Criteria: Under the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance, 2 CFR §200.305), non-federal entities must minimize the time between the receipt of federal funds and the disbursement of those funds for program purposes. Reimbursements must be used promptly to pay allowable costs incurred. Condition:Duringtheauditperiod,theCentersubmittedreimbursementrequestsfundsforallowableprogramexpenses andreceivedreimbursementinthesubsequentyear,butdidnotremitpaymenttovendorsinatimelymanner.3of the14 vendor invoices remained unpaid for extended periods despite the Center having received reimbursement for those costs. Cause: The delays in vendor payments were primarily due to weaknesses in internal cash management controls, including lack of reconciliation between reimbursement receipts and outstanding payables, and insufficient oversight of accounts payable processing. Effect: The Center was not in compliance with 2 CFR §200.305. Failure to promptly pay vendors after receiving reimbursement can also result in reputational risk, strained vendor relationships, and potential disallowance of costs by grantor agencies. Questioned Costs: None Recommendation: Management should establish procedures to ensure timely disbursement of funds upon receipt of reimbursements to vendors. Views of Responsible Officials: Management agrees with the finding; see corrective action plan.
2024-001 Cash Management – WIC Reimbursement to Member Counties Prior Year Finding Number: N/A Year of Finding Origination: 2024 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of Agriculture Program: 10.557 WIC Special Supplemental Nutrition Program for Women, Infants, and Children Award Number and Year: 202792; 2024 Pass-Through Agency: Minnesota Department of Health Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Title 2 U.S. Code of Federal Regulations § 200.305(b) states 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. Condition: One of four subrecipient payments tested for compliance with federal cash management requirements was not paid timely to minimize the time elapsing between receipt of federal funds and disbursement to subrecipients. Questioned Costs: None. Context: Payment was made 126 days after receipt of the reimbursement request. The total amount reimbursed by the Minnesota Department of Health and paid to subrecipients is $1,087,575, consisting of 12 reimbursements. The sample of four reimbursements totaled $393,605. The payment made 126 days after receipt was for $89,935. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: Partnership4Health is not in compliance with cash management requirements. Cause: Partnership4Health did not have backup procedures in place during an employee transition. Recommendation: We recommend Partnership4Health establish procedures to ensure cash management requirements are met. View of Responsible Official: Concur
Reference Number: 2024-005 Prior Year Finding: No Federal Agency: U.S Department of Justice Federal Program: Congressionally Recommended Awards Assistance Listing Number: 16.753 Award Number: 15PBJA-23-GG-00920-BRND Compliance Requirement: Cash Management Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Condition The County received reimbursement for the total grant award amount prior to incurring expenditures. Criteria or specific requirement Compliance: Per 2 CFR section 200.305(b) For recipients and subrecipients other than States, 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. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions the Federal award. These internal controls should comply with guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States or the Internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Context The County received $2.5 million on July 1, 2024, for the grant, as of that date the general ledger reported no expenditures. The County incurred expenditures of $274,235 in October, $62,247 in November, and $2,160,518 in December. Cause The County’s controls were not operating effectively to ensure reimbursement request were performed in accordance with federal requirements. Effect The County had to return funding of $1,367,790 in November, which was subsequently drawn in December when expenditures were incurred. Questioned Costs None noted. Recommendation We recommend that the County develop internal controls and procedures to ensure drawdowns are performed in a manner to minimize the time between drawing and disbursing federal funds Views of responsible officials and planned corrective actions Fiscal Clerk has been trained on proper drawdown of grant funds and accurate recording of expenditures.
Finding # 2024-003 Type: Immaterial noncompliance Federal Agency: U.S. Department of Commerce, National Oceanic and Atmospheric Administration Assistance Listing: 11.441 Criteria/Requirement: In accordance with 2 CFR 200.305, organizations that receive more than $250,000 of federal funding per year should maintain those funds in an interest-bearing account. Interest earned in excess of $500 should be remitted back to the federal government. Cause: Funds are not maintained in an interest-bearing account. Effect: There are potential lost earnings and the Organization is not following federal guidelines. Recommendation: The Organization should change their primary operating account to an interest-bearing account. Management Response: Funds on hand will be moved to an interest-bearing account.
Federal agency: U.S. Department of Health and Human Services Federal Award Project Title: Better Family Life’s Relationship, Education, Advancement, and Development for Youth for Life Project Assistance Listing Number: 93.086 Assistance Listing Program Title: Healthy Marriage Promotion and Responsible Fatherhood Grants Award Period: September 30, 2023 – September 29, 2024 Award Period: September 30, 2024 – September 29, 2025 Federal agency: U.S. Department of Health and Human Services Federal Award Project Title: Better Family Life’s Teen Pregnancy Prevention Education Assistance Listing Number: 93.297 Assistance Listing Program Title: Adolescent Health Programs Award Period: July 1, 2023 – June 30, 2024 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Compliance and Internal Control over Compliance Criteria: Related to cash management, when entities are funded on a reimbursement basis, program costs must be incurred before the drawdown is requested according to CFR section 200.305. Nonprofits should document the basis, or calculation, used for each drawdown request to show that the amount requested matches the expenses incurred for the period. Additionally, CFR section 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal control over the Federal awards that provides reasonable assurance that the Federal expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. Drawdown requests should be reviewed and approved by appropriate personnel prior to submission by reviewing supporting documents to ensure amounts have been incurred.Condition: During audit testing of compliance and internal control over compliance, it was discovered funds were drawn down several times based on estimated bi-monthly expenses. Additionally, drawdown requests were not properly reviewed and approved by appropriate personnel. Cause: Due to staff turnover and timing constraints, the Organization utilized reasonable estimates rather than exact amounts for drawdown requests. Additionally, review and approval procedures related to drawdown requests were not being consistently performed. Effect: The estimated drawdown of funds could be different than actual expenditures incurred for the period, leading to costs being reimbursed prior to costs being incurred. As of December 31, 2024, all funds drawn were for expenses incurred prior to December 31, 2024. Additionally, the inconsistent application of internal controls could result in reimbursement of costs that were not incurred prior to drawdown. Questioned costs: No questioned costs were identified. Context: During audit testing of the Organization’s compliance and internal controls over compliance related to cash management, it was discovered the Organization at times utilized reasonable estimates rather than exact amounts for drawdown requests. Additionally, there was no review and approval of drawdown requests by appropriate personnel after February 2024, due to staff turnover. The audit team did not identify any questioned costs and concluded that the control failure was not indicative of fraud or illegal activities. Due to the compliance finding and lack of control, the audit team concluded the finding to be a significant deficiency in compliance and internal control over compliance. Recommendation: We recommend the Organization implement procedures to monitor drawdowns of funds so that funds are only requested when approved and documented reimbursable expenses have been incurred. Additionally, we recommend that management establish and enforce documented review and approval procedures of all drawdown requests. View of responsible officials: There is no disagreement with the audit finding.
Finding 2024-004 Lack of Internal Control over Cash Management Federal Agency: U.S. Department of the Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) ALN: 21.027 Award Numbers: SLFRP4178/4850 Award Year: 2021 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 grant funds drawn down were used for grant expenditures in the applicable program. We compared the unearned revenue balances of the grant funds with the available cash balances at year end. The Village’s cash balances for all governmental funds amounted to $6,230,065 at December 31, 2024. The unearned revenues were $6,512,960 which resulted in a shortfall of $282,895. The CSLFRF program had an unearned revenue balance of $5,352,004 as of December 31, 2024. Cause: Lack of internal control over cash management. Effect: The Village requested and received advances for various federal programs to cover expenditures. Cash advances were used to fund other unrelated programs of the Village. Questioned Costs: $282,895, which is the shortfall between cash and cash equivalents and the unearned revenue balances. Repeat Finding: This is a repeat of Finding 2023-006, and since it is a repeat finding we believe this to be a systemic issue. Recommendation: We recommend that the Village monitor grant budgets and drawdowns throughout the year and ensure that program funds are not being lent or borrowed between programs to ensure that unearned revenue balances do not exceed total cash and cash equivalents. Management’s Response: Management concurs with this finding. See corrective action plan.
