Finding 2023-002 – Cash Management – Subrecipient Payments Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of two subrecipient payments tested (50%), the College did not submit payment within 30 days after receipt of the billing from the subrecipient. Criteria Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. The College made payment to the subrecipient 105 days after receipt of the billing from the subrecipient. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Questioned Costs There were no questioned costs related to testing of subrecipient payments. Cause To ensure the College is fully monitoring both programmatic activities and financial compliance with Uniform Guidance cost principles of its subrecipients, the College’s internal control procedure requires signatures from the Principal Investigator (PI), Director of Resource Development, and the Manager of Grants Accounting and Compliance. Delays in the internal approval process caused the delay in payment of the sampled invoice. Prevalence Frequent. One out of two payments selected for testing. Effect Without proper program cash management policies and procedures, late subrecipient payments could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that payments to subrecipients minimize the time elapsing between transfer of federal funds from the pass-through entity to the subrecipient. Views of responsible officials We agree with this finding. See corrective action plan.
Finding 2023-002 – Cash Management – Subrecipient Payments Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of two subrecipient payments tested (50%), the College did not submit payment within 30 days after receipt of the billing from the subrecipient. Criteria Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. The College made payment to the subrecipient 105 days after receipt of the billing from the subrecipient. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Questioned Costs There were no questioned costs related to testing of subrecipient payments. Cause To ensure the College is fully monitoring both programmatic activities and financial compliance with Uniform Guidance cost principles of its subrecipients, the College’s internal control procedure requires signatures from the Principal Investigator (PI), Director of Resource Development, and the Manager of Grants Accounting and Compliance. Delays in the internal approval process caused the delay in payment of the sampled invoice. Prevalence Frequent. One out of two payments selected for testing. Effect Without proper program cash management policies and procedures, late subrecipient payments could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that payments to subrecipients minimize the time elapsing between transfer of federal funds from the pass-through entity to the subrecipient. Views of responsible officials We agree with this finding. See corrective action plan.
Identification of the federal program: Assistance Listing Number 93.958, Block Grants for Community Mental Health Services, United States Department of Health and Human Services. Criteria: Non-federal entities must minimize the time elapsing between the transfer of funds from the U.S. Treasury or pass through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). Condition: In one of three months selected for testing, we noted that the amount requested for reimbursement was greater than the expenses incurred resulting in an advance of federal funds. The overdraw was corrected over the subsequent two-month period. Cause: Management indicated that this error occurred due to a change in the budgeted indirect costs allowed for in year two vs. year one, and that resulted in an oversight in the calculation. Effect or potential effect: In one of three months tested, the amount overdrawn approximated $58,000 and the error was corrected over the subsequent two-month period. Questioned costs: not applicable. Context: In one of three months selected for testing, Bellefaire did receive an advance of federal funds. Management was able to provide supporting documentation which appeared to indicate that the error was corrected in the subsequent two-month period. Given the interest rate environment and the amount of time the advance was maintained, any interest income earned would be considered trivial. Recommendation: We recommend that existing policies and procedures be reviewed to ensure that reimbursement of federal funds is made within the required timeframe to minimize the time elapsing between the receipt of funds from the U.S. Treasury and disbursement. Views of responsible officials: Management concurs with this finding. See page 43 for corrective action.
Program: Coronavirus State and Local Fiscal Recovery Funds ALN #93.323 Program Requirement: Cash Management Criteria: Per 2 CFR 200.305, “non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or pass-through entity and the disbursement by the non-Federal Entity”. The non-Federal entity has cash on hand from federal funds, interest begins to accrue from the date of receipt of the drawdown and will be required to be remitted back to the federal government once the total aggregate amount of interest earned on federal grant awards equals $500. Condition: In accordance with 2 CFR 200.305 the District deposited federal grant funds into an interest bearing account. Interest earned on the federal funds exceeded $500. Context: The District received an allocation of Covid funding in FY 2022 but the funds were not expended until FY 2023. Cause: The District utilized the grant to purchase a HVAC Auto Cleaning air system which is subject to procurement and bid test work. With higher interest rates and the timing of the grant funds received and expended; interest accrued on the federal funds in excess of $500. Effect: At June 30, 2023, he District has accrued the interest payable to remit to the Department of Health and Human Services Payment Management System. Questioned Costs: No Repeat Finding: No Recommendation: The District needs to implement additional monitoring to ensure compliance with 2 CFR 200.305 and advances on federal funds. Views of Responsible Officials: The District agrees with the recommendation.
Program: Magnet Schools Assistance (Assistance Listing No. 84.165) Compliance Requirement – Cash Management Finding Type: Material Noncompliance / Material Weakness in Internal Controls over Compliance Criteria: 2 CFR Part 200.305 requires that for non-Federal entities other than states, payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. In addition, interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually through a Fedwire Funds Service payment. Condition: In March 2023, the District performed a drawdown of all available funding allocated to the Magnet Schools Assistance Program (MSAP). This drawdown included the entirety of the Year 1 program allocation, in addition to the entirety of the Year 2 program allocation for a total drawdown of $7,804,837. As of June 30, 2023, the District had expended $1,077,941 of these funds, leaving an excess drawdown of $6,726,896. Interest earned on these funds, to be returned to the federal government, totaled $20,791 as of June 30, 2023 and had not been recorded. Cause: The District failed to have an adequate documented system of internal controls in place surrounding the drawdown of funds for MSAP. Effect: The failure to properly monitor drawdowns and limit the time between drawdown and disbursement can result in program non-compliance and the loss of program funds altogether. In addition, excess drawdowns can lead to unnecessary federal interest being earned that would have to be returned. Auditor’s Recommendations: The District should implement internal control processes and monitoring to handle MSAP similar to other federal programs in the way it requests reimbursement and/or drawdown funds. Views of Responsible Official: The District will implement additional internal control procedures to require the MSAP Director complete a request for reimbursement based off general ledger expenditures similar to other federal programs at the District. In addition, the District will implement additional monitoring procedures to ensure requests for reimbursement are received and reflect general ledger transactions prior to performing any drawdown of federal funds.
2023-004: Cash Request Reimbursements Federal Asisstance Listing Number: 84.371 Compliance Area: Cash (c) Type of Finding: Significant Deficiency Questioned Costs: None Criteria: In accordance with 2 CFR subsection 200.305 the District should seek to minimize the time elapsing between expenditures and cash requests. The District should have written procedures addressing the timing of cash requests. Condition: We found that the District did not have written procedures addressing the timing of cash requests, furthermore we found the District was over twelve months behind in requesting grant funds. Identification as a repeat finding: No. Recommendation: The District should submit Federal cash drawdown requests on a monthly basis relating to the expenditures.
