)). The University must develop its own control activities. Requests for reimbursement are to be reviewed and authorized prior to submission by reviewing supporting documents/schedules/reports to ensure amounts have been paid with the University's funds prior to the reimbursement request. Condition/Context: During our testing of 5 reimbursement requests made during the fiscal year, we noted 4 instances that did not include documentation of review and approval by a representative of the University. Questioned Costs: None. Cause: The University’s internal controls did not include a control for review and approval by an individual other than the person performing the drawdown calculation and request from the federal agency. Effect: Incorrect drawdown requests could be made of the federal agency. Repeat Finding: No. Recommendation: We recommend the University review its internal controls around the reimbursement process for all federal grants to ensure the necessary review and approval controls are in place and performed by an individual other than the one performing the drawdown calculation and request from the federal agency. Views of Responsible Officials: Please refer to the attached corrective action plan.

Criteria or Specific Requirement: For recipients of research and development grants, payment methods 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. When the reimbursement method is used, the Federal agency or pass-through entity must make payment within 30 calendar days after receipt of the payment request unless the Federal agency or pass-through entity reasonably believes the request to be improper (2 CFR 200.305(b)(3)). The University must develop its own control activities. Requests for reimbursement are to be reviewed and authorized prior to submission by reviewing supporting documents/schedules/reports to ensure amounts have been paid with the University's funds prior to the reimbursement request. Condition/Context: During our testing of 5 reimbursement requests made during the fiscal year, we noted 4 instances that did not include documentation of review and approval by a representative of the University. Questioned Costs: None. Cause: The University’s internal controls did not include a control for review and approval by an individual other than the person performing the drawdown calculation and request from the federal agency. Effect: Incorrect drawdown requests could be made of the federal agency. Repeat Finding: No. Recommendation: We recommend the University review its internal controls around the reimbursement process for all federal grants to ensure the necessary review and approval controls are in place and performed by an individual other than the one performing the drawdown calculation and request from the federal agency. Views of Responsible Officials: Please refer to the attached corrective action plan.

Criteria or Specific Requirement: For recipients of research and development grants, payment methods 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. When the reimbursement method is used, the Federal agency or pass-through entity must make payment within 30 calendar days after receipt of the payment request unless the Federal agency or pass-through entity reasonably believes the request to be improper (2 CFR 200.305(b)(3)). The University must develop its own control activities. Requests for reimbursement are to be reviewed and authorized prior to submission by reviewing supporting documents/schedules/reports to ensure amounts have been paid with the University's funds prior to the reimbursement request. Condition/Context: During our testing of 5 reimbursement requests made during the fiscal year, we noted 4 instances that did not include documentation of review and approval by a representative of the University. Questioned Costs: None. Cause: The University’s internal controls did not include a control for review and approval by an individual other than the person performing the drawdown calculation and request from the federal agency. Effect: Incorrect drawdown requests could be made of the federal agency. Repeat Finding: No. Recommendation: We recommend the University review its internal controls around the reimbursement process for all federal grants to ensure the necessary review and approval controls are in place and performed by an individual other than the one performing the drawdown calculation and request from the federal agency. Views of Responsible Officials: Please refer to the attached corrective action plan.

Criteria or Specific Requirement: For recipients of research and development grants, payment methods 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. When the reimbursement method is used, the Federal agency or pass-through entity must make payment within 30 calendar days after receipt of the payment request unless the Federal agency or pass-through entity reasonably believes the request to be improper (2 CFR 200.305(b)(3)). The University must develop its own control activities. Requests for reimbursement are to be reviewed and authorized prior to submission by reviewing supporting documents/schedules/reports to ensure amounts have been paid with the University's funds prior to the reimbursement request. Condition/Context: During our testing of 5 reimbursement requests made during the fiscal year, we noted 4 instances that did not include documentation of review and approval by a representative of the University. Questioned Costs: None. Cause: The University’s internal controls did not include a control for review and approval by an individual other than the person performing the drawdown calculation and request from the federal agency. Effect: Incorrect drawdown requests could be made of the federal agency. Repeat Finding: No. Recommendation: We recommend the University review its internal controls around the reimbursement process for all federal grants to ensure the necessary review and approval controls are in place and performed by an individual other than the one performing the drawdown calculation and request from the federal agency. Views of Responsible Officials: Please refer to the attached corrective action plan.

Criteria or Specific Requirement: For recipients of research and development grants, payment methods 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. When the reimbursement method is used, the Federal agency or pass-through entity must make payment within 30 calendar days after receipt of the payment request unless the Federal agency or pass-through entity reasonably believes the request to be improper (2 CFR 200.305(b)(3)). The University must develop its own control activities. Requests for reimbursement are to be reviewed and authorized prior to submission by reviewing supporting documents/schedules/reports to ensure amounts have been paid with the University's funds prior to the reimbursement request. Condition/Context: During our testing of 5 reimbursement requests made during the fiscal year, we noted 4 instances that did not include documentation of review and approval by a representative of the University. Questioned Costs: None. Cause: The University’s internal controls did not include a control for review and approval by an individual other than the person performing the drawdown calculation and request from the federal agency. Effect: Incorrect drawdown requests could be made of the federal agency. Repeat Finding: No. Recommendation: We recommend the University review its internal controls around the reimbursement process for all federal grants to ensure the necessary review and approval controls are in place and performed by an individual other than the one performing the drawdown calculation and request from the federal agency. Views of Responsible Officials: Please refer to the attached corrective action plan.