Reference Number: 2024-005 Prior Year Finding: No Federal Agency: U.S Department of Justice Federal Program: Congressionally Recommended Awards Assistance Listing Number: 16.753 Award Number: 15PBJA-23-GG-00920-BRND Compliance Requirement: Cash Management Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Condition The County received reimbursement for the total grant award amount prior to incurring expenditures. Criteria or specific requirement Compliance: Per 2 CFR section 200.305(b) For recipients and subrecipients other than States, 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. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions the Federal award. These internal controls should comply with guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States or the Internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Context The County received $2.5 million on July 1, 2024, for the grant, as of that date the general ledger reported no expenditures. The County incurred expenditures of $274,235 in October, $62,247 in November, and $2,160,518 in December. Cause The County’s controls were not operating effectively to ensure reimbursement request were performed in accordance with federal requirements. Effect The County had to return funding of $1,367,790 in November, which was subsequently drawn in December when expenditures were incurred. Questioned Costs None noted. Recommendation We recommend that the County develop internal controls and procedures to ensure drawdowns are performed in a manner to minimize the time between drawing and disbursing federal funds Views of responsible officials and planned corrective actions Fiscal Clerk has been trained on proper drawdown of grant funds and accurate recording of expenditures.
Finding No. 2024-001 – Cash Management | Identification of the Program: | Program Name: Research and Development Cluster: Basic Scientific Research, Department of Defense Awarding Office, 12.431; NSF Technology, Innovation and Partnerships, National Science Foundation, 47.084 | Criteria or Specific Requirements (Including Statutory, Regulatory, or Other Citations): 2 CFR 200.303 requires that a non-Federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” According to page 3-C-5 of the 2024 OMB Compliance Supplement, expenses must be incurred before submitting a reimbursement request (2 CFR § 200.305(b)(3)). | Condition: During our testing of 2024 reimbursement requests (totaling $536,272), we noted that there was no evidence of review and approval of the requests to indicate whether the reviewer determined that expenditures submitted for reimbursement had been incurred prior to the request for reimbursement. Management has indicated this review does, in fact, take place, however, there is no evidence (i.e., sign off) on the request to indicate that the review had occurred. | Section III— Federal Award Findings and Questioned Costs (continued) | Cause: Internal controls over the review and approval of the reimbursement requests were not effective. | Effect or Potential Effect: This could result in reimbursement for expenditures that have not been incurred and paid prior to reimbursement being requested. | Questioned Costs: None. | Context: As the sample size is small, we selected 10 cash disbursements for testing. There was no evidence of approval for all 10 reimbursement requests. | Identification as a Repeat Finding: N/A – This is a first year Uniform Guidance audit. | Recommendation: Management should strengthen its internal controls over cash management related to reimbursement requests by having the reviewer sign off on the reimbursement request to support that the review had occurred. | View of Responsible Officials: Management concurs with the findings and has developed a corrective action plan to address this finding.
Finding 2024-001: Lack of Internal Control over Financial Reporting Information on the Federal Program: Assistance Listing Number 11.405 - Cooperative Institute for Marine and Atmospheric Research. Award Number NA22NMF4050043 (MA 1797). Compliance Requirement: Reporting. Type of Finding: Material Noncompliance. Criteria: Uniform Guidance, 2 CFR § 200.305 Report Submission requires that a non-federal entity submit its Single Audit report, data collection form (SF-SAC), and reporting package to the Federal Audit Clearinghouse within the earlier of 30 days after the receipt of the auditor's report or nine months after the end of the audit period. Condition: The auditee's fiscal year-end is December 31, 2024. Per 2 CFR § 200.512, the reporting package was due on September 30, 2025. The auditee did not submit the completed Single Audit package to the Federal Audit Clearinghouse until after the required due date. Context: A review of the auditee's internal records and the FAC website confirmed that the Single Audit reporting package was not submitted by the required deadline. The delay was primarily caused by the lack of timely reconciliation of the auditee's financial records, which postponed the auditor's ability to complete their fieldwork. Cause: Management had not established and maintained effective internal controls over reporting to ensure timely submission of audited financial statements to the Federal Audit Clearinghouse. Effect or Potential Effect: The late submission put the auditee in noncompliance with federal regulations. This hinders the oversight agency from getting timely information about the auditee’s financial and compliance status. A lack of internal controls over required compliance requirements could affect the Organization receiving future federal funding. Questioned Costs: None Repeat Finding: Repeat finding of 2024-001 Recommendation: We recommend that management timely submit annual audit report to the Federal Audit Clearinghouse. To do this, management should develop and implement a clear timeline with internal milestones for completing audit preparation and review. Management should also establish internal control procedures that assign specific responsibilities to staff to ensure that all federal reporting deadlines are met. Views of Responsible Official: Management of the Organization concurs with the audit finding and will immediately implement the auditors’ recommendations. Internal control procedures will be put into place to establish milestones and overseen by the Executive director.
Compliance Requirement Cash Management and Reporting Type of Finding Material Weakness in Internal Control over Compliance Material Noncompliance Program Port Security Grant Program ALN# 97.056 Federal Agency Department of Homeland Security – Direct Award Federal Award Year 2020, 2021, 2022 and 2023 Grant Number EMW-2022-PU-00022 – IJ#1, IJ#2, EMW-2023-PU-00164 – IJ#1, IJ#2, IJ#3, IJ#4 EMW-2024-PU-05541 – IJ#4 Questioned Costs None Criteria - Federal rules require grant recipients to request reimbursement from the federal government soon after paying expenses, rather than holding costs for long periods. They also require financial reports to be accurate, up to date, and complete. To meet these standards, timely reporting must be supported by timely reimbursement requests so that the reports truly reflect the District’s financial activity. Condition - Although the District submitted the required SF-425 Federal Financial Reports on a timely basis, it did not submit requests for reimbursement timely. Repeatedly, reimbursements were requested nine to twelve months after expenditures were incurred, creating cash flow inefficiencies and increasing risk of misreporting. The total value of these requests were $661,577 Cause - The District failed to establish and implement adequate procedures to ensure reimbursement requests were submitted in coordination with actual cash outflows. This control weakness reflects insufficient oversight of cash management practices and resulted in noncompliance with federal requirements for timely reimbursement.Effect - Delayed reimbursement requests reduce cash management efficiency and create potential inconsistencies between reporting and drawdown activity. Recommendation - The District must establish and enforce policies mandating that reimbursement requests be submitted promptly after vendor payments are made. The District must reconcile reimbursement activity with SF-425 reporting to ensure that expenditures are accurately, timely, and consistently reflected in financial reports submitted to FEMA, in compliance with 2 CFR 200.305 and 2 CFR 200.328
Condition and Context: The County does not have a complete set of written cash management policies and procedures as required by the Uniform Guidance. The lack of written procedures did not result in any material noncompliance, fraud or abuse with respect to the major program. Criteria: The Uniform Guidance requires Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, to follow the cash management standards set out at 2 CFR section 200.305. The County must have a complete set of written cash management policies, which conform to applicable Federal statutes and the cash management requirements identified in 2 CFR part 200. Cause: The County was unaware of the written cash management policy requirements required by the Uniform Guidance. Effect: An important component of internal controls is the existence of operating policies and procedures and that they are clearly understood and communicated. Without clear written policies and procedures, there is a higher risk of noncompliance with program requirements. Recommendation: Management should determine the scope of written policies needed for compliance with all federal programs and develop policies and procedures to comply with the Uniform Guidance. Grantee Response: Management agrees with the finding and recommendation. The County’s existing policies are currently under review by management and staff to determine what updates/changes are necessary in order to meet the Uniform Guidance requirements. Once any updates/changes are drafted, the policy will be presented to the Governing Body for review and approval.