Cash Management for the Institutional Portion of the COVID-19 Education Stabilization Fund Type of Finding - Noncompliance with Cash Management compliance requirements and material weakness in internal control over compliance Program: COVID-19 Education Stabilization Fund Assistance Listing Number: Institutional Aid Portion 84.425F Federal Agency: U.S. Department of Education Criteria - 2 CFR section 200.305 requires recipients of Federal funds to minimize the time between drawing down funds from G5 and paying incurred obligations. The Certification and Agreement and/or the Supplemental Agreement published by the U.S. Department of Education pertaining to the Public and Nonprofit Institution Grant Funds identifies that funds not disbursed within three days of being drawn down may be subject to heightened scrutiny by the U.S. Department of Education, the institution’s auditors, and/or the Department’s Office of the Inspector General. Internal controls over compliance with direct and material compliance requirements should be sufficient to prevent or detect and correct material noncompliance in a timely manner. Condition - During testing of the cash management compliance requirements, it was noted that Sterling College was not compliant with cash management requirements. During the year ending June 30, 2023, the College drew Institutional Aid funds multiple times through the G5 system and did not disburse the funds within three calendar days of the drawdown. The College drew $80,035 on August 26, 2022. $47,835 of the amount that was drawn was not disbursed until September 1, 2022. The College drew $20,662 on November 2, 2022 which was not disbursed until January 18, 2023. Cause - A material weakness in internal control over compliance exists relating to cash management. Personnel responsible for maintaining compliance with cash management did not have sufficient education on the cash management requirements. In addition, there was no review over compliance with cash management requirements to monitor compliance. Effect - The College was not compliant with Federal requirements of the COVID-19 Education Stabilization Fund. Questioned Costs - There were no unspent funds as of June 30, 2023. Context - During the year ended June 30, 2023, the College drew a total of $257,405 in COVID-19 Education Stabilization Funds from the G5 system. $68,497 of the amount drawn during the year ended June 30, 2023 was not disbursed timely. Identification as a Repeat Finding - The College had similar findings for the year ended June 30, 2022 identified as findings 2022-001 and 2022-002. Recommendation - We recommend the College provide education to those responsible for compliance with the requirements and have an individual independent of the drawdown process review drawdown requests prior to execution to ensure the drawdowns will be expended in the appropriate time frame. Views of Responsible Official - Management concurs with the finding and is in the process of reviewing policies and procedures to comply with the requirements.
U.S. Department of Commerce Congressionally Identified Projects – 11.617 Award Number - 60NANB22D201 Criteria or Specific Requirement – Cash Management 2 CFR 200.305(b) of the compliance supplement requires organizations receiving federal funds to establish controls and procedures that would minimize the amount of time between drawdowns and disbursement of the funds. As required per the Department of Commerce Financial Assistance Standard Terms and Conditions, Section B, "Financial Requirements", paragraph .02.b1, advanced payments must be limited to immediate cash needs and must time advance payment requests so that Federal funds are on hand for a maximum of 30 calendar days before being disbursed by the non-Federal entity for allowable award costs. Condition – RI requested an advance payment in October 2022 for anticipated expenditures and did not expend all funding within the 30 day period. Questioned Costs – None noted. Context – We selected one drawdown for $1,000,000 out of three drawdowns totaling $3,000,000 during fiscal year 2023 for testing. During our testwork, we noted that a portion of the drawdown was not expended within the 30 day period following the receipt of the drawdown. The sample was not intended to be, and was not a statistically valid sample. Effect – RI did not comply with the 30 day period required for advanced payments. Cause – RI had issued purchase orders to vendors prior to advance payment request, but did not receive invoices from vendors for payment within the 30 day period and, as such, did not disburse funding. Identification as a Repeat Finding – Not applicable. Recommendation – We recommend RI only request advance payments up to the amount they are able to disburse within the required time in order to minimize the time elapsing between the receipt and disbursement of federal funds. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.
Program Name – Federal Transit Formula Grant and State of Good Repair Grant Assistance Listing Number – 20.507 and 20.525 Finding Type – Significant Deficiency and Non-Compliance Criteria – In accordance with 2CFR section 200.305(b) of the OMB compliance supplement, non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Condition – During our audit we noted that the federal funds paybacks resulting from prior year grant reconciliations were not refunded in a timely manner. Questioned Costs – Unknown Cause/Effect – DTC is not in compliance with the cash management requirement.
Program Name – Federal Transit Formula Grant and State of Good Repair Grant Assistance Listing Number – 20.507 and 20.525 Finding Type – Significant Deficiency and Non-Compliance Criteria – In accordance with 2CFR section 200.305(b) of the OMB compliance supplement, non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Condition – During our audit we noted that the federal funds paybacks resulting from prior year grant reconciliations were not refunded in a timely manner. Questioned Costs – Unknown Cause/Effect – DTC is not in compliance with the cash management requirement.
Program Name – Federal Transit Formula Grant and State of Good Repair Grant Assistance Listing Number – 20.507 and 20.525 Finding Type – Significant Deficiency and Non-Compliance Criteria – In accordance with 2CFR section 200.305(b) of the OMB compliance supplement, non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Condition – During our audit we noted that the federal funds paybacks resulting from prior year grant reconciliations were not refunded in a timely manner. Questioned Costs – Unknown Cause/Effect – DTC is not in compliance with the cash management requirement.
Program Name – Federal Transit Formula Grant and State of Good Repair Grant Assistance Listing Number – 20.507 and 20.525 Finding Type – Significant Deficiency and Non-Compliance Criteria – In accordance with 2CFR section 200.305(b) of the OMB compliance supplement, non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Condition – During our audit we noted that the federal funds paybacks resulting from prior year grant reconciliations were not refunded in a timely manner. Questioned Costs – Unknown Cause/Effect – DTC is not in compliance with the cash management requirement.
Program Name – Federal Transit Formula Grant and State of Good Repair Grant Assistance Listing Number – 20.507 and 20.525 Finding Type – Significant Deficiency and Non-Compliance Criteria – In accordance with 2CFR section 200.305(b) of the OMB compliance supplement, non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Condition – During our audit we noted that the federal funds paybacks resulting from prior year grant reconciliations were not refunded in a timely manner. Questioned Costs – Unknown Cause/Effect – DTC is not in compliance with the cash management requirement.
Program Name – Federal Transit Formula Grant and State of Good Repair Grant Assistance Listing Number – 20.507 and 20.525 Finding Type – Significant Deficiency and Non-Compliance Criteria – In accordance with 2CFR section 200.305(b) of the OMB compliance supplement, non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Condition – During our audit we noted that the federal funds paybacks resulting from prior year grant reconciliations were not refunded in a timely manner. Questioned Costs – Unknown Cause/Effect – DTC is not in compliance with the cash management requirement.
