United States Department of the Treasury Reference Number: 2023-007 Program: 21.026 COVID-19 Homeowner Assistance Fund Program Federal Award Number: HAF0034 Type of Finding: Noncompliance; Significant Deficiency in Internal Controls over Compliance Compliance Requirement: Cash Management; Program Income Condition: During audit testing of the HAF program, we found the following instances of non-compliance. HAF funding received in June 2022 totaling $45 million was deposited into a non-interest-bearing demand account. In March 2023, $21 million was moved to an interest-bearing savings account. Fiscal year 2023 interest earnings of $88,777 on the HAF funds held by DSHA were recognized as program income. Interest earnings in excess of $500 were not annually remitted to the Department of Health and Human Services Payment Management System. Criteria: The HAF program operates in accordance with the requirements of 2 CFR 200.305(b) which requires the following: (8) The non-Federal entity must maintain advance payments of Federal awards in interest-bearing accounts… (9) Interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS) through an electronic medium using either Automated Clearing House (ACH) network or a Fedwire Funds Service payment. Questioned Costs: $88,777. Interest income on HAF program funds was initially recorded as program income until it was corrected by an adjusting journal entry. During the audit of the year ended June 30, 2023, interest income was reduced by an audit adjusting journal entry. Effect: HAF program funds were held in a non-interest-bearing account during the period of July 2022 through March 2023. Interest income on HAF program was not timely remitted to the Department of Health and Human Services as required by the federal regulations. Cause: DSHA’s internal controls did not identify HAF program compliance requirements in time to prevent the Conditions noted. Recommendation: We recommend DSHA review the design and implementation of internal controls to address the identified weaknesses in internal control.
Criteria: The federal award program noted above is not subject to the Treasury-State Cash Management Improvement Act agreement and, as such, is subject to 2 CFR 200.305(b), which states: “The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions.” 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. The State of Hawaii, Department of Budget and Finance has determined and communicated in Finance Memorandum 20-02 that their standard for an “administratively feasible time period” was 21 calendar days. Condition: During the testing of the Department’s cash management procedures, it was determined that two out of sixty payments tested were not distributed within 21 days of the draw down of funds. For the items tested, the time elapsed between draw down and payment ranged to 28 to 57 days. Context: During the fiscal year ended June 30, 2023, the Department expended $8,398,791 (excluding food expenditures). Cause: The Department draws down federal funds that will be needed based on the expenditures that must be paid. However, since deposits must be posted prior to the processing of payments or disbursing of the funds, it is difficult for the Department to disburse federal funds in accordance with 2 CFR 200.305 (b). Also, the State’s payment process requires all State departments to process payments through DAGS resulting in processing delays. Effect: Noncompliance with federal regulations could result in a loss of funding that may jeopardize the operations of the Department’s federally funded programs. Questioned Costs: None Identification as a Repeat Finding, if applicable: See finding 2022-005 included in the Summary Schedule of Prior Audit Findings. Recommendation: We recommend that the Department work with DAGS and the Department of Budget and Finance to ensure compliance with established standard and timely disbursement of federal funds in accordance with 2 CFR 200.305(b). Views of Responsible Officials and Planned Corrective Action: See Part VI Correction Action Plan.
Department of Education and Passed through State of Iowa Department of Education Federal Financial Assistance Listing #84.287, C14-SHIP, C15-SHIP, C16-SHIP, C17-SHIP, 7/1/2022 – 6/30/2023 Twenty-First Century Community Learning Centers Program Cash Management Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) states that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. In addition, 2 CFR 200.302(b)(6) establishes that the financial management system of the entity must provide written procedures to implement the requirements of 2 CFR 200.305 Payment. Condition: No support could be provided for the third quarter draw requests to substantiate a secondary level of review was completed prior to submission of the draws. Cause: Documentation to support the review of draw requests prior to submission was not retained during the transition period in the Finance Director role. Effect: Without retaining supporting documentation to substantiate the review of draw requests, demonstrating that the program complies with laws, regulations, and other compliance requirements is difficult. Questioned Costs: None reported. Context: A non-statistical sample of 2 of 4 quarters were selected for testing. All draws submitted within the selected quarters were tested. Repeat Finding from Prior Year: No Recommendation: We acknowledge the review process lapsed during a time of employee transition, however, we recommend that management retain documentation to support the review of grant draws is performed for all grant draw requests. Views of Responsible Officials: Management is in agreement.