Finding 2025-001: Cash Management (Material Weakness) Federal Program: Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease (Ryan White Part C). [93.918] Federal Agency: U.S. Department of Health and Human Services (HHS) Criteria: Effective internal controls require an entity to have a financial management system that provides accurate, current, and complete disclosure of the financial results of a federally assisted project (2 CFR § 200.302). Drawdown requests must be based on actual incurred expenditures and be properly reviewed for accuracy before submission to minimize the time between draw and disbursement (2 CFR § 200.305). Additionally, the entity must maintain records that adequately identify the source and application of funds for all federally assisted activities (2 CFR § 200.333). Condition: During our audit of the financial management system and cash management practices for the Ryan White Federal Program, we identified the following deficiencies: Transposed Drawdown Amount: A drawdown request submitted to the PMS system for the Ryan White Program had the requested amount transposed with the amount of another federal program. This resulted in an over-request of a material amount on the Ryan White Program. Duplicate Invoice Reimbursement: An invoice was requested and received for reimbursement on a prior drawdown and was subsequently included again in a draw after year-end, resulting in a duplicate reimbursement. Incomplete Expenditure Tracking: The entity did not have a complete system for tracking all expenditures eligible for reimbursement. The drawdown process was limited to cash disbursement and payroll transactions and excluded expenditures incurred and recorded by journal entries. This resulted in the entity having unreimbursed expenditures that could have offset the over-requests noted above. Questioned Costs: $252,567 The questioned costs consist of the material amount over-requested in the transposed drawdown and the duplicate reimbursement of the previously paid invoice. A detailed breakdown is as follows: Over-requested amount due to transposed data: $150,516 Duplicate reimbursement for invoice submitted twice: $102,051 Cause: The organization's internal controls over the cash management and drawdown request process were inadequate. Specifically, there was a lack of a formal review and approval process to verify the accuracy and completeness of drawdown requests before they were submitted. Effect: The deficiencies in internal control led to material noncompliance with federal regulations related to financial management and cash management. This resulted in the entity holding federal funds in excess of immediate needs, which is a violation of the terms and conditions of the federal award. The inadequate financial management system also prevented the entity from accurately tracking and requesting all eligible expenditures, which could have helped offset the over-draws. Context: This is a systemic finding. Repeat Finding: No. This is the first time this specific finding has been identified. Recommendation: The entity should implement robust internal controls to ensure all drawdown requests are reviewed and approved by a second person with authority. A reconciliation of expenditures to the general ledger should be performed before each drawdown to ensure all eligible costs are included and that no duplicate requests are made. The entity’s cash management policies and procedures should be updated to address these deficiencies and ensure compliance with federal requirements. Management Response: The organization acknowledges and we are committed to remediation. To correct the deficiency, we are implementing a plan focused on establishing a review and approval process for all drawdown requests and revising our policies to ensure that all eligible incurred expenditures are properly captured and reconciled, thereby assuring strict compliance with federal cash management regulations and preventing federal funds from exceeding our immediate needs.
Condition and Context: The County does not have a complete set of written cash management policies and procedures required by the Uniform Guidance. The lack of written procedures did not result in any material noncompliance, fraud or abuse with respect to the major program. Criteria: The Uniform Guidance requires Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the cash management standards set out at 2 CFR section 200.305. They must have a complete set of written cash management policies, which conform to applicable Federal statutes and the cash management requirements identified in 2 CFR part 200. Cause: The County was unaware of the written cash management policy requirements required by the Uniform Guidance. Effect: An important component of internal controls is the existence of operating policies and procedures and that they are clearly understood and communicated. Without clear written policies and procedures, there is a higher risk of noncompliance with program requirements. Recommendation: Management should determine the scope of written policies needed for compliance with all federal programs and develop policies and procedures to comply with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and recommendation. The County’s existing policies are currently under review by management and staff to determine what updates/changes are necessary in order to meet the Uniform Guidance requirements. Once any updates/changes are drafted, the policy will be presented to the Governing Body for review and approval.
Criteria or specific requirement: 2 CFR section 200.305(b)(1) requires that an entity 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 be minimized. 2 CFR section 200.305 (b)(3) states the pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the request is believed to be improper. Condition: 5 out of 18 total billings sampled were not paid timely. Questioned costs: None. Context: During our testing of subrecipient payments, 5 out of the 18 billings sampled were not paid within 30 calendar days to the subrecipient after the billing was submitted for payment. Cause: Policies and procedures were not in place to ensure timely payments of subrecipient billings. Effect: Subrecipients received payments a significant amount of time after expenditures have been incurred. Repeat Finding: Yes. Recommendation: We recommend that the Organization implement policies and procedures to ensure subrecipients are paid within 30 days of when the billing is received. If the request is believed to be improper, support for the delay in payment should be maintained. Views of responsible officials: There is no disagreement with the audit finding.
Cash Management Federal Department – U.S. Department of Justice Pass-through Illinois Criminal Justice Information Authority Federal Award Identification Number and Year: 15JOVW-21-GG-00543-STOP and 2021 15JOVW-22-GG-00422-STOP and 2022 Violence Against Women Formula Grants, Federal Assistance Listing #16.588 County Department – State’s Attorney Office Finding 2024 – 001 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.305 Federal Payment (b)(3) Payments for recipients and subrecipients other than States requires that, “Reimbursement is preferred when the requirements in paragraph (b) cannot be met, when the Federal agency or pass-through entity sets a specific condition per Section 200.208, when requested by the recipient or subrecipient, when a Federal award is for construction, or when a significant portion of the construction project is accomplished through private market financing or Federal loans and the Federal award constitutes a minor portion of the project. 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.” CONDITION During the current audit period, the Cook County State’s Attorney Office (SAO) did not adequately comply with its cash management requirements in accordance with federal regulations. CAUSE Based on discussions with management, a portion of the late payments resulted from the SAO’s Program Managers being unable to provide sufficient documentation demonstrating that the delays were due to late invoice submissions by subrecipients. As a result, the Auditor could not verify whether the non-compliance was attributable to subrecipient actions. The remaining delays were due to weaknesses in the payment processing system, which relied heavily on email communications between involved parties. These emails, initiated by the Accounts Payable Processor, were not acted upon in a timely manner, resulting in payments being processed well over the thirty (30) days after initial submission. EFFECT The failure to pay each subrecipient for allowable costs within 30 days after receiving the subrecipient’s billing or payment request is a violation of federal regulations. This could impact the subrecipient’s ability to adequately perform its programmatic responsibilities under the program. QUESTIONED COSTS None. CONTEXT During our test of 29 subrecipients’ expenditures, we noted 17 instances where payments to the subrecipients’ were not made within 30 days after receipt of the subrecipient’s payment request. The payments were submitted late, ranging from 2 to 313 days late. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend that SAO develop and implement procedures to ensure payments to subrecipients are made within 30 days after receipt of the subrecipients billing or payment request, as required. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County’s corrective action plan is on page 38.