Internal Controls over Compliance and Other Matters C. Cash Management – Lack of Documented Procedures Related to Advance Payments U.S. ENVIRONMENTAL PROTECTION AGENCY Geographic Programs - Great Lakes Restoration Initiative – Assistance Listing No. 66.469 Criteria: The federal sub-award grant agreement number 208171 for the EPA Perch Lake Habitat Restoration Project from the State of Minnesota requires Minnesota Land Trust to comply with all federal requirements imposed on the awarded funds, which includes Title 2 U.S. Code of Federal Regulation (CFR) section 200.305. In accordance with 2 CFR section 200.305, a non-federal entity must maintain written procedures that minimize the time elapsing between the transfer of funds and disbursement. Condition: Minnesota Land Trust does not have documented procedures over advance payments that incorporate all the requirements of 2 CFR section 200.305. Cause: Internal controls were not in place to ensure Minnesota Land Trust was aware of the compliance requirements per 2 CFR 200.305 for advance payments. Questioned Costs: None. Effect: Minnesota Land Trust is not in compliance with 2 CFR section 200.305. Context: The federal sub-award grant agreement number 208171 allows for Minnesota Land Trust to request advance payments. Minnesota Land Trust requested and received advance payments related to this project during fiscal year 2023. Recommendation: We recommend that Minnesota Land Trust adopt a written advance payment policy which includes all requirements of 2 CFR section 200.305. Views of Responsible Officials: Minnesota Land Trust agrees with the finding and will adopt a documented advance payment policy consistent with the standards of 2 CFR section 200.305 to use for advance payment requests under federal awards or sub-awards.
Internal Controls over Compliance and Other Matters C. Cash Management – Lack of Documented Procedures Related to Advance Payments U.S. ENVIRONMENTAL PROTECTION AGENCY Geographic Programs - Great Lakes Restoration Initiative – Assistance Listing No. 66.469 Criteria: The federal sub-award grant agreement number 208171 for the EPA Perch Lake Habitat Restoration Project from the State of Minnesota requires Minnesota Land Trust to comply with all federal requirements imposed on the awarded funds, which includes Title 2 U.S. Code of Federal Regulation (CFR) section 200.305. In accordance with 2 CFR section 200.305, a non-federal entity must maintain written procedures that minimize the time elapsing between the transfer of funds and disbursement. Condition: Minnesota Land Trust does not have documented procedures over advance payments that incorporate all the requirements of 2 CFR section 200.305. Cause: Internal controls were not in place to ensure Minnesota Land Trust was aware of the compliance requirements per 2 CFR 200.305 for advance payments. Questioned Costs: None. Effect: Minnesota Land Trust is not in compliance with 2 CFR section 200.305. Context: The federal sub-award grant agreement number 208171 allows for Minnesota Land Trust to request advance payments. Minnesota Land Trust requested and received advance payments related to this project during fiscal year 2023. Recommendation: We recommend that Minnesota Land Trust adopt a written advance payment policy which includes all requirements of 2 CFR section 200.305. Views of Responsible Officials: Minnesota Land Trust agrees with the finding and will adopt a documented advance payment policy consistent with the standards of 2 CFR section 200.305 to use for advance payment requests under federal awards or sub-awards.
Internal Controls over Compliance and Other Matters C. Cash Management – Lack of Documented Procedures Related to Advance Payments U.S. ENVIRONMENTAL PROTECTION AGENCY Geographic Programs - Great Lakes Restoration Initiative – Assistance Listing No. 66.469 Criteria: The federal sub-award grant agreement number 208171 for the EPA Perch Lake Habitat Restoration Project from the State of Minnesota requires Minnesota Land Trust to comply with all federal requirements imposed on the awarded funds, which includes Title 2 U.S. Code of Federal Regulation (CFR) section 200.305. In accordance with 2 CFR section 200.305, a non-federal entity must maintain written procedures that minimize the time elapsing between the transfer of funds and disbursement. Condition: Minnesota Land Trust does not have documented procedures over advance payments that incorporate all the requirements of 2 CFR section 200.305. Cause: Internal controls were not in place to ensure Minnesota Land Trust was aware of the compliance requirements per 2 CFR 200.305 for advance payments. Questioned Costs: None. Effect: Minnesota Land Trust is not in compliance with 2 CFR section 200.305. Context: The federal sub-award grant agreement number 208171 allows for Minnesota Land Trust to request advance payments. Minnesota Land Trust requested and received advance payments related to this project during fiscal year 2023. Recommendation: We recommend that Minnesota Land Trust adopt a written advance payment policy which includes all requirements of 2 CFR section 200.305. Views of Responsible Officials: Minnesota Land Trust agrees with the finding and will adopt a documented advance payment policy consistent with the standards of 2 CFR section 200.305 to use for advance payment requests under federal awards or sub-awards.
Internal Controls over Compliance and Other Matters C. Cash Management – Lack of Documented Procedures Related to Advance Payments U.S. ENVIRONMENTAL PROTECTION AGENCY Geographic Programs - Great Lakes Restoration Initiative – Assistance Listing No. 66.469 Criteria: The federal sub-award grant agreement number 208171 for the EPA Perch Lake Habitat Restoration Project from the State of Minnesota requires Minnesota Land Trust to comply with all federal requirements imposed on the awarded funds, which includes Title 2 U.S. Code of Federal Regulation (CFR) section 200.305. In accordance with 2 CFR section 200.305, a non-federal entity must maintain written procedures that minimize the time elapsing between the transfer of funds and disbursement. Condition: Minnesota Land Trust does not have documented procedures over advance payments that incorporate all the requirements of 2 CFR section 200.305. Cause: Internal controls were not in place to ensure Minnesota Land Trust was aware of the compliance requirements per 2 CFR 200.305 for advance payments. Questioned Costs: None. Effect: Minnesota Land Trust is not in compliance with 2 CFR section 200.305. Context: The federal sub-award grant agreement number 208171 allows for Minnesota Land Trust to request advance payments. Minnesota Land Trust requested and received advance payments related to this project during fiscal year 2023. Recommendation: We recommend that Minnesota Land Trust adopt a written advance payment policy which includes all requirements of 2 CFR section 200.305. Views of Responsible Officials: Minnesota Land Trust agrees with the finding and will adopt a documented advance payment policy consistent with the standards of 2 CFR section 200.305 to use for advance payment requests under federal awards or sub-awards.
Noncompliance and Significant Deficiency in Internal Controls over Compliance for Cash Management Identification data: U.S. Department of Health and Human Services (HHS) – Mental and Behavioral Health Education and Training Grants, Assistance Listing No. 93.732, Agreement Identifying No. M0142518. Criteria: Title 2 CFR §200.305 establishes the criteria for cash management requirements for states and non-Federal entities other than states. This includes non-Federal entities utilizing the reimbursement method and requires that expenditures were incurred prior to the date of the reimbursement request. Condition: The Organization drew funds before expenditures were incurred. Cause: A breakdown in the Organization’s internal controls over cash management did not allow the Organization to meet the reporting requirements of the program. Effect or potential effect: The control deficiency is a significant deficiency that prevented the Organization from complying with the cash management requirements of the program. Identification of a Repeat Finding: New finding. Recommendation: The Organization should review its system of internal control over cash management to determine improvements that can be made to ensure the Organization has processes for remaining in compliance with all cash management criteria identified above. Views of Responsible Officials: The Organization misunderstood the directions given by the Grants Management Specialist in this instance. The Organization has reviewed the requirements of Compliance for Cash Management and has controls in place to ensure those requirements are followed.