Federal Program: Research and Development Cluster Grantor Agency: Department of Defense Program Title: Randomized Trial for Pazopanib in HHT-Related Bleeding Federal Award Year: July 1, 2022 - June 30, 2023 Type of finding: • Significant Deficiency in Internal Control over Compliance • Compliance, Other Matter Criteria: 2 CFR 200.303 requires that organizations establish and maintain effective internal controls in place over Federal awards that provide reasonable assurance that the non-Federal entity is managing the award in compliance with Federal statues, regulations, and the terms of and conditions of the Federal award. Additionally, 2 CFR 200.305(b)(1) requires an organization receiving advances on federal funds must maintain or demonstrate the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part, and the timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. Condition: One reimbursement request submitted to the cognizant agency included expenditures for which the organization had already been reimbursed and, per review of the organization’s SF-425 submissions and accounting records, we noted that Federal funds advanced to the organization were not disbursed in a timely manner. Context: During our review of the organization’s Federal grant revenue reconciliation, an amount classified as an advance on Federal funds was determined to include amounts for which the organization had already requested reimbursement and been paid. Additionally, through review of grant reports, accounting records and inquiries with management, we discovered that the funds the organization had received in advance had not been used for project costs in a timely manner, consistent with 2 CFR 200.305. Cause: During the preparation of the fiscal year-end drawdown request, the data used to determine the amount the organization needed to draw down was not reviewed or reconciled against amounts previously requested and, thus, the drawdown included duplicate and/or incorrect requests for grant funds. Effect or possible effect of condition: Proper internal controls were not in place to mitigate the excess drawdown due to incorrect underlying information and procedures were not in place to minimize the time elapsing between receipt and disbursement of Federal funds. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that management strengthen its internal controls over cash management to ensure that amounts submitted for reimbursement are properly reconciled against internal data used to request funding to date. Additionally, we recommend that management develop written procedures to minimize the time elapsed between receipt of Federal funds and the disbursement thereof. Views of responsible officials: This error occurred during a time of transition from one outsourced accounting firm and accounting system to another. The new outsourced accounting systems were not fully in place or automated at the time of the reporting error and there was no internal review process. The outsourced accounting firm is now fully transitioned, all systems are fully integrated with the accounting software, and the accounting team provides the program managers and organization managers with the reports needed to prepare drawdown requests. Cure HHT has developed and fully implemented a corrective action plan. The organization has communicated with the cognizant agency and all expenses eligible for submission for payment through grant funding will be submitted to and paid from the overdrawn funds. Once these funds are depleted, the organization will resume monthly draw submissions for all eligible expenses. The organization will reconcile all eligible expenses prior to requesting grant funds to avoid future duplicate and/or incorrect requests for grant funds. In addition, pending proper internal approvals of all submitted expenses, grant funds received will be dispersed within 3-7 business days from the date received.