Finding: 2024-007 Cash Management – Federal Grants Federal Programs: Department of Health and Human Services Health Center Program Cluster Assistance Listing No. - 93.224 and 93.527 Criteria: Cash Management, 2 CFR 200.305(b)(1) Condition: Due to staff turnover, the Organization was unable to immediately provide proper documentation to support the fact that qualifying expenditures were made prior to making certain drawdowns of federal funds. No grant draws exceeded the cash needs for grant-related expenditures. However, failure to reconcile expenditures to federal grant draws, and failure to maintain such documentation, could result in advance draws. Cause: The Organization did not maintain proper documentation of expenditures to support the drawdowns made, Effect: Without proper controls over the reconciliation of expenditures to federal grant draws, drawdowns may occur for the incorrect amount, for the wrong period, and for costs that may not have been incurred. Questioned Costs: None reported. Context/Sampling: The finding appears to be a systemic issue. Repeat Finding from Prior Year: No Recommendation: It is recommended that management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented. Views of Responsible Officials: The Organization understands the requirements to document expenditures prior to drawing down federal funds. Procedures will be established to ensure that federal grant expenditures are documented so that advance draws of federal funds do not occur. Contact Person: Suzanne Freeman, CEO Anticipated Date of Completion: October 31, 2025
Finding: 2024-007 Cash Management – Federal Grants Federal Programs: Department of Health and Human Services Health Center Program Cluster Assistance Listing No. - 93.224 and 93.527 Criteria: Cash Management, 2 CFR 200.305(b)(1) Condition: Due to staff turnover, the Organization was unable to immediately provide proper documentation to support the fact that qualifying expenditures were made prior to making certain drawdowns of federal funds. No grant draws exceeded the cash needs for grant-related expenditures. However, failure to reconcile expenditures to federal grant draws, and failure to maintain such documentation, could result in advance draws. Cause: The Organization did not maintain proper documentation of expenditures to support the drawdowns made, Effect: Without proper controls over the reconciliation of expenditures to federal grant draws, drawdowns may occur for the incorrect amount, for the wrong period, and for costs that may not have been incurred. Questioned Costs: None reported. Context/Sampling: The finding appears to be a systemic issue. Repeat Finding from Prior Year: No Recommendation: It is recommended that management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented. Views of Responsible Officials: The Organization understands the requirements to document expenditures prior to drawing down federal funds. Procedures will be established to ensure that federal grant expenditures are documented so that advance draws of federal funds do not occur. Contact Person: Suzanne Freeman, CEO Anticipated Date of Completion: October 31, 2025
Finding: 2024-007 Cash Management – Federal Grants Federal Programs: Department of Health and Human Services Health Center Program Cluster Assistance Listing No. - 93.224 and 93.527 Criteria: Cash Management, 2 CFR 200.305(b)(1) Condition: Due to staff turnover, the Organization was unable to immediately provide proper documentation to support the fact that qualifying expenditures were made prior to making certain drawdowns of federal funds. No grant draws exceeded the cash needs for grant-related expenditures. However, failure to reconcile expenditures to federal grant draws, and failure to maintain such documentation, could result in advance draws. Cause: The Organization did not maintain proper documentation of expenditures to support the drawdowns made, Effect: Without proper controls over the reconciliation of expenditures to federal grant draws, drawdowns may occur for the incorrect amount, for the wrong period, and for costs that may not have been incurred. Questioned Costs: None reported. Context/Sampling: The finding appears to be a systemic issue. Repeat Finding from Prior Year: No Recommendation: It is recommended that management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented. Views of Responsible Officials: The Organization understands the requirements to document expenditures prior to drawing down federal funds. Procedures will be established to ensure that federal grant expenditures are documented so that advance draws of federal funds do not occur. Contact Person: Suzanne Freeman, CEO Anticipated Date of Completion: October 31, 2025
Finding: 2024-007 Cash Management – Federal Grants Federal Programs: Department of Health and Human Services Health Center Program Cluster Assistance Listing No. - 93.224 and 93.527 Criteria: Cash Management, 2 CFR 200.305(b)(1) Condition: Due to staff turnover, the Organization was unable to immediately provide proper documentation to support the fact that qualifying expenditures were made prior to making certain drawdowns of federal funds. No grant draws exceeded the cash needs for grant-related expenditures. However, failure to reconcile expenditures to federal grant draws, and failure to maintain such documentation, could result in advance draws. Cause: The Organization did not maintain proper documentation of expenditures to support the drawdowns made, Effect: Without proper controls over the reconciliation of expenditures to federal grant draws, drawdowns may occur for the incorrect amount, for the wrong period, and for costs that may not have been incurred. Questioned Costs: None reported. Context/Sampling: The finding appears to be a systemic issue. Repeat Finding from Prior Year: No Recommendation: It is recommended that management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented. Views of Responsible Officials: The Organization understands the requirements to document expenditures prior to drawing down federal funds. Procedures will be established to ensure that federal grant expenditures are documented so that advance draws of federal funds do not occur. Contact Person: Suzanne Freeman, CEO Anticipated Date of Completion: October 31, 2025
2024 – 004 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038; 24-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds; interest should also be calculated on amounts of unearned revenue. Effective internal controls should include procedures that involve reimbursement requests being reviewed and approved prior to submission. Condition: There were instances in which reimbursement requests did not agree to the County’s accounting records or to the amounts reported on the SEFA. The time between receiving and disbursing federal funds was not minimized, and interest on unearned revenue was not calculated. Furthermore, reimbursement requests were not reviewed and approved prior to submission, and documentation of such review was not retained. Questioned Costs: $132,322 Context: 2 of 8 reimbursement requests tested did not have supporting documentation for the exact amount received. All 8 reimbursement requests tested lacked documentation of review and approval prior to submission. Cause: Supporting documentation for reimbursement requests was not complete; specifically, adjustments made to the project accounting records after the reimbursement requests were submitted caused the County to receive more funds than expenditures incurred on specific grants. Documentation of review and approval for reimbursement requests was also not retained. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 004 Cash Management (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-006. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to reimbursement requests and that supporting documentation is retained. Reconciliations should be reviewed and approved by an individual other than the preparer prior to submission, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 004 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038; 24-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds; interest should also be calculated on amounts of unearned revenue. Effective internal controls should include procedures that involve reimbursement requests being reviewed and approved prior to submission. Condition: There were instances in which reimbursement requests did not agree to the County’s accounting records or to the amounts reported on the SEFA. The time between receiving and disbursing federal funds was not minimized, and interest on unearned revenue was not calculated. Furthermore, reimbursement requests were not reviewed and approved prior to submission, and documentation of such review was not retained. Questioned Costs: $132,322 Context: 2 of 8 reimbursement requests tested did not have supporting documentation for the exact amount received. All 8 reimbursement requests tested lacked documentation of review and approval prior to submission. Cause: Supporting documentation for reimbursement requests was not complete; specifically, adjustments made to the project accounting records after the reimbursement requests were submitted caused the County to receive more funds than expenditures incurred on specific grants. Documentation of review and approval for reimbursement requests was also not retained. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 004 Cash Management (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-006. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to reimbursement requests and that supporting documentation is retained. Reconciliations should be reviewed and approved by an individual other than the preparer prior to submission, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 004 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038; 24-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds; interest should also be calculated on amounts of unearned revenue. Effective internal controls should include procedures that involve reimbursement requests being reviewed and approved prior to submission. Condition: There were instances in which reimbursement requests did not agree to the County’s accounting records or to the amounts reported on the SEFA. The time between receiving and disbursing federal funds was not minimized, and interest on unearned revenue was not calculated. Furthermore, reimbursement requests were not reviewed and approved prior to submission, and documentation of such review was not retained. Questioned Costs: $132,322 Context: 2 of 8 reimbursement requests tested did not have supporting documentation for the exact amount received. All 8 reimbursement requests tested lacked documentation of review and approval prior to submission. Cause: Supporting documentation for reimbursement requests was not complete; specifically, adjustments made to the project accounting records after the reimbursement requests were submitted caused the County to receive more funds than expenditures incurred on specific grants. Documentation of review and approval for reimbursement requests was also not retained. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 004 Cash Management (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-006. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to reimbursement requests and that supporting documentation is retained. Reconciliations should be reviewed and approved by an individual other than the preparer prior to submission, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 004 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038; 24-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds; interest should also be calculated on amounts of unearned revenue. Effective internal controls should include procedures that involve reimbursement requests being reviewed and approved prior to submission. Condition: There were instances in which reimbursement requests did not agree to the County’s accounting records or to the amounts reported on the SEFA. The time between receiving and disbursing federal funds was not minimized, and interest on unearned revenue was not calculated. Furthermore, reimbursement requests were not reviewed and approved prior to submission, and documentation of such review was not retained. Questioned Costs: $132,322 Context: 2 of 8 reimbursement requests tested did not have supporting documentation for the exact amount received. All 8 reimbursement requests tested lacked documentation of review and approval prior to submission. Cause: Supporting documentation for reimbursement requests was not complete; specifically, adjustments made to the project accounting records after the reimbursement requests were submitted caused the County to receive more funds than expenditures incurred on specific grants. Documentation of review and approval for reimbursement requests was also not retained. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 004 Cash Management (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-006. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to reimbursement requests and that supporting documentation is retained. Reconciliations should be reviewed and approved by an individual other than the preparer prior to submission, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 004 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038; 24-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds; interest should also be calculated on amounts of unearned revenue. Effective internal controls should include procedures that involve reimbursement requests being reviewed and approved prior to submission. Condition: There were instances in which reimbursement requests did not agree to the County’s accounting records or to the amounts reported on the SEFA. The time between receiving and disbursing federal funds was not minimized, and interest on unearned revenue was not calculated. Furthermore, reimbursement requests were not reviewed and approved prior to submission, and documentation of such review was not retained. Questioned Costs: $132,322 Context: 2 of 8 reimbursement requests tested did not have supporting documentation for the exact amount received. All 8 reimbursement requests tested lacked documentation of review and approval prior to submission. Cause: Supporting documentation for reimbursement requests was not complete; specifically, adjustments made to the project accounting records after the reimbursement requests were submitted caused the County to receive more funds than expenditures incurred on specific grants. Documentation of review and approval for reimbursement requests was also not retained. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 004 Cash Management (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-006. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to reimbursement requests and that supporting documentation is retained. Reconciliations should be reviewed and approved by an individual other than the preparer prior to submission, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
Cash Management Federal Department – U.S. Department of Justice Pass-through Illinois Criminal Justice Information Authority Federal Award Identification Number and Year: 15JOVW-21-GG-00543-STOP and 2021 15JOVW-22-GG-00422-STOP and 2022 Violence Against Women Formula Grants, Federal Assistance Listing #16.588 County Department – State’s Attorney Office Finding 2024 – 001 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.305 Federal Payment (b)(3) Payments for recipients and subrecipients other than States requires that, “Reimbursement is preferred when the requirements in paragraph (b) cannot be met, when the Federal agency or pass-through entity sets a specific condition per Section 200.208, when requested by the recipient or subrecipient, when a Federal award is for construction, or when a significant portion of the construction project is accomplished through private market financing or Federal loans and the Federal award constitutes a minor portion of the project. 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.” CONDITION During the current audit period, the Cook County State’s Attorney Office (SAO) did not adequately comply with its cash management requirements in accordance with federal regulations. CAUSE Based on discussions with management, a portion of the late payments resulted from the SAO’s Program Managers being unable to provide sufficient documentation demonstrating that the delays were due to late invoice submissions by subrecipients. As a result, the Auditor could not verify whether the non-compliance was attributable to subrecipient actions. The remaining delays were due to weaknesses in the payment processing system, which relied heavily on email communications between involved parties. These emails, initiated by the Accounts Payable Processor, were not acted upon in a timely manner, resulting in payments being processed well over the thirty (30) days after initial submission. EFFECT The failure to pay each subrecipient for allowable costs within 30 days after receiving the subrecipient’s billing or payment request is a violation of federal regulations. This could impact the subrecipient’s ability to adequately perform its programmatic responsibilities under the program. QUESTIONED COSTS None. CONTEXT During our test of 29 subrecipients’ expenditures, we noted 17 instances where payments to the subrecipients’ were not made within 30 days after receipt of the subrecipient’s payment request. The payments were submitted late, ranging from 2 to 313 days late. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend that SAO develop and implement procedures to ensure payments to subrecipients are made within 30 days after receipt of the subrecipients billing or payment request, as required. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County’s corrective action plan is on page 38.
Finding: 2024-007 Cash Management – Federal Grants Federal Programs: Department of Health and Human Services Health Center Program Cluster Assistance Listing No. - 93.224 and 93.527 Criteria: Cash Management, 2 CFR 200.305(b)(1) Condition: Due to staff turnover, the Organization was unable to immediately provide proper documentation to support the fact that qualifying expenditures were made prior to making certain drawdowns of federal funds. No grant draws exceeded the cash needs for grant-related expenditures. However, failure to reconcile expenditures to federal grant draws, and failure to maintain such documentation, could result in advance draws. Cause: The Organization did not maintain proper documentation of expenditures to support the drawdowns made, Effect: Without proper controls over the reconciliation of expenditures to federal grant draws, drawdowns may occur for the incorrect amount, for the wrong period, and for costs that may not have been incurred. Questioned Costs: None reported. Context/Sampling: The finding appears to be a systemic issue. Repeat Finding from Prior Year: No Recommendation: It is recommended that management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented. Views of Responsible Officials: The Organization understands the requirements to document expenditures prior to drawing down federal funds. Procedures will be established to ensure that federal grant expenditures are documented so that advance draws of federal funds do not occur. Contact Person: Suzanne Freeman, CEO Anticipated Date of Completion: October 31, 2025
Finding: 2024-007 Cash Management – Federal Grants Federal Programs: Department of Health and Human Services Health Center Program Cluster Assistance Listing No. - 93.224 and 93.527 Criteria: Cash Management, 2 CFR 200.305(b)(1) Condition: Due to staff turnover, the Organization was unable to immediately provide proper documentation to support the fact that qualifying expenditures were made prior to making certain drawdowns of federal funds. No grant draws exceeded the cash needs for grant-related expenditures. However, failure to reconcile expenditures to federal grant draws, and failure to maintain such documentation, could result in advance draws. Cause: The Organization did not maintain proper documentation of expenditures to support the drawdowns made, Effect: Without proper controls over the reconciliation of expenditures to federal grant draws, drawdowns may occur for the incorrect amount, for the wrong period, and for costs that may not have been incurred. Questioned Costs: None reported. Context/Sampling: The finding appears to be a systemic issue. Repeat Finding from Prior Year: No Recommendation: It is recommended that management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented. Views of Responsible Officials: The Organization understands the requirements to document expenditures prior to drawing down federal funds. Procedures will be established to ensure that federal grant expenditures are documented so that advance draws of federal funds do not occur. Contact Person: Suzanne Freeman, CEO Anticipated Date of Completion: October 31, 2025
Finding: 2024-007 Cash Management – Federal Grants Federal Programs: Department of Health and Human Services Health Center Program Cluster Assistance Listing No. - 93.224 and 93.527 Criteria: Cash Management, 2 CFR 200.305(b)(1) Condition: Due to staff turnover, the Organization was unable to immediately provide proper documentation to support the fact that qualifying expenditures were made prior to making certain drawdowns of federal funds. No grant draws exceeded the cash needs for grant-related expenditures. However, failure to reconcile expenditures to federal grant draws, and failure to maintain such documentation, could result in advance draws. Cause: The Organization did not maintain proper documentation of expenditures to support the drawdowns made, Effect: Without proper controls over the reconciliation of expenditures to federal grant draws, drawdowns may occur for the incorrect amount, for the wrong period, and for costs that may not have been incurred. Questioned Costs: None reported. Context/Sampling: The finding appears to be a systemic issue. Repeat Finding from Prior Year: No Recommendation: It is recommended that management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented. Views of Responsible Officials: The Organization understands the requirements to document expenditures prior to drawing down federal funds. Procedures will be established to ensure that federal grant expenditures are documented so that advance draws of federal funds do not occur. Contact Person: Suzanne Freeman, CEO Anticipated Date of Completion: October 31, 2025