Finding 2023-002 Cash Management Internal Controls: Federal Program: Title IV-E Prevention Program – Family Preservation Program [AL #93.472]. Criteria: Per the Uniform Guidance in 2 CFR section 200.305, a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States of the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) Condition: During testing of compliance requirements and internal controls for cash management, it was determined that the February, 2023 invoice was not reviewed prior to submission and the invoice was overstated by $17,712 as it also contained the MCO portion and not just the federal portion. Cause: The individual that normally performs the review of invoices submitted for payment was on vacation and the review was not performed. Effect: When internal controls are not always being performed, this could result in compliance requirements not being met or errors being made. Questioned Costs: None Context: This is not a systematic problem. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Organization have a procedure in place for reviewing invoices sent for payment that can be consistently applied even in the event of an absence or vacation of the normal reviewer. Views of Responsible Officials: The Organization is in agreement with the finding. The Organization will implement a procedure to ensure that invoices are approved by someone other than the normal reviewer if there is an absence or vacation.
Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabilization Fund Federal Award Identification Number and Year - P425E203325, 2020; P425F202751, 2020; P425M200930, 2020 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-001 Criteria - The College must minimize the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds, as outlined in 2 CFR Section 200.305(b). Condition - The College drew down the full amount of each award prior to the funds being disbursed to students or used for allowable expenditures, including lost revenue. Questioned Costs - There were no questioned costs identified. Context - In November 2021, the College drew down $5,882,052 for the student aid portion and $5,622,717 for the institutional aid portion. In July 2022, the College drew down $929,887 for the Strengthening Institutions Program (SIP). In each case, the College did not spend the funds within the required time frame following the cash management rules under 2 CFR Section 200.305(b). Cause and Effect - The College was not aware that cash management requirements under the Uniform Guidance applied to these programs, which resulted in an excess of funds drawndown. Recommendation - We recommend the College implement a process to minimize the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds. Views of Responsible Officials and Corrective Action Plan - There is no more HEERF or federal stimulus funding to be drawn down moving forward. However, if there is in the future,the College will follow the three-day drawdown rules for cash disbursements.
Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabilization Fund Federal Award Identification Number and Year - P425E203325, 2020; P425F202751, 2020; P425M200930, 2020 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-001 Criteria - The College must minimize the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds, as outlined in 2 CFR Section 200.305(b). Condition - The College drew down the full amount of each award prior to the funds being disbursed to students or used for allowable expenditures, including lost revenue. Questioned Costs - There were no questioned costs identified. Context - In November 2021, the College drew down $5,882,052 for the student aid portion and $5,622,717 for the institutional aid portion. In July 2022, the College drew down $929,887 for the Strengthening Institutions Program (SIP). In each case, the College did not spend the funds within the required time frame following the cash management rules under 2 CFR Section 200.305(b). Cause and Effect - The College was not aware that cash management requirements under the Uniform Guidance applied to these programs, which resulted in an excess of funds drawndown. Recommendation - We recommend the College implement a process to minimize the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds. Views of Responsible Officials and Corrective Action Plan - There is no more HEERF or federal stimulus funding to be drawn down moving forward. However, if there is in the future,the College will follow the three-day drawdown rules for cash disbursements.
Assistance Listing Number, Federal Agency, and Program Name - 84.425, U.S. Department of Education, Education Stabilization Fund Federal Award Identification Number and Year - P425E203325, 2020; P425F202751, 2020; P425M200930, 2020 Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-001 Criteria - The College must minimize the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds, as outlined in 2 CFR Section 200.305(b). Condition - The College drew down the full amount of each award prior to the funds being disbursed to students or used for allowable expenditures, including lost revenue. Questioned Costs - There were no questioned costs identified. Context - In November 2021, the College drew down $5,882,052 for the student aid portion and $5,622,717 for the institutional aid portion. In July 2022, the College drew down $929,887 for the Strengthening Institutions Program (SIP). In each case, the College did not spend the funds within the required time frame following the cash management rules under 2 CFR Section 200.305(b). Cause and Effect - The College was not aware that cash management requirements under the Uniform Guidance applied to these programs, which resulted in an excess of funds drawndown. Recommendation - We recommend the College implement a process to minimize the time elapsed between the transfer of funds from the United States Treasury to the College and the disbursement of those funds. Views of Responsible Officials and Corrective Action Plan - There is no more HEERF or federal stimulus funding to be drawn down moving forward. However, if there is in the future,the College will follow the three-day drawdown rules for cash disbursements.
2023-001 ALLOWABLE COST, CASH MANAGEMENT, AND PERIOD OF PERFORMANCE - SIGNIFICANT DEFICIENCY Federal Program Unaccompanied Alien Children Program ALN 93.676 Criteria Part 3 of the Compliance Supplement indicates non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). Part 3 of the Compliance Supplement indicates a non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition/Cause In July 2022, the Home requested reimbursement and received funding to cover costs that had not yet been incurred or paid for as of June 30, 2023. Effect The Home was reimbursed for costs that were not incurred during the budget period. Additionally, the Home has held onto grant funds for twelve plus months. Questioned Costs Known questioned costs are $52,841. Context The Home budgeted to have new fire alarms installed in the cottages during the July 1, 2021 - June 30, 2022 grant budget period. Due to supply chain issues and labor shortages the alarms were not installed until the Fall of 2023 at which time the Home paid the contractor. Repeat Finding No. Recommendation We recommend the Home contact the funding agency to inquire about returning the funds and any interest earned. We also recommend that the Home revisit and strengthen internal controls over allowable activities, allowable costs, cash management, and period of availability related to grant programs. Management Response See corrective action plan included in this report package.
