2022-007: Cash Management - Material Weakness – Originated in 2019 Federal Program Information: Funding Agency: U.S Department of Health and Human Services FALN: 93.926 Federal Award Identification Number: H49MC00119-22-00 Pass Through Entity: State of Georgia Department of Human Services Award Year: 2020-2024 Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Additionally regulations require the reimbursement payment method may be used on a Federal award for activities as specified in 2 CFR section 200.305(b)(3), program costs must be paid by non-Federal entity funds before submitting a payment request (2 CFR section 200.305(b)(3)), i.e., the non-Federal entity must disburse funds for program purposes before requesting payment from the Federal awarding agency or pass-through entity. Condition: The Organization has a policy which includes the Fiscal/Grant Manager and/or the CEO review all drawdown requests to ensure costs are paid before reimbursement is requested. However of the sixteen (16) drawdown requests that we tested, there was no evidence of review and approval for drawdown. Effect: Management possibly did not expend funds in accordance with the federal award due to lack of evidence of oversight/review of drawdowns and after reimbursable expenses have been incurred. Cause: Management did not document evidence of review and approval of drawdown requests. This was due in part to lack of oversight. Also there were several changes in personnel within the accounting area and overall limited number of personnel for certain functions and lack of board oversight. Questioned costs: None Recommendation: We recommend that internal controls be strengthened and processes implemented to ensure all draw