Finding: 2024-007 Cash Management – Federal Grants Federal Programs: Department of Health and Human Services Health Center Program Cluster Assistance Listing No. - 93.224 and 93.527 Criteria: Cash Management, 2 CFR 200.305(b)(1) Condition: Due to staff turnover, the Organization was unable to immediately provide proper documentation to support the fact that qualifying expenditures were made prior to making certain drawdowns of federal funds. No grant draws exceeded the cash needs for grant-related expenditures. However, failure to reconcile expenditures to federal grant draws, and failure to maintain such documentation, could result in advance draws. Cause: The Organization did not maintain proper documentation of expenditures to support the drawdowns made, Effect: Without proper controls over the reconciliation of expenditures to federal grant draws, drawdowns may occur for the incorrect amount, for the wrong period, and for costs that may not have been incurred. Questioned Costs: None reported. Context/Sampling: The finding appears to be a systemic issue. Repeat Finding from Prior Year: No Recommendation: It is recommended that management consider developing a contingency plan for when there is turnover in key personnel involved with the drawdown process of federal grants. As part of this plan, if changes need to occur to the primary internal control over drawdowns, those changes should be documented. Views of Responsible Officials: The Organization understands the requirements to document expenditures prior to drawing down federal funds. Procedures will be established to ensure that federal grant expenditures are documented so that advance draws of federal funds do not occur. Contact Person: Suzanne Freeman, CEO Anticipated Date of Completion: October 31, 2025
2024 – 004 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038; 24-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds; interest should also be calculated on amounts of unearned revenue. Effective internal controls should include procedures that involve reimbursement requests being reviewed and approved prior to submission. Condition: There were instances in which reimbursement requests did not agree to the County’s accounting records or to the amounts reported on the SEFA. The time between receiving and disbursing federal funds was not minimized, and interest on unearned revenue was not calculated. Furthermore, reimbursement requests were not reviewed and approved prior to submission, and documentation of such review was not retained. Questioned Costs: $132,322 Context: 2 of 8 reimbursement requests tested did not have supporting documentation for the exact amount received. All 8 reimbursement requests tested lacked documentation of review and approval prior to submission. Cause: Supporting documentation for reimbursement requests was not complete; specifically, adjustments made to the project accounting records after the reimbursement requests were submitted caused the County to receive more funds than expenditures incurred on specific grants. Documentation of review and approval for reimbursement requests was also not retained. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 004 Cash Management (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-006. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to reimbursement requests and that supporting documentation is retained. Reconciliations should be reviewed and approved by an individual other than the preparer prior to submission, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 004 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038; 24-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds; interest should also be calculated on amounts of unearned revenue. Effective internal controls should include procedures that involve reimbursement requests being reviewed and approved prior to submission. Condition: There were instances in which reimbursement requests did not agree to the County’s accounting records or to the amounts reported on the SEFA. The time between receiving and disbursing federal funds was not minimized, and interest on unearned revenue was not calculated. Furthermore, reimbursement requests were not reviewed and approved prior to submission, and documentation of such review was not retained. Questioned Costs: $132,322 Context: 2 of 8 reimbursement requests tested did not have supporting documentation for the exact amount received. All 8 reimbursement requests tested lacked documentation of review and approval prior to submission. Cause: Supporting documentation for reimbursement requests was not complete; specifically, adjustments made to the project accounting records after the reimbursement requests were submitted caused the County to receive more funds than expenditures incurred on specific grants. Documentation of review and approval for reimbursement requests was also not retained. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 004 Cash Management (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-006. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to reimbursement requests and that supporting documentation is retained. Reconciliations should be reviewed and approved by an individual other than the preparer prior to submission, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 004 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038; 24-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds; interest should also be calculated on amounts of unearned revenue. Effective internal controls should include procedures that involve reimbursement requests being reviewed and approved prior to submission. Condition: There were instances in which reimbursement requests did not agree to the County’s accounting records or to the amounts reported on the SEFA. The time between receiving and disbursing federal funds was not minimized, and interest on unearned revenue was not calculated. Furthermore, reimbursement requests were not reviewed and approved prior to submission, and documentation of such review was not retained. Questioned Costs: $132,322 Context: 2 of 8 reimbursement requests tested did not have supporting documentation for the exact amount received. All 8 reimbursement requests tested lacked documentation of review and approval prior to submission. Cause: Supporting documentation for reimbursement requests was not complete; specifically, adjustments made to the project accounting records after the reimbursement requests were submitted caused the County to receive more funds than expenditures incurred on specific grants. Documentation of review and approval for reimbursement requests was also not retained. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 004 Cash Management (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-006. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to reimbursement requests and that supporting documentation is retained. Reconciliations should be reviewed and approved by an individual other than the preparer prior to submission, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 004 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038; 24-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds; interest should also be calculated on amounts of unearned revenue. Effective internal controls should include procedures that involve reimbursement requests being reviewed and approved prior to submission. Condition: There were instances in which reimbursement requests did not agree to the County’s accounting records or to the amounts reported on the SEFA. The time between receiving and disbursing federal funds was not minimized, and interest on unearned revenue was not calculated. Furthermore, reimbursement requests were not reviewed and approved prior to submission, and documentation of such review was not retained. Questioned Costs: $132,322 Context: 2 of 8 reimbursement requests tested did not have supporting documentation for the exact amount received. All 8 reimbursement requests tested lacked documentation of review and approval prior to submission. Cause: Supporting documentation for reimbursement requests was not complete; specifically, adjustments made to the project accounting records after the reimbursement requests were submitted caused the County to receive more funds than expenditures incurred on specific grants. Documentation of review and approval for reimbursement requests was also not retained. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 004 Cash Management (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-006. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to reimbursement requests and that supporting documentation is retained. Reconciliations should be reviewed and approved by an individual other than the preparer prior to submission, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
2024 – 004 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: G-2302ILLIEA 6/1/2023; G-2302ILLIEA 10/1/2022 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 23-221038; 23-274038; 23-224038; 24-224038 Award Period: June 1, 2023 through September 30, 2024; October 1, 2022 through August 31, 2024 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.305(b)) requires non-federal entities to minimize the time between drawing and disbursing of federal funds; interest should also be calculated on amounts of unearned revenue. Effective internal controls should include procedures that involve reimbursement requests being reviewed and approved prior to submission. Condition: There were instances in which reimbursement requests did not agree to the County’s accounting records or to the amounts reported on the SEFA. The time between receiving and disbursing federal funds was not minimized, and interest on unearned revenue was not calculated. Furthermore, reimbursement requests were not reviewed and approved prior to submission, and documentation of such review was not retained. Questioned Costs: $132,322 Context: 2 of 8 reimbursement requests tested did not have supporting documentation for the exact amount received. All 8 reimbursement requests tested lacked documentation of review and approval prior to submission. Cause: Supporting documentation for reimbursement requests was not complete; specifically, adjustments made to the project accounting records after the reimbursement requests were submitted caused the County to receive more funds than expenditures incurred on specific grants. Documentation of review and approval for reimbursement requests was also not retained. Effect: Lack of proper documentation and reconciliation can result in over- or under-reimbursement of federal grant funds, potentially leading to noncompliance with federal requirements and potential repayment obligations. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2024 – 004 Cash Management (Continued) Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-006. Recommendation: We recommend that the County design and implement internal controls to ensure accounting records reconcile to reimbursement requests and that supporting documentation is retained. Reconciliations should be reviewed and approved by an individual other than the preparer prior to submission, and documentation of such review should be retained. Views of Responsible Officials: There is no disagreement with the audit finding.