2023–034 SUBRECIPIENT CASH MANAGEMENT Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) 93.323/COVID-19 93.323, Grant Award 6NU50CK000551-01-05, Grant Award 5NU50CK000551-C2-00, Grant Award 6NU50CK000551-02-01, Grant Award 6NU50CK000551-02-02, Grant Award 6NU50CK000551-03-05, Grant Award 6NU50CK000551-03-02, Grant Award 6NU50CK000551-02-04, Grant Award 6NU50CK000551-02-08, Grant Award 6NU50CK000551-02-06, Grant Award 6NU50CK000551-03-01, Grant Award 6NU50CK000551-01-07, Grant Award 6NU50CK000551-02-03, Grant Award 6NU50CK000551-01-06, Grant Award 5NU50CK000551-04-00, Grant Award 6NU50CK000551-04-02, Grant Award 6NU50CK000551-04-04 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.305(b)(1) requires that the non-federal entity must “monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized as required by the applicable cash management requirements in the federal award to the recipient.” Per DHHR policy, the Spending Unit shall limit cash advances to a subrecipient to the minimum amounts needed and be timed in accordance with the actual, immediate cash requirements of the subrecipient for carrying out the purpose of the approved program or project. The timing and amount of cash advances shall be as close as is administratively feasible to the actual disbursements by the subrecipient for direct program or project costs and the proportionate share of any allowable indirect costs. Condition: During our testing of Epidemiology and Laboratory Capacity for Infectious Diseases, the West Virginia Department of Health and Human Resources (DHHR) was unable to provide adequate documentation supporting why a subrecipient drawdown was approved for payment for 1 of the 36 drawdowns selected for testing. The supporting documentation for the draw down showed less expenses than the amount that had been drawn down to date on the grants and also showed the subrecipient appeared to have adequate cash balances on hand at the time of the request. Cause: Supporting documentation was not retained to demonstrate cash advances to the subrecipient represented the minimum amount needed for actual and immediate cash requirements of the subrecipient for carrying out the purpose of the program. Effect or Potential Effect: The cash remitted to the subrecipient may not be accurate and may be in excess of the subrecipients actual and immediate cash requirements for carrying out the purpose of the program. Questioned Costs: $77,063 Context: The total subrecipient drawdowns selected for testing was $1,879,150. The total amount of subrecipient drawdowns for the Epidemiology program during FY23 was $7,478,038. Identification as a Repeat Finding: This is not a repeat finding from the prior year. Recommendation: We recommend that DHHR establish policies and procedures requiring documentation from subrecipients substantiating that the amount of a drawdown is appropriate based on the expenditures through the request date so that the reconciliation preformed for the related drawdown is sufficient to determine that the drawdown is appropriate and excess cash is not remitted to the subrecipient. View of Responsible Officials: Management concurs with the findings and has developed a plan to correct the finding.
2023–034 SUBRECIPIENT CASH MANAGEMENT Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) 93.323/COVID-19 93.323, Grant Award 6NU50CK000551-01-05, Grant Award 5NU50CK000551-C2-00, Grant Award 6NU50CK000551-02-01, Grant Award 6NU50CK000551-02-02, Grant Award 6NU50CK000551-03-05, Grant Award 6NU50CK000551-03-02, Grant Award 6NU50CK000551-02-04, Grant Award 6NU50CK000551-02-08, Grant Award 6NU50CK000551-02-06, Grant Award 6NU50CK000551-03-01, Grant Award 6NU50CK000551-01-07, Grant Award 6NU50CK000551-02-03, Grant Award 6NU50CK000551-01-06, Grant Award 5NU50CK000551-04-00, Grant Award 6NU50CK000551-04-02, Grant Award 6NU50CK000551-04-04 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.305(b)(1) requires that the non-federal entity must “monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized as required by the applicable cash management requirements in the federal award to the recipient.” Per DHHR policy, the Spending Unit shall limit cash advances to a subrecipient to the minimum amounts needed and be timed in accordance with the actual, immediate cash requirements of the subrecipient for carrying out the purpose of the approved program or project. The timing and amount of cash advances shall be as close as is administratively feasible to the actual disbursements by the subrecipient for direct program or project costs and the proportionate share of any allowable indirect costs. Condition: During our testing of Epidemiology and Laboratory Capacity for Infectious Diseases, the West Virginia Department of Health and Human Resources (DHHR) was unable to provide adequate documentation supporting why a subrecipient drawdown was approved for payment for 1 of the 36 drawdowns selected for testing. The supporting documentation for the draw down showed less expenses than the amount that had been drawn down to date on the grants and also showed the subrecipient appeared to have adequate cash balances on hand at the time of the request. Cause: Supporting documentation was not retained to demonstrate cash advances to the subrecipient represented the minimum amount needed for actual and immediate cash requirements of the subrecipient for carrying out the purpose of the program. Effect or Potential Effect: The cash remitted to the subrecipient may not be accurate and may be in excess of the subrecipients actual and immediate cash requirements for carrying out the purpose of the program. Questioned Costs: $77,063 Context: The total subrecipient drawdowns selected for testing was $1,879,150. The total amount of subrecipient drawdowns for the Epidemiology program during FY23 was $7,478,038. Identification as a Repeat Finding: This is not a repeat finding from the prior year. Recommendation: We recommend that DHHR establish policies and procedures requiring documentation from subrecipients substantiating that the amount of a drawdown is appropriate based on the expenditures through the request date so that the reconciliation preformed for the related drawdown is sufficient to determine that the drawdown is appropriate and excess cash is not remitted to the subrecipient. View of Responsible Officials: Management concurs with the findings and has developed a plan to correct the finding.
2023–052 SUBRECIPIENT CASH MANAGEMENT Federal Program Information: Federal Agency and Program Name Assistance Listing # U.S. Department of Health and Human Services Opioid STR 93.788, Grant Award 1H79TI085744, Grant Award 5H79TI083313, Grant Award 1H79TI083313, Grant Award 6H79TI083313 Criteria or specific requirement (including statutory, regulatory or other citation): 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 following guidance in “Standards for Internal Control in the Federal Government” issued by the comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.305(b)(1) requires that the non-federal entity must “monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized as required by the applicable cash management requirements in the federal award to the recipient.” Per DHHR policy, the Spending Unit shall limit cash advances to a subrecipient to the minimum amounts needed and be timed in accordance with the actual, immediate cash requirements of the subrecipient for carrying out the purpose of the approved program or project. The timing and amount of cash advances shall be as close as is administratively feasible to the actual disbursements by the subrecipient for direct program or project costs and the proportionate share of any allowable indirect costs. Condition: During testing of the State Targeted Response to the Opioid Crisis Grants, for 3 of the 40 disbursements selected for testing the approval of the reconciliation of grantee drawdowns and expenses was not reviewed prior to the payment of the subrecipient invoice. Further for 1 of the 40 disbursements selected for testing, information supporting why the subrecipient drawdown was approved for payment was not adequate. Supporting information indicates the grantee had excess cash balances on hand prior to the draw and there was no formal documentation of a program manager’s justification to allow the draw therefore the state was not minimizing the time between the transfer of funds to the subrecipient and the subrecipient’s expenditure of the funds. Cause: Internal controls are not operating effectively surrounding the approval of subrecipient cash disbursements. Supporting documentation was not retained to demonstrate cash advances to the subrecipient represented the minimum amount needed for actual and immediate cash requirements of the subrecipient for carrying out the purpose of the program. Effect or Potential Effect: The cash remitted to the subrecipient may not be accurate and may be in excess of the subrecipients actual and immediate cash requirements for carrying out the purpose of the program. Questioned Costs: $188,484, Opioid STR 93.788 Context: The total subrecipient drawdowns selected for testing was $8,073,637. The total amount of subrecipient drawdowns for the Opioid STR program was $32,972,268 for the year ended June 30, 2023. Identification as a Repeat Finding: Prior Year Finding 2022–038 Recommendation: We recommend that DHHR establish policies and procedures requiring documentation from subrecipients substantiating that the amount of a drawdown is appropriate based on the expenditures through the request date so that the reconciliation preformed for the related drawdown is sufficient to determine that the drawdown is appropriate and excess cash is not remitted to the subrecipient. Views of Responsible Officials: Management concurs with the findings and has developed a plan to correct the finding.