Criteria or Specific Requirement: For recipients of research and development grants, payment methods 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. When the reimbursement method is used, the Federal agency or pass-through entity must make payment within 30 calendar days after receipt of the payment request unless the Federal agency or pass-through entity reasonably believes the request to be improper (2 CFR 200.305(b)(3)). The University must develop its own control activities. Requests for reimbursement are to be reviewed and authorized prior to submission by reviewing supporting documents/schedules/reports to ensure amounts have been paid with the University's funds prior to the reimbursement request. Condition/Context: During our testing of 5 reimbursement requests made during the fiscal year, we noted 4 instances that did not include documentation of review and approval by a representative of the University. Questioned Costs: None. Cause: The University’s internal controls did not include a control for review and approval by an individual other than the person performing the drawdown calculation and request from the federal agency. Effect: Incorrect drawdown requests could be made of the federal agency. Repeat Finding: No. Recommendation: We recommend the University review its internal controls around the reimbursement process for all federal grants to ensure the necessary review and approval controls are in place and performed by an individual other than the one performing the drawdown calculation and request from the federal agency. Views of Responsible Officials: Please refer to the attached corrective action plan.

Criteria or Specific Requirement: For recipients of research and development grants, payment methods 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. When the reimbursement method is used, the Federal agency or pass-through entity must make payment within 30 calendar days after receipt of the payment request unless the Federal agency or pass-through entity reasonably believes the request to be improper (2 CFR 200.305(b)(3)). The University must develop its own control activities. Requests for reimbursement are to be reviewed and authorized prior to submission by reviewing supporting documents/schedules/reports to ensure amounts have been paid with the University's funds prior to the reimbursement request. Condition/Context: During our testing of 5 reimbursement requests made during the fiscal year, we noted 4 instances that did not include documentation of review and approval by a representative of the University. Questioned Costs: None. Cause: The University’s internal controls did not include a control for review and approval by an individual other than the person performing the drawdown calculation and request from the federal agency. Effect: Incorrect drawdown requests could be made of the federal agency. Repeat Finding: No. Recommendation: We recommend the University review its internal controls around the reimbursement process for all federal grants to ensure the necessary review and approval controls are in place and performed by an individual other than the one performing the drawdown calculation and request from the federal agency. Views of Responsible Officials: Please refer to the attached corrective action plan.

Criteria or Specific Requirement: For recipients of research and development grants, payment methods 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. When the reimbursement method is used, the Federal agency or pass-through entity must make payment within 30 calendar days after receipt of the payment request unless the Federal agency or pass-through entity reasonably believes the request to be improper (2 CFR 200.305(b)(3)). The University must develop its own control activities. Requests for reimbursement are to be reviewed and authorized prior to submission by reviewing supporting documents/schedules/reports to ensure amounts have been paid with the University's funds prior to the reimbursement request. Condition/Context: During our testing of 5 reimbursement requests made during the fiscal year, we noted 4 instances that did not include documentation of review and approval by a representative of the University. Questioned Costs: None. Cause: The University’s internal controls did not include a control for review and approval by an individual other than the person performing the drawdown calculation and request from the federal agency. Effect: Incorrect drawdown requests could be made of the federal agency. Repeat Finding: No. Recommendation: We recommend the University review its internal controls around the reimbursement process for all federal grants to ensure the necessary review and approval controls are in place and performed by an individual other than the one performing the drawdown calculation and request from the federal agency. Views of Responsible Officials: Please refer to the attached corrective action plan.

Federal agency: U.S. Department of Commerce Federal program title: Connecting Minority Communities Pilot Program ALN: 11.028 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 Commerce. Condition and Context: The Connecting Minority Communities Pilot Program funds drawn in advance were not limited to immediate cash requirements. Cause: Improper projection of immediate cash needs Effect: Excess cash maintained may not be available for use in other programs. Questioned costs: None Recommendation The College should implement a process to only drawdown funds for its immediate needs. Also, the College should compute interest earned on advance funds and refund the grantor when required.

DEPARTMENT OF HEALTH AND HUMAN SERVICES Administration for Children and Families, Refugee and Entrant Assistance - Discretionary Grants - Refugee Educational and Savings Success Program - Assistance Listing No. 93.576; award numbers 90RG0208, 90Re0305, 90ZN0005, and 90RE0336; award year ending September 30, 2024. Condition: Excess federal funds drawn. Criteria: 2 CFR Section 200.305 requires non-federal entities to minimize the time elapsing between the transfer of funds from the U.S. Treasury and the disbursement of the funds for allowable program costs. Cause: The agency failed to monitor their federal funds drawn. Effect: The agency's audit shows that the agency had excess federal funds among four directly funded federal programs totaling $354,061 at June 30, 2024. Context: A comparison of total funds drawn by grant to total allowable costs by grant disclosed that there was an excess of funds at the end of the audit period as follows: Grant Number 90RG0208 Excess Funds $35,973 Grant Number 90RE0305 Excess Funds $32,741 Grant Number 90ZN0005 Excess Funds $196,886 Grant Number 90RE0336 Excess Funds $88,461 Total $354,061. Recommendation: The agency should establish procedures to track funds drawn fron the U.S. Treasury and limit cash on hand to what is required by the grant within 30 days. View of Responsible Officials: Reason for excess funds - we withdrew funds from the payment management service uniformly on a quarterly basis for each program. This approach has resulted in accumulating the above-mentioned funds at the end of the period.