Cash Management Grantor: Department of Health and Human Services Pass Through Entity: Advanced Regenerative Manufacturing Institute, Inc. Award Name: Hospital Preparedness Program (HPP) Ebola Preparedness and Response Activities Award Number: IDSEP22005-003 Assistance Listing Number: 93.817 Award Year: June 1, 2023-September 30, 2023 Criteria In accordance with 2 CFR 200.305 (b)(3), reimbursement is the preferred method when the requirements in paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per 2 CFR 200.208, or when the non-Federal entity requests payment by reimbursement. In accordance with 2 CFR 200.334 (c) and (e), a subrecipient must liquidate all financial obligations incurred under a subaward no later than 90 calendar days after the conclusion of the period of performance of the subaward (or an earlier date as agreed upon by the pass-through entity and subrecipient). The subrecipient must promptly refund any unobligated funds that the pass-through entity paid and that are not authorized to be retained. Condition In testing the period of performance compliance requirement in accordance with the OMB Compliance Supplement, we requested support for the expenditures on the FY2024 Schedule of Federal Awards, as they were outside of the period of performance of the subaward, which ended September 30, 2023. The Company issued an invoice to Advanced Regenerative Manufacturing Institute, the Prime awardee, for $215,192 on September 14, 2023, but did not incur those expenses until after the period of performance of the subaward. Therefore, the Company requested and received the funds in advance of incurring the expenses. Further, the Company did not liquidate its obligations under the subaward within the required 90 calendar days after the conclusion of the performance of the subaward, as expenditures were recorded through August 2024. There were no terms in the award that allowed retention of unused funds. Cause The grant personnel were not aware of the invoicing requirements under the reimbursement method and invoiced the Prime awardee in advance of incurring the associated costs. Effect Federal funds were obtained in advance of incurring costs and outside of the period of performance of the subaward. Questioned Costs $215,192 Recommendation We recommend that the Company return the advance funds received to the Prime. Further, the Company should consider the need for clarifying and/or enhancing existing internal control procedures to ensure expenditures are paid in compliance with Federal reimbursement requirements and that requests for reimbursement are reviewed and validated against supporting documentation to identify any discrepancies prior to requesting reimbursement. Management’s Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
Finding 2024-008 – Cash Management (Material Weakness and Noncompliance) Information on the Federal Program: U.S. Department of Education, Higher Education- Institutional Aid, Assistance Listing No. 84.031Criteria: 2 CFR Part 200.305 establishes the methods of receiving payment from the federal agency. The College uses the reimbursement method to receive Title III funds. The non-federal entity is also required to design and implement internal controls over the cash management process. Condition: We selected 5 drawdowns for reimbursement made during the year for testing. For 4 drawdowns, there was no documentation of a review of the calculation of the amount to draw or approval to draw down the funds. Cause: The College did not have a review and approval process in place for 9 months of the fiscal year. Effect: The College’s grant reimbursements were not properly approved. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures over cash management to ensure controls are properly implemented and working effectively. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-001 – Cash Management (Material Weakness) Information on the Federal Program: U.S. Department of Education, Trio Cluster Criteria: 2 CFR 200.305 establishes the procedures for receiving federal payments. Non-federal entities must design and implement internal controls to ensure compliance with cash management requirements. Condition: We selected a sample of 24 reimbursement draw downs made during the year through the G5 payment system. Procedures were in place to accumulate expenses based on approved invoices and draw the reimbursement amount down through G5, however, documentation of review and approval of amounts to be drawn was not available. Cause: The College did not document the review and approval of the calculated reimbursement before it was drawn down. Effect: Key controls over cash management were not operating effectively. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures to properly design and implement controls over the draw down process. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-001 – Cash Management (Material Weakness) Information on the Federal Program: U.S. Department of Education, Trio Cluster Criteria: 2 CFR 200.305 establishes the procedures for receiving federal payments. Non-federal entities must design and implement internal controls to ensure compliance with cash management requirements. Condition: We selected a sample of 24 reimbursement draw downs made during the year through the G5 payment system. Procedures were in place to accumulate expenses based on approved invoices and draw the reimbursement amount down through G5, however, documentation of review and approval of amounts to be drawn was not available. Cause: The College did not document the review and approval of the calculated reimbursement before it was drawn down. Effect: Key controls over cash management were not operating effectively. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures to properly design and implement controls over the draw down process. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-001 – Cash Management (Material Weakness) Information on the Federal Program: U.S. Department of Education, Trio Cluster Criteria: 2 CFR 200.305 establishes the procedures for receiving federal payments. Non-federal entities must design and implement internal controls to ensure compliance with cash management requirements. Condition: We selected a sample of 24 reimbursement draw downs made during the year through the G5 payment system. Procedures were in place to accumulate expenses based on approved invoices and draw the reimbursement amount down through G5, however, documentation of review and approval of amounts to be drawn was not available. Cause: The College did not document the review and approval of the calculated reimbursement before it was drawn down. Effect: Key controls over cash management were not operating effectively. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures to properly design and implement controls over the draw down process. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-001 – Cash Management (Material Weakness) Information on the Federal Program: U.S. Department of Education, Trio Cluster Criteria: 2 CFR 200.305 establishes the procedures for receiving federal payments. Non-federal entities must design and implement internal controls to ensure compliance with cash management requirements. Condition: We selected a sample of 24 reimbursement draw downs made during the year through the G5 payment system. Procedures were in place to accumulate expenses based on approved invoices and draw the reimbursement amount down through G5, however, documentation of review and approval of amounts to be drawn was not available. Cause: The College did not document the review and approval of the calculated reimbursement before it was drawn down. Effect: Key controls over cash management were not operating effectively. Questioned Costs: None reported Recommendation: We recommend the College strengthen its policies and procedures to properly design and implement controls over the draw down process. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-014 – Cash Management (Significant Deficiency and Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health). Criteria: 2 CFR 200.305 establishes methods of receiving payment from federal agencies. 2 CFR 200.303 established that recipients must establish, document and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to the City's approved fiscal policies and procedures, drawdown reports/reimbursement requests must be approved by the grants department and accounting manager or CFO. Condition: The City drew the remaining balance on the Minority Health award during the year. Documentation of review and approval for the draw was not available. Cause: The City is experiencing turnovers and staffing challenges which have led to some gaps in following procedures. Effect: The City did not document proper controls in place over cash management. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen procedures to ensure it complies with its policies and procedures to ensure appropriate level of management is reviewing cash drawdown requests. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Assistance Listing Number: 66.468 Program Title: Capitalization Grants for Drinking Water Revolving Fund Pass-through Entity: Alabama Department of Environmental Management Contract Number and Year: FS010055.02 2022 Finding Type: Significant Deficiency Known Questioned Costs: None Criteria - 2 CFR Section 200.303(a) requires nonfederal entities receiving federal awards to establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. 2 CFR 200.305 Federal Payment requires nonfederal entities to establish written procedures to implement the requirements of cash management of federal funding. Condition - The Organization received federal funds prior to paying contractors and had no written procedures in place for appropriately handling those funds. Cause - The Organization has not developed or implemented written procedures for appropriately handling advance federal funds. Effect - Possible noncompliance with cash management requirements of the program. Recommendation - The Organization should develop, implement and comply with written procedures to meet the requirements of 2 CFR Section 200.303(a) and 2 CFR 200.305 Federal Payment. View of Responsible Officials - The General Manager has implemented policies and procedures so the Utilities Board of the City of Oneonta will not request advance payments. Payments to contractors will issue within 10 business days of receipt of approval from Project Engineer. In the event contractors can not be paid within 30 days, advanced funds received will be deposited into a designated insured interest bearing account until contractors are paid.
Item 2024-001 Uniform Guidance Written Policies, Procedures and Standards of Conduct U.S. Department of Treasury COVID-19 Coronavirus State and Local Fiscal Recovery Funds Listing #21.027 Year Ended September 30, 2024 Criteria – Grantees should have written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. 2 CFR 200, Subparts D & E requires the non-Federal entity to establish and maintain written policies, procedures, and standards of conduct including internal controls over the Federal awards that provides reasonable assurance that the non‐Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award. Specific requirements relate to the following: • § 200.302 Financial management • § 200.305 Payment Condition – The City does not have written policies, procedures and standards of conduct. Cause – The entity has failed to prepare written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. Questioned Costs – None noted Effect – Lack of written policies, procedures, and standards of conduct could result in noncompliance related to federal awards. Recommendation – We recommend that the Commission prepare written policies, procedures, and standards of conduct to include all the required elements as provided in 2 CFR 200, Subparts D & E of the Uniform Guidance. Management’s Response – The City is evaluating the auditor’s recommendations and will implement the necessary corrective action based on a cost benefit analysis.
Condition: During our audit, we noted the Agency did not comply with the cash management requirements for federal awards. Specifically, the Agency drew down federal funds in advance of immediate cash needs, resulting in excess cash balances being held for extended periods. Criteria: Under 2 CFR Part 200.305, non-federal entities must minimize the time elapsing between the transfer of funds from the U.S. Treasury and the disbursement of those funds for program purposes. Funds should be drawn down only as needed to meet immediate cash requirements. Cause: The Agency made periodic draws of federal awards without ensuring such draws were for immediate cash needs. Effect: Holding excess federal funds for extended periods can result in non-compliance with federal regulations, and could potentially increase the risk of mismanagement or misuse of funds. Recommendation: We recommend the Agency revise federal award cash draw procedures to ensure compliance with cash management requirements. Such draws should be made solely for immediate cash needs. Management Response: Management agrees with this finding and has begun implementing corrective actions. Such actions include implementing a process whereby federal draws are based on upcoming cash needs rather than periodic draws.