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 20.232, U.S. Department of Transportation, Commercial Driver's License Program Implementation Grant - 93.350, U.S. Department of Health and Human Services, National Center for Advancing Translational Sciences - 93.279, U.S. Department of Health and Human Services, Drug Abuse and Addiction Research Programs - 93.853, U.S. Department of Health and Human Services, Extramural Research Programs in the Neurosciences and Neurological Disorders - 93.866, U.S. Department of Health and Human Services, Aging Research Non-Research and Development Cluster: - 17.268, Department of Labor, H-1B Job Training Federal Award Identification Number and Year - Research and Development Cluster: - 20.323 - FM-CDL-0435-20-01-00 - 93.350 - UTR001425B - 93.279 - OSU SPC-1000006389 UM1DA; UDA013732E - 93.853 - SUBK00007313 SLEEP SMART; UNS110772A - 93.866 - RAG072592A 17.268: HG-33044-19-60-A-39, 2019 Pass-through Entity - 93.279 - The Ohio State University; 93.853 - University of Michigan Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a payment within 30 calendar days after receipt of the billing unless the federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition - Out of 28 payments to subrecipients that were tested, 12 were made after the 30-calendar-day requirement, 10 and 2 from the R&D Cluster and ALN 17.268, respectively. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related solely to timeliness of payments. Context - In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 39 - 242 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - The University does have formal general accounts payable and cash disbursement processes in place; however, there are no specific controls in place to ensure that subrecipients are paid within the 30-day requirement. Although all of the payments were ultimately made, the lack of controls resulted in several late payments. Recommendation - The University should implement a control to ensure that payments are made within the required time frame. Views of Responsible Officials and Corrective Action Plan - Accounts payable personnel will review all vendor invoices to determine whether an invoice is related to a federal award expenditure. For federal award expenditures, accounts payable will manually change the payment terms to 30 calendar days or less to ensure compliance. Periodically, accounts payable will review open federal award payables to verify payment terms have been properly set for the 30-day compliance requirement. The Controller’s and Accounts Payable offices will also explore creating a more efficient long-term solution, whereby the 30-day terms could be automatically set during the purchase order creation process. This would eliminate any manual updates to the payment terms by accounts payable personnel. The Sponsored Research Services Accounting Office will send reminders to all college business officers and principal investigators (PIs) to highlight the need for prompt review and approval of federal award invoices. This language will be incorporated into the SRS Best Grant Practices training classes, as well as the University’s fundamentals of sponsored administration training courses.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 20.232, U.S. Department of Transportation, Commercial Driver's License Program Implementation Grant - 93.350, U.S. Department of Health and Human Services, National Center for Advancing Translational Sciences - 93.279, U.S. Department of Health and Human Services, Drug Abuse and Addiction Research Programs - 93.853, U.S. Department of Health and Human Services, Extramural Research Programs in the Neurosciences and Neurological Disorders - 93.866, U.S. Department of Health and Human Services, Aging Research Non-Research and Development Cluster: - 17.268, Department of Labor, H-1B Job Training Federal Award Identification Number and Year - Research and Development Cluster: - 20.323 - FM-CDL-0435-20-01-00 - 93.350 - UTR001425B - 93.279 - OSU SPC-1000006389 UM1DA; UDA013732E - 93.853 - SUBK00007313 SLEEP SMART; UNS110772A - 93.866 - RAG072592A 17.268: HG-33044-19-60-A-39, 2019 Pass-through Entity - 93.279 - The Ohio State University; 93.853 - University of Michigan Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a payment within 30 calendar days after receipt of the billing unless the federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition - Out of 28 payments to subrecipients that were tested, 12 were made after the 30-calendar-day requirement, 10 and 2 from the R&D Cluster and ALN 17.268, respectively. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related solely to timeliness of payments. Context - In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 39 - 242 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - The University does have formal general accounts payable and cash disbursement processes in place; however, there are no specific controls in place to ensure that subrecipients are paid within the 30-day requirement. Although all of the payments were ultimately made, the lack of controls resulted in several late payments. Recommendation - The University should implement a control to ensure that payments are made within the required time frame. Views of Responsible Officials and Corrective Action Plan - Accounts payable personnel will review all vendor invoices to determine whether an invoice is related to a federal award expenditure. For federal award expenditures, accounts payable will manually change the payment terms to 30 calendar days or less to ensure compliance. Periodically, accounts payable will review open federal award payables to verify payment terms have been properly set for the 30-day compliance requirement. The Controller’s and Accounts Payable offices will also explore creating a more efficient long-term solution, whereby the 30-day terms could be automatically set during the purchase order creation process. This would eliminate any manual updates to the payment terms by accounts payable personnel. The Sponsored Research Services Accounting Office will send reminders to all college business officers and principal investigators (PIs) to highlight the need for prompt review and approval of federal award invoices. This language will be incorporated into the SRS Best Grant Practices training classes, as well as the University’s fundamentals of sponsored administration training courses.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 20.232, U.S. Department of Transportation, Commercial Driver's License Program Implementation Grant - 93.350, U.S. Department of Health and Human Services, National Center for Advancing Translational Sciences - 93.279, U.S. Department of Health and Human Services, Drug Abuse and Addiction Research Programs - 93.853, U.S. Department of Health and Human Services, Extramural Research Programs in the Neurosciences and Neurological Disorders - 93.866, U.S. Department of Health and Human Services, Aging Research Non-Research and Development Cluster: - 17.268, Department of Labor, H-1B Job Training Federal Award Identification Number and Year - Research and Development Cluster: - 20.323 - FM-CDL-0435-20-01-00 - 93.350 - UTR001425B - 93.279 - OSU SPC-1000006389 UM1DA; UDA013732E - 93.853 - SUBK00007313 SLEEP SMART; UNS110772A - 93.866 - RAG072592A 17.268: HG-33044-19-60-A-39, 2019 Pass-through Entity - 93.279 - The Ohio State University; 93.853 - University of Michigan Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a payment within 30 calendar days after receipt of the billing unless the federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition - Out of 28 payments to subrecipients that were tested, 12 were made after the 30-calendar-day requirement, 10 and 2 from the R&D Cluster and ALN 17.268, respectively. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related solely to timeliness of payments. Context - In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 39 - 242 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - The University does have formal general accounts payable and cash disbursement processes in place; however, there are no specific controls in place to ensure that subrecipients are paid within the 30-day requirement. Although all of the payments were ultimately made, the lack of controls resulted in several late payments. Recommendation - The University should implement a control to ensure that payments are made within the required time frame. Views of Responsible Officials and Corrective Action Plan - Accounts payable personnel will review all vendor invoices to determine whether an invoice is related to a federal award expenditure. For federal award expenditures, accounts payable will manually change the payment terms to 30 calendar days or less to ensure compliance. Periodically, accounts payable will review open federal award payables to verify payment terms have been properly set for the 30-day compliance requirement. The Controller’s and Accounts Payable offices will also explore creating a more efficient long-term solution, whereby the 30-day terms could be automatically set during the purchase order creation process. This would eliminate any manual updates to the payment terms by accounts payable personnel. The Sponsored Research Services Accounting Office will send reminders to all college business officers and principal investigators (PIs) to highlight the need for prompt review and approval of federal award invoices. This language will be incorporated into the SRS Best Grant Practices training classes, as well as the University’s fundamentals of sponsored administration training courses.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 20.232, U.S. Department of Transportation, Commercial Driver's License Program Implementation Grant - 93.350, U.S. Department of Health and Human Services, National Center for Advancing Translational Sciences - 93.279, U.S. Department of Health and Human Services, Drug Abuse and Addiction Research Programs - 93.853, U.S. Department of Health and Human Services, Extramural Research Programs in the Neurosciences and Neurological Disorders - 93.866, U.S. Department of Health and Human Services, Aging Research Non-Research and Development Cluster: - 17.268, Department of Labor, H-1B Job Training Federal Award Identification Number and Year - Research and Development Cluster: - 20.323 - FM-CDL-0435-20-01-00 - 93.350 - UTR001425B - 93.279 - OSU SPC-1000006389 UM1DA; UDA013732E - 93.853 - SUBK00007313 SLEEP SMART; UNS110772A - 93.866 - RAG072592A 17.268: HG-33044-19-60-A-39, 2019 Pass-through Entity - 93.279 - The Ohio State University; 93.853 - University of Michigan Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a payment within 30 calendar days after receipt of the billing unless the federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition - Out of 28 payments to subrecipients that were tested, 12 were made after the 30-calendar-day requirement, 10 and 2 from the R&D Cluster and ALN 17.268, respectively. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related solely to timeliness of payments. Context - In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 39 - 242 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - The University does have formal general accounts payable and cash disbursement processes in place; however, there are no specific controls in place to ensure that subrecipients are paid within the 30-day requirement. Although all of the payments were ultimately made, the lack of controls resulted in several late payments. Recommendation - The University should implement a control to ensure that payments are made within the required time frame. Views of Responsible Officials and Corrective Action Plan - Accounts payable personnel will review all vendor invoices to determine whether an invoice is related to a federal award expenditure. For federal award expenditures, accounts payable will manually change the payment terms to 30 calendar days or less to ensure compliance. Periodically, accounts payable will review open federal award payables to verify payment terms have been properly set for the 30-day compliance requirement. The Controller’s and Accounts Payable offices will also explore creating a more efficient long-term solution, whereby the 30-day terms could be automatically set during the purchase order creation process. This would eliminate any manual updates to the payment terms by accounts payable personnel. The Sponsored Research Services Accounting Office will send reminders to all college business officers and principal investigators (PIs) to highlight the need for prompt review and approval of federal award invoices. This language will be incorporated into the SRS Best Grant Practices training classes, as well as the University’s fundamentals of sponsored administration training courses.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 20.232, U.S. Department of Transportation, Commercial Driver's License Program Implementation Grant - 93.350, U.S. Department of Health and Human Services, National Center for Advancing Translational Sciences - 93.279, U.S. Department of Health and Human Services, Drug Abuse and Addiction Research Programs - 93.853, U.S. Department of Health and Human Services, Extramural Research Programs in the Neurosciences and Neurological Disorders - 93.866, U.S. Department of Health and Human Services, Aging Research Non-Research and Development Cluster: - 17.268, Department of Labor, H-1B Job Training Federal Award Identification Number and Year - Research and Development Cluster: - 20.323 - FM-CDL-0435-20-01-00 - 93.350 - UTR001425B - 93.279 - OSU SPC-1000006389 UM1DA; UDA013732E - 93.853 - SUBK00007313 SLEEP SMART; UNS110772A - 93.866 - RAG072592A 17.268: HG-33044-19-60-A-39, 2019 Pass-through Entity - 93.279 - The Ohio State University; 93.853 - University of Michigan Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a payment within 30 calendar days after receipt of the billing unless the federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition - Out of 28 payments to subrecipients that were tested, 12 were made after the 30-calendar-day requirement, 10 and 2 from the R&D Cluster and ALN 17.268, respectively. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related solely to timeliness of payments. Context - In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 39 - 242 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - The University does have formal general accounts payable and cash disbursement processes in place; however, there are no specific controls in place to ensure that subrecipients are paid within the 30-day requirement. Although all of the payments were ultimately made, the lack of controls resulted in several late payments. Recommendation - The University should implement a control to ensure that payments are made within the required time frame. Views of Responsible Officials and Corrective Action Plan - Accounts payable personnel will review all vendor invoices to determine whether an invoice is related to a federal award expenditure. For federal award expenditures, accounts payable will manually change the payment terms to 30 calendar days or less to ensure compliance. Periodically, accounts payable will review open federal award payables to verify payment terms have been properly set for the 30-day compliance requirement. The Controller’s and Accounts Payable offices will also explore creating a more efficient long-term solution, whereby the 30-day terms could be automatically set during the purchase order creation process. This would eliminate any manual updates to the payment terms by accounts payable personnel. The Sponsored Research Services Accounting Office will send reminders to all college business officers and principal investigators (PIs) to highlight the need for prompt review and approval of federal award invoices. This language will be incorporated into the SRS Best Grant Practices training classes, as well as the University’s fundamentals of sponsored administration training courses.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 20.232, U.S. Department of Transportation, Commercial Driver's License Program Implementation Grant - 93.350, U.S. Department of Health and Human Services, National Center for Advancing Translational Sciences - 93.279, U.S. Department of Health and Human Services, Drug Abuse and Addiction Research Programs - 93.853, U.S. Department of Health and Human Services, Extramural Research Programs in the Neurosciences and Neurological Disorders - 93.866, U.S. Department of Health and Human Services, Aging Research Non-Research and Development Cluster: - 17.268, Department of Labor, H-1B Job Training Federal Award Identification Number and Year - Research and Development Cluster: - 20.323 - FM-CDL-0435-20-01-00 - 93.350 - UTR001425B - 93.279 - OSU SPC-1000006389 UM1DA; UDA013732E - 93.853 - SUBK00007313 SLEEP SMART; UNS110772A - 93.866 - RAG072592A 17.268: HG-33044-19-60-A-39, 2019 Pass-through Entity - 93.279 - The Ohio State University; 93.853 - University of Michigan Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a payment within 30 calendar days after receipt of the billing unless the federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition - Out of 28 payments to subrecipients that were tested, 12 were made after the 30-calendar-day requirement, 10 and 2 from the R&D Cluster and ALN 17.268, respectively. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related solely to timeliness of payments. Context - In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 39 - 242 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - The University does have formal general accounts payable and cash disbursement processes in place; however, there are no specific controls in place to ensure that subrecipients are paid within the 30-day requirement. Although all of the payments were ultimately made, the lack of controls resulted in several late payments. Recommendation - The University should implement a control to ensure that payments are made within the required time frame. Views of Responsible Officials and Corrective Action Plan - Accounts payable personnel will review all vendor invoices to determine whether an invoice is related to a federal award expenditure. For federal award expenditures, accounts payable will manually change the payment terms to 30 calendar days or less to ensure compliance. Periodically, accounts payable will review open federal award payables to verify payment terms have been properly set for the 30-day compliance requirement. The Controller’s and Accounts Payable offices will also explore creating a more efficient long-term solution, whereby the 30-day terms could be automatically set during the purchase order creation process. This would eliminate any manual updates to the payment terms by accounts payable personnel. The Sponsored Research Services Accounting Office will send reminders to all college business officers and principal investigators (PIs) to highlight the need for prompt review and approval of federal award invoices. This language will be incorporated into the SRS Best Grant Practices training classes, as well as the University’s fundamentals of sponsored administration training courses.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 20.232, U.S. Department of Transportation, Commercial Driver's License Program Implementation Grant - 93.350, U.S. Department of Health and Human Services, National Center for Advancing Translational Sciences - 93.279, U.S. Department of Health and Human Services, Drug Abuse and Addiction Research Programs - 93.853, U.S. Department of Health and Human Services, Extramural Research Programs in the Neurosciences and Neurological Disorders - 93.866, U.S. Department of Health and Human Services, Aging Research Non-Research and Development Cluster: - 17.268, Department of Labor, H-1B Job Training Federal Award Identification Number and Year - Research and Development Cluster: - 20.323 - FM-CDL-0435-20-01-00 - 93.350 - UTR001425B - 93.279 - OSU SPC-1000006389 UM1DA; UDA013732E - 93.853 - SUBK00007313 SLEEP SMART; UNS110772A - 93.866 - RAG072592A 17.268: HG-33044-19-60-A-39, 2019 Pass-through Entity - 93.279 - The Ohio State University; 93.853 - University of Michigan Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a payment within 30 calendar days after receipt of the billing unless the federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition - Out of 28 payments to subrecipients that were tested, 12 were made after the 30-calendar-day requirement, 10 and 2 from the R&D Cluster and ALN 17.268, respectively. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related solely to timeliness of payments. Context - In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 39 - 242 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - The University does have formal general accounts payable and cash disbursement processes in place; however, there are no specific controls in place to ensure that subrecipients are paid within the 30-day requirement. Although all of the payments were ultimately made, the lack of controls resulted in several late payments. Recommendation - The University should implement a control to ensure that payments are made within the required time frame. Views of Responsible Officials and Corrective Action Plan - Accounts payable personnel will review all vendor invoices to determine whether an invoice is related to a federal award expenditure. For federal award expenditures, accounts payable will manually change the payment terms to 30 calendar days or less to ensure compliance. Periodically, accounts payable will review open federal award payables to verify payment terms have been properly set for the 30-day compliance requirement. The Controller’s and Accounts Payable offices will also explore creating a more efficient long-term solution, whereby the 30-day terms could be automatically set during the purchase order creation process. This would eliminate any manual updates to the payment terms by accounts payable personnel. The Sponsored Research Services Accounting Office will send reminders to all college business officers and principal investigators (PIs) to highlight the need for prompt review and approval of federal award invoices. This language will be incorporated into the SRS Best Grant Practices training classes, as well as the University’s fundamentals of sponsored administration training courses.
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster: - 20.232, U.S. Department of Transportation, Commercial Driver's License Program Implementation Grant - 93.350, U.S. Department of Health and Human Services, National Center for Advancing Translational Sciences - 93.279, U.S. Department of Health and Human Services, Drug Abuse and Addiction Research Programs - 93.853, U.S. Department of Health and Human Services, Extramural Research Programs in the Neurosciences and Neurological Disorders - 93.866, U.S. Department of Health and Human Services, Aging Research Non-Research and Development Cluster: - 17.268, Department of Labor, H-1B Job Training Federal Award Identification Number and Year - Research and Development Cluster: - 20.323 - FM-CDL-0435-20-01-00 - 93.350 - UTR001425B - 93.279 - OSU SPC-1000006389 UM1DA; UDA013732E - 93.853 - SUBK00007313 SLEEP SMART; UNS110772A - 93.866 - RAG072592A 17.268: HG-33044-19-60-A-39, 2019 Pass-through Entity - 93.279 - The Ohio State University; 93.853 - University of Michigan Finding Type - Significant deficiency Repeat Finding - No Criteria - As outlined in 2 CFR 200.305(b)(3), when the reimbursement method is used for payment, organizations must make a payment within 30 calendar days after receipt of the billing unless the federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition - Out of 28 payments to subrecipients that were tested, 12 were made after the 30-calendar-day requirement, 10 and 2 from the R&D Cluster and ALN 17.268, respectively. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - The issue identified was related solely to timeliness of payments. Context - In all samples tested, payment was made to the subrecipient; however, the delayed payments ranged from 39 - 242 days between the invoice being received by the University and payment being made to the subrecipient. Cause and Effect - The University does have formal general accounts payable and cash disbursement processes in place; however, there are no specific controls in place to ensure that subrecipients are paid within the 30-day requirement. Although all of the payments were ultimately made, the lack of controls resulted in several late payments. Recommendation - The University should implement a control to ensure that payments are made within the required time frame. Views of Responsible Officials and Corrective Action Plan - Accounts payable personnel will review all vendor invoices to determine whether an invoice is related to a federal award expenditure. For federal award expenditures, accounts payable will manually change the payment terms to 30 calendar days or less to ensure compliance. Periodically, accounts payable will review open federal award payables to verify payment terms have been properly set for the 30-day compliance requirement. The Controller’s and Accounts Payable offices will also explore creating a more efficient long-term solution, whereby the 30-day terms could be automatically set during the purchase order creation process. This would eliminate any manual updates to the payment terms by accounts payable personnel. The Sponsored Research Services Accounting Office will send reminders to all college business officers and principal investigators (PIs) to highlight the need for prompt review and approval of federal award invoices. This language will be incorporated into the SRS Best Grant Practices training classes, as well as the University’s fundamentals of sponsored administration training courses.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(3)). Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Nine exceptions were identified in a sample of forty subrecipient draw requests. Of the nine exceptions noted, exceptions ranged from 31 days to 90 days. Questioned costs: None. Cause: There was a misunderstanding of processes from backup staff. Additionally, there were delays in the department resulting in invoices not being processed timely. Lastly, approvals from the respective Principal Investigators were not being routed correctly. Effect: Subrecipients did not receive their reimbursement timely and in accordance with federal regulations. Repeat finding: No Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.