CASH MANAGEMENT ACTVITIES 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: The BOCES submitted three reimbursement requests for its Colorado Department of Education ESSER III ARP 9.5%, RURAL COACTION grant that were not properly supported by the underlying expenses. It appears in two of the instances the draws for the August through October 2023 expenditures and the draw for the November 2023 expenditures included a $1,667 payment that was subsequently charged to a different program. In the third instance, the amount requested differed from the June and 2023 accrued expenditures by $313. We were not able to isolate the cause of the difference. In total there was $3,647 of expenditures that had been reimbursed that were not charged to the grant. The BOCES did recognize that these amounts had been requested in error by year end and recorded an unearned revenue of $3,647 at year end and accordingly are not considered a questioned cost. This was not considered a material non-compliance with the grant requirements. In addition, the BOCES requested a reimbursement of $48,962 for the 23-24 fiscal year from the Colorado Department of Education. When this payment was received by the BOCES from the Department, it was noted as being for the 22-23 fiscal year and was recorded by the BOCES as a receivable and unearned revenue at year end. Context: This finding was noted during the testing of Cash Management procedures related to the BOES Educational Stabilization Funds grant receipts. All other tested grant receipts were based on previously incurred grant expenditures in compliance with the Cash Management requirements and this does not appear to be a recurring issue or a material weakness in controls and was not noted in prior years for the BOCES’ other Federal grants. Effect: The BOCES had requested $3,647 of grant funding that had either not been earned or obligated at the time of the request or was subsequently charged to a different BOCES program. Cause: It appears that the BOCES may have reclassified expenditures from one program to another subsequent to the corresponding draw request. This error may have occurred if the BOCES was generating reimbursement requests based on current month activity rather than relying on year to date report relative to year to date draw requests Recommendation: The BOCES must ensure that internal control procedures are in place to verify that all grant funding requests meet Cash Management requirements. In the BOCES case, this is normally a process whereby reimbursements are requested subsequent to the expenditure of grant funds, The BOCES should establish internal controls whereby the grant manager determines the amount to be requested and this is subsequently verified by finance staff to ensure that total requests do not exceed incurred or obligated expenditures. Management Response: The BOCES will assure internal control procedures are in place to verify that all grant funding requests meet Cash Management requirements. Reimbursements will be requested subsequent to the expenditure of grant funds. The BOCES will establish internal controls whereby the grant manager determines the amount to be requested and this will be subsequently verified by finance staff to ensure that total requests do not exceed incurred or obligated expenditures. A review of the internal control procedures with all grant management and finance staff will assure that this is not a reoccurring issue.
Finding Reference Number: SA2023-003 Cash Management - Draw Down of Community Development Block Grant Funds in Advance of Disbursement Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant – Entitlement Grants COVID-19 - Community Development Block Grants/Entitlement Grants-CV Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-22-MC-06-0010 COVID-19 - B-20-MW-06-0010 Criteria: Under 2 CFR 200.305, a CDBG grantee is prohibited from drawing funds down from its line of credit in advance of cash need, and must minimize the time elapsing between the transfer of funds from its line of credit, and the disbursement of the funds. Advance payment must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the grantee or subrecipient carrying out an eligible activity. Condition: We selected eight non-payroll disbursements related to projects and subgrants for testing and noted two disbursement in April 2023 and June 2023 totaling $268,439 had been charged to the CDBG program in the amount of $282.567. The difference of $14,128 was the retention payable to the vendor, which was not paid in cash until after June 30, 2023. However, the City included the retentions payable in the grant drawdowns filed and received in May 2023 and September 2023. We also noted that total retentions payable charged to the CDBG program for the project were $17,301 as of June 30, 2023. Cause: We understand that the retentions were included in the grant drawdowns due to staff oversight. Questioned Costs: We question costs in the amount of $17,301. Effect: Drawing down funds in advance does not minimize the time elapsing between receipt of funds and expenditures and is not in compliance with the cash management provisions of 2 CFR 200.305 and the CDBG program. Recommendation: The City should not draw down funds until expenditures have been paid in cash and in the event, drawdowns occur prior to disbursement, ensure that the time elapsing between the draw down and the expenditure is minimized. In addition, the City should determine whether the interest earned on the grant funds advanced need to be returned to the grantor. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.
Finding Reference Number: SA2023-003 Cash Management - Draw Down of Community Development Block Grant Funds in Advance of Disbursement Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant – Entitlement Grants COVID-19 - Community Development Block Grants/Entitlement Grants-CV Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-22-MC-06-0010 COVID-19 - B-20-MW-06-0010 Criteria: Under 2 CFR 200.305, a CDBG grantee is prohibited from drawing funds down from its line of credit in advance of cash need, and must minimize the time elapsing between the transfer of funds from its line of credit, and the disbursement of the funds. Advance payment must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the grantee or subrecipient carrying out an eligible activity. Condition: We selected eight non-payroll disbursements related to projects and subgrants for testing and noted two disbursement in April 2023 and June 2023 totaling $268,439 had been charged to the CDBG program in the amount of $282.567. The difference of $14,128 was the retention payable to the vendor, which was not paid in cash until after June 30, 2023. However, the City included the retentions payable in the grant drawdowns filed and received in May 2023 and September 2023. We also noted that total retentions payable charged to the CDBG program for the project were $17,301 as of June 30, 2023. Cause: We understand that the retentions were included in the grant drawdowns due to staff oversight. Questioned Costs: We question costs in the amount of $17,301. Effect: Drawing down funds in advance does not minimize the time elapsing between receipt of funds and expenditures and is not in compliance with the cash management provisions of 2 CFR 200.305 and the CDBG program. Recommendation: The City should not draw down funds until expenditures have been paid in cash and in the event, drawdowns occur prior to disbursement, ensure that the time elapsing between the draw down and the expenditure is minimized. In addition, the City should determine whether the interest earned on the grant funds advanced need to be returned to the grantor. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.
2023-008 – Cash Management Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund – Higher Education Emergency Relief Fund – Student Aid Portion and Institutional Portion Federal Assistance Listing Numbers: 84.425E and 84.425F Federal Award Identification Number and Year: P425F203028 and P425E201388 – all grants were awarded within 2021-2022 and 2022-2023 Award Period: 7/1/2022 – 6/30/2023 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 2 CFR 200.305(b)(1), the non- Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions. 200.305(b)(9) Interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the government. A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303). Condition: The University did not expend all funds drawn down in advance by June 30, 2023, and therefore, they did not minimize the amount of time between the transfer of funds and disbursement. Additionally, more than $500 of interest was earned on the unspent funds and it was not remitted to the federal government as of year-end. Questioned Costs: $75,070 of interest earned as of June 30, 2023 Context: Federal funds were drawn down in advance of expenditure and there were no policies to minimize the time elapsing between the transfer of funds and disbursement by the University. Additionally, the University earned interest greater than $500 which was not remitted as of report date. Cause: University does not have a documented procedure or control that minimizes the time elapsing between the transfer of funds and disbursement or returning earned interest. Effect: Failure to document and adhere to procedures to minimize the time elapsing between transfer and disbursement of funds and the University incurred interest that has not been remitted back to the treasury. Repeat Finding: Yes, 2022-011 Recommendation: We recommend the University formally design and implement controls and monitor advances in federal funds to ensure time elapsing between the transfer of funds and disbursement is minimized and any interest required to be remitted is calculated and returned on a timely basis. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2023-008 – Cash Management Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund – Higher Education Emergency Relief Fund – Student Aid Portion and Institutional Portion Federal Assistance Listing Numbers: 84.425E and 84.425F Federal Award Identification Number and Year: P425F203028 and P425E201388 – all grants were awarded within 2021-2022 and 2022-2023 Award Period: 7/1/2022 – 6/30/2023 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 2 CFR 200.305(b)(1), the non- Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions. 200.305(b)(9) Interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the government. A non-federal entity must maintain effective internal control over the federal award (2 CFR 200.303). Condition: The University did not expend all funds drawn down in advance by June 30, 2023, and therefore, they did not minimize the amount of time between the transfer of funds and disbursement. Additionally, more than $500 of interest was earned on the unspent funds and it was not remitted to the federal government as of year-end. Questioned Costs: $75,070 of interest earned as of June 30, 2023 Context: Federal funds were drawn down in advance of expenditure and there were no policies to minimize the time elapsing between the transfer of funds and disbursement by the University. Additionally, the University earned interest greater than $500 which was not remitted as of report date. Cause: University does not have a documented procedure or control that minimizes the time elapsing between the transfer of funds and disbursement or returning earned interest. Effect: Failure to document and adhere to procedures to minimize the time elapsing between transfer and disbursement of funds and the University incurred interest that has not been remitted back to the treasury. Repeat Finding: Yes, 2022-011 Recommendation: We recommend the University formally design and implement controls and monitor advances in federal funds to ensure time elapsing between the transfer of funds and disbursement is minimized and any interest required to be remitted is calculated and returned on a timely basis. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
Finding Reference Number: 2023-014 NH Department of Energy Low Income Home Energy Assistance and COVID-19 Low Income Home Energy Assistance. (Assistance Listing #93.568) Federal Award Numbers: 2001NHLEA, 2001NHLIE4, 2001NH5C3, 2101NHLIEA, 2101NHE5C6, 2201NHLIEA, 2101NHLIE4, 2201NHLIEE, 2201NHLIEI, 2301NHLIEA, 2301NHLIEE, 2301NHLIEI Federal Award Year: 2020, 2021, 2022, 2023 U.S. Department of Health and Human Services Compliance Requirement: Cash Management Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2022-027 Statistically Valid Sample: No Criteria U.S. Department of the Treasury (Treasury) regulations at 31 CFR 204 part 205 implement the Cash Management Act of 1990 (CMIA). Subpart A of those regulations requires state recipients to enter into Treasury-State Agreements that prescribe specific methods of drawing down federal funds (funding techniques) for federal programs listed in the Catalog of Federal Domestic assistance that meet the funding threshold for a major federal program under the CMIA. Treasury-State Agreements also specify the terms and conditions under which an interest liability would be incurred. Pass-through entities 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 (2 CFR section 200.305(b)(1)). Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the 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. Condition During our testwork over performed over cash management related to the Low-Income Home Energy Assistance program, we noted the following: A. Under the State of New Hampshire’s Cash Management Agreement (CMIA), direct expenditures are to be drawn using the actual draw – monthly technique. Under this technique, the funds are to be requested monthly based on actual costs incurred during that 1-month period. The funding technique is interest neutral. During our testwork over the cash draw process, we noted the following: a. For 4 of 9 cash draws selected for testwork, the New Hampshire Department of Energy (the Department) did not draw funds timely resulting in the cash draw to be delinquent. Each of the 4 cash draw covered multiple months of activity. As the clearance pattern within the CMIA agreement is interest neutral, there was no interest impact because of the cash draws not being performed timely. B. The Department advances payments to subrecipients to ensure that they have sufficient cash on hand to pay for benefit payments. The Department passed through $52,485,098 to subrecipients during the year ended June 30, 2023. During our testwork over compliance with cash management, we noted that for the 4 cash advance payment samples selected for testwork, the Department was not able to provide sufficient evidence to support that the cash advance was spent within a time period that minimizes the time elapsed between the transfer of federal funds to the subrecipient and their disbursement for program purposes. The Department’s normal disbursement cycle of every 30 days. As such, it does not appear that the Department sufficiently minimized the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes. Cause The cause of the condition found was primarily due to insufficient resources to monitor and track cash draws to ensure they are performed timely in accordance with the clearance patten established within the CMIA agreement and to ensure that subrecipients either utilize advance funds timely or effectively evaluate the amount of funds they need on hand at the time of the advance payment. Effect The effect of the condition found is that the Department did not comply with the provisions of the CMIA as it relates to the timing of cash draws. In addition, the Department did not have sufficient policies and procedures in place to ensure the time elapsed between the transfer of federal funds to the subrecipient and their disbursement of funds for program purposes is minimized. As such the Department was not in compliance with 2 CFR section 200.305(b)(1). Questioned Costs None. Recommendation We recommend that the Department review its existing internal controls, policies, and procedures to ensure that all cash draws are performed timely and in accordance with the CMIA agreement. In addition, we recommend that the Department review its existing internal controls, policies and procedures relating to advancing funds to subrecipients to ensure that excess cash held by the subrecipients does not exceed 30 days. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2023-014 NH Department of Energy Low Income Home Energy Assistance and COVID-19 Low Income Home Energy Assistance. (Assistance Listing #93.568) Federal Award Numbers: 2001NHLEA, 2001NHLIE4, 2001NH5C3, 2101NHLIEA, 2101NHE5C6, 2201NHLIEA, 2101NHLIE4, 2201NHLIEE, 2201NHLIEI, 2301NHLIEA, 2301NHLIEE, 2301NHLIEI Federal Award Year: 2020, 2021, 2022, 2023 U.S. Department of Health and Human Services Compliance Requirement: Cash Management Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2022-027 Statistically Valid Sample: No Criteria U.S. Department of the Treasury (Treasury) regulations at 31 CFR 204 part 205 implement the Cash Management Act of 1990 (CMIA). Subpart A of those regulations requires state recipients to enter into Treasury-State Agreements that prescribe specific methods of drawing down federal funds (funding techniques) for federal programs listed in the Catalog of Federal Domestic assistance that meet the funding threshold for a major federal program under the CMIA. Treasury-State Agreements also specify the terms and conditions under which an interest liability would be incurred. Pass-through entities 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 (2 CFR section 200.305(b)(1)). Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the 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. Condition During our testwork over performed over cash management related to the Low-Income Home Energy Assistance program, we noted the following: A. Under the State of New Hampshire’s Cash Management Agreement (CMIA), direct expenditures are to be drawn using the actual draw – monthly technique. Under this technique, the funds are to be requested monthly based on actual costs incurred during that 1-month period. The funding technique is interest neutral. During our testwork over the cash draw process, we noted the following: a. For 4 of 9 cash draws selected for testwork, the New Hampshire Department of Energy (the Department) did not draw funds timely resulting in the cash draw to be delinquent. Each of the 4 cash draw covered multiple months of activity. As the clearance pattern within the CMIA agreement is interest neutral, there was no interest impact because of the cash draws not being performed timely. B. The Department advances payments to subrecipients to ensure that they have sufficient cash on hand to pay for benefit payments. The Department passed through $52,485,098 to subrecipients during the year ended June 30, 2023. During our testwork over compliance with cash management, we noted that for the 4 cash advance payment samples selected for testwork, the Department was not able to provide sufficient evidence to support that the cash advance was spent within a time period that minimizes the time elapsed between the transfer of federal funds to the subrecipient and their disbursement for program purposes. The Department’s normal disbursement cycle of every 30 days. As such, it does not appear that the Department sufficiently minimized the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes. Cause The cause of the condition found was primarily due to insufficient resources to monitor and track cash draws to ensure they are performed timely in accordance with the clearance patten established within the CMIA agreement and to ensure that subrecipients either utilize advance funds timely or effectively evaluate the amount of funds they need on hand at the time of the advance payment. Effect The effect of the condition found is that the Department did not comply with the provisions of the CMIA as it relates to the timing of cash draws. In addition, the Department did not have sufficient policies and procedures in place to ensure the time elapsed between the transfer of federal funds to the subrecipient and their disbursement of funds for program purposes is minimized. As such the Department was not in compliance with 2 CFR section 200.305(b)(1). Questioned Costs None. Recommendation We recommend that the Department review its existing internal controls, policies, and procedures to ensure that all cash draws are performed timely and in accordance with the CMIA agreement. In addition, we recommend that the Department review its existing internal controls, policies and procedures relating to advancing funds to subrecipients to ensure that excess cash held by the subrecipients does not exceed 30 days. View of Responsible Officials: Management concurs with the finding above.
Condition: During our Cash Management tests, we found the following instances on which the Institution did not disbursed funds in an expedite matter: Fund Instances Days late 84.425F 3 32/40/46 84.031S 3 10/16/29 84.031M 2 13/15 Criteria: As per regulation, 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)).With respect to HEERF Section 2 funds the time elapsing between the transfer of funds and the disbursement should be 3 calendar days.Cause: In these instances, for the amount of the service contracted or equipment purchased, the Institution requested the totality of the amount of the service or purchase but, disbursements were made as worked progressed or equipment was completely delivered.Effect: Not following established controls could result in non-compliance of federal regulations for the program.Questioned costs: -0- Recommendation: Cash management procedures should be monitored better so that compliance with established safeguards are followed. Views of Responsible Officials and Planned Corrective Actions: Atlantic University agrees with the finding. See Corrective Action plan for the University’s Comments and plan.
Condition: During our Cash Management tests, we found the following instances on which the Institution did not disbursed funds in an expedite matter: Fund Instances Days late 84.425F 3 32/40/46 84.031S 3 10/16/29 84.031M 2 13/15 Criteria: As per regulation, 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)).With respect to HEERF Section 2 funds the time elapsing between the transfer of funds and the disbursement should be 3 calendar days.Cause: In these instances, for the amount of the service contracted or equipment purchased, the Institution requested the totality of the amount of the service or purchase but, disbursements were made as worked progressed or equipment was completely delivered.Effect: Not following established controls could result in non-compliance of federal regulations for the program.Questioned costs: -0- Recommendation: Cash management procedures should be monitored better so that compliance with established safeguards are followed. Views of Responsible Officials and Planned Corrective Actions: Atlantic University agrees with the finding. See Corrective Action plan for the University’s Comments and plan.
Condition: During our Cash Management tests, we found the following instances on which the Institution did not disbursed funds in an expedite matter: Fund Instances Days late 84.425F 3 32/40/46 84.031S 3 10/16/29 84.031M 2 13/15 Criteria: As per regulation, 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)).With respect to HEERF Section 2 funds the time elapsing between the transfer of funds and the disbursement should be 3 calendar days.Cause: In these instances, for the amount of the service contracted or equipment purchased, the Institution requested the totality of the amount of the service or purchase but, disbursements were made as worked progressed or equipment was completely delivered.Effect: Not following established controls could result in non-compliance of federal regulations for the program.Questioned costs: -0- Recommendation: Cash management procedures should be monitored better so that compliance with established safeguards are followed. Views of Responsible Officials and Planned Corrective Actions: Atlantic University agrees with the finding. See Corrective Action plan for the University’s Comments and plan.
U.S. Department of Health and Human Services Health Resources and Services Administration Health Care Center Program CFDA 93.224 2023-05: Timeliness of Deposits Criteria: The recipient is responsible for complying with audit requirements in accordance with 2 CFR 200.305. A non-Federal entity 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. Condition: The Organization did not deposit funds from the pass-through entity in a timely manner. Effect: Failure to have an adequate policy and procedure regarding cash management could result in misappropriation of assets and material misstatements in financial statements. Cause: Lack of policies and procedures regarding cash management and recording deposits. Identification of a repeat finding: No. Recommendation: We recommend that the Organization ensure to deposit funds received in a timely manner as to avoid misappropriation of assets and misstatements in financial statements. Views of responsible officials and planned corrective actions: The Organization agrees with this finding and will adhere to the corrective action plan on page 33 in this audit report.
Finding No. 2023-001 Cash Management – Drawdowns of funds Federal Program ALN 66.458 - Capitalization Grants for Clean Water State Revolving Funds Name of Federal Agency U.S Environmental Protection Agency Pass-through Entity Puerto Rico Department of Natural and Environmental Resources (DNER) Category Compliance/Significant Deficiency on Internal Control Compliance Requirements Cash Management – Drawdowns of funds Criteria 2 CFR Section 200.305 (b) establishes the following: For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. The non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions. Pursuant to § 35.3135(d) The State must agree to expend all funds in the SRF in an expenditious and timely manner. Condition found In two (2) of five (5) drawdowns selected for testing, we found that the disbursements were not transferred to the recipient in a timely manner as follows: Grant award # Date Federal portion Total Date deposited in Revolving Fund bank account Date paid to subrecipient Days elapsed C-72-051-03 10/11/2022 $ 2,723,093.00 $ 2,723,093.00 10/12/2022 10/19/2022 7 C-72-051-03 12/15/2022 1,200,151.81 1,200,151.81 12/16/2022 12/30/2022 14 Cause The delays in the transfer of funds were caused by administrative delays and lack of personnel assigned to carry out these tasks in a timely manner. Effect Advanced funds remained idle at the rotatory fund trust account for an extended amount of time. This also may result in administrative sanctions by the grantor. Questioned Cost None. Context Two (2) of five (5) drawdowns selected for testing were not transferred to the recipient in a timely manner. Identification of a repeat finding This is a not repeat finding from the immediate previous audit. Views of responsible officials and planned corrective actions The management of the Revolving Fund agrees with this finding. Please refer to the corrective action plan section on pages 49-50. Recommendation We recommend management of the Revolving Funds to establish written procedures and proper monitoring that ensure the compliance with the requirements for cash management.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003: Material weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities 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…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $360,671. It was noted that other programs were also overdrawn as follows: Temporary Assistance for Needy Families Cluster (ALN 93.958): $55,725, Employment Services Cluster (ALN 17.207): $1,389, and Unemployment Insurance (ALN 17.225): $18,660. The total amount of funds overdrawn as of year-end totaled $436,445. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not 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. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2023-003 – Cash Management Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Number: 93.391Assistance Listing Name: Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Pass-through Awards under the Uniform Guidance Requirements: Criteria – CFR § 200.305 Federal payment. section (b) states that, " For Non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means.” Further, “The timing and amount of advance payments must be as close as administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions,” and “To the extent available, the non-Federal entity must disburse funds available from program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries and interest earned on such funds before requesting additional cash payments. Condition – During our testing of payments received from the Ohio Department of Health, we noted that ODH funded $300,000 to the Organization, however, costs incurred through July 30, 2023 were approximately $195,000 per the SEFA. Management was unable to support the difference between total expenditures reported in the GMIS YTD June Report to the amounts reported in the SEFA, and therefore, it is unknown if the costs were incurred prior to requesting additional cash payments. Cause – United Way of Greater Cleveland does not have policies or procedures that address minimizing the time between receipt funds from the Ohio Department of Health and disbursement for programmatic expenses. Effect – United Way of Greater Cleveland is not in compliance with the provisions of CFR 200.305, in that, the Organization did not adhere to requirements to minimize the time elapsing between the transfer of funds and disbursement by the recipient, or that funds were disbursed prior to requesting additional cash payments. Questioned Costs – None Context – We sampled 7 cash receipts for the OHIZ program, noting a total of $300,000 received under the program as compared to expenditures of approximately $195,000, for which there were no policies or procedures to minimize the time elapsing between receipt and disbursement of such funds. Repeat Finding – This is not a repeat finding. Recommendation – We recommend that United Way of Greater Cleveland draft formal policies and procedures whereby federal funds received in advance of the expenditure are segregated and expended in a manner to minimize the time between date of receipt and date of disbursement. Views of Responsible Officials -
Finding: 2023-004 –Significant Deficiency in Internal Control over Compliance and Noncompliance – Cash Management Identification of federal program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Criteria: For purposes of the federal government, 2 CFR Chapter II part 200 Subpart D §200.305 requires for non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Condition: Cash draw downs and receipt of federal funds exceeded the amount expended and ultimately were required to be returned. Cause: The Organization did not have controls in place to minimize the time elapsing between the transfer of funds from the United States Treasury and the disbursement of the funds by the Organization. Effect or potential effect: The Organization is not in compliance with 2 CFR §200.305 Questioned Costs: None Context: For this program, a sample of three drawdowns were selected. Two of the three drawdowns exceeded the amount of expenditures incurred at the time of the drawdown and cumulatively through the period of performance requiring the funds to be returned. Identification of Repeat Finding: Not applicable. Recommendations: Management should implement controls to minimize the time elapsing between the transfer of funds from the United States Treasury and the disbursement of the funds by the Organization. Views of Responsible Officials: Please refer to Corrective Action Plan.