2024-001: CASH MANAGEMENT Type: Considered a significant deficiency in internal control over compliance/immaterial noncompliance Program: ALN 93.788 Opioid STR; grant number H79TI085750 ALN 93.959 Block Grants for Prevention and Treatment of Substance Abuse (SUD Block Grant); grant number B08TI085813 Criteria: As detailed by 2 CFR 200.305(b), “For recipients and subrecipients other than States, 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.” Condition: During testing, it was noted that cash was requested prior to disbursement of funds by a month or more. Cause/Effect: This condition appears to be the result of a misunderstanding of the cash management requirements by management. Questioned Cost: Immaterial Recommendation: We recommend that the CMHSP review its methods to ensure that cash requests are made for expenditures for which disbursement has been made.
2024-001: CASH MANAGEMENT Type: Considered a significant deficiency in internal control over compliance/immaterial noncompliance Program: ALN 93.788 Opioid STR; grant number H79TI085750 ALN 93.959 Block Grants for Prevention and Treatment of Substance Abuse (SUD Block Grant); grant number B08TI085813 Criteria: As detailed by 2 CFR 200.305(b), “For recipients and subrecipients other than States, 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.” Condition: During testing, it was noted that cash was requested prior to disbursement of funds by a month or more. Cause/Effect: This condition appears to be the result of a misunderstanding of the cash management requirements by management. Questioned Cost: Immaterial Recommendation: We recommend that the CMHSP review its methods to ensure that cash requests are made for expenditures for which disbursement has been made.
Item: 2024-001 Assistance Listing Number: 93.243 Program: Substance Abuse and Mental Health Services, Projects of Regional and National Significance Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: N/A Contract Number: 5H79TI082775-02 Award Year: 9/30/2023 – 9/29/2024 Compliance Requirement: Cash Management, Reporting Criteria: Per 2 CFR 200.305, under the reimbursement method, expenditures must be incurred prior to the date of the reimbursement request. The Organization is also responsible for submitting an annual Federal Financial Report (“FFR” or SF-425) to the U.S. Department of Health and Human Services, Substance Abuse and Mental Health Services Administration. Condition: The Organization erroneously included a duplicate request for reimbursement in a monthly reimbursement request report submitted to the granting agency and was overpaid by the amount of this duplicate request for reimbursement totaling $41,042. Additionally, the total expenditures reported in the FFR/SF-425 were misstated by $23,058. Questioned Costs: $41,042 Context: In our testing of the annual FFR/SF-425, we noted that the total expenditures reported did not agree to the expenditures reported on the Schedule of Expenditures of Federal Awards by $23,058. Upon further investigation and review of each monthly request for reimbursement submitted for fiscal 2024, we noted a duplicate reimbursement request totaling $41,042. Additionally, we noted that $17,984 representing an expense accrual at September 30, 2024, while properly reflected on the Schedule of Expenditures of Federal Awards, was not properly included in the detail of expenditures noted in the FFR/SF-425 for fiscal 2024. As a result, the FFR/SF-425 misreported expenditures by $23,058, the net of the two errors noted above. Effect: The duplicate federal draw request resulted in a duplicate payment from the grantor. Thus, the Organization has drawn federal funds in excess of the federal expenditures incurred totaling $41,042, which is reported as a questioned cost as the overpayment is due back to the granting agency. Additionally, the expenditures reported on the FFR/SF-425 for fiscal 2024 were misstated by $23,058. This is deemed to be a material weakness in internal control over compliance. Cause: Review and approval controls of the monthly reimbursement request and the annual FFR/SF-425 report were not operating effectively. Identification as a Repeat Finding: Not a repeat finding Recommendation: The Organization should ensure monthly requests for reimbursement and reviewed and approved prior to submission. Additionally, the annual FFR/SF-425 should be reviewed and reconciled to the monthly draws. Views of Responsible Officials: Management of the Organization concurs with the finding. See Corrective Action Plan.
Reportable Finding Considered a Material Weakness – Lack of Supporting Documentation for Cash Draws Program Name: Innovative Approaches to Literacy; Full-Service Community Schools; and Promise Neighborhood Assistance listing #: 84.215K Program year: 2024 Federal Awarding Agency: Department of Education Compliance requirement: Cash Management Criteria: According to 2 CFR 200.305(b)(4) – If the recipient or subrecipient cannot meet the criteria for advance payments, an advance payment for an initial period may be made, however, after that, the Federal agency or pass-through entity must reimburse the recipient or subrecipient for its actual cash disbursements. In addition, per 2 CFR 200.305(b)(9), the recipient or subrecipient must be able to account for all Federal funds received, obligated, and expended. Condition: During our testing of cash draws, it was noted that the reimbursement requests submitted for this award were not based on actual cash disbursements, lacked adequate documentation with no internal support retained that showed internal review and approval for the cash draws. Cause: Policies and internal controls over draw requests were not in place during the year, due in part to turnover in the positions that were in charge of approvals. Effect: The requests for reimbursement were not in line with actual expenses incurred during the draw period. Questioned costs: There are no questioned costs related to this finding. Repeat finding: This is not a repeat finding. Recommendation: We recommend that the Organization update their policies and procedures surrounding cash management to ensure that funds are drawn on a reimbursement basis, supported by actual expenditures incurred. Views of Responsible Officials and Corrective Action Plan (unaudited): See corrective action plan.
Finding 2024-001 Significant deficiency in internal controls over compliance and instances of noncompliance with cash management for subrecipients. Federal Agency: National Science Foundation Assistance Listing Number: 47.050 Assistance Listing Name: Geosciences Award Number: 2208081 Award Year: October 1, 2023 through September 30, 2024 Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards section 200.305(b)(3) requires that when the reimbursement method is used, the pass-through entity must make payment within 30-calendar days after receipt of the payment request unless the pass-through entity reasonably believes the request to be improper. Condition/Context for Evaluation During our testing, we noted that the Institute paid three subrecipient invoices beyond the 30-calendar day standard. The sample size was six selections. These subrecipients were under the reimbursement method for payment. Cause The Institute does not have an adequate system of internal control to ensure payments to subrecipients are disbursed within 30-calendar days after receiving the subrecipient’s request for reimbursement. Effect or Potential Effect The Institute is not in compliance with the requirements of 2 CFR section 200.305(b)(3). Payments to subrecipients were not made timely and exceed the 30-calendar day standard. Questioned Costs Not applicable. Repeat Finding This is not a repeat finding. Recommendation We recommend management update its system of internal controls to add processes in place that ensure payments to subrecipients are paid within 30 days after receipt of reimbursement request from the subrecipient. Views of Responsible Officials and Correct Action Management concurs with the finding and has provided the accompanying corrective action plan.
Finding 2024-001 Lack of Internal Controls over Cash Management Federal Agency: U.S. Department of the Treasury Federal Programs: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Numbers: 21.027 Award Number: SLFRP3171/4774 Award Years: 2021 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, which 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 Village’s cash balances for all governmental funds amounted to $8,470,564 at September 30, 2024. The unearned revenues were $8,727,660 which resulted in a shortfall of $257,096. The unearned revenue for the CSLFRF Program (ARPA Special Revenue Fund) was $269,930. Cause: Lack of internal controls over cash management. Effect: The Village requested and received advances for various federal programs to cover expenditures. Deposits were used to fund other programs of the Village. Questioned Costs: $257,096, which is the shortfall between cash and cash equivalent balance and the unearned revenue balance. Repeat Finding: This is a repeat of Finding 2023-001, and since this is a repeat finding we believe this to be a systemic issue. Recommendation: We recommend that the Village 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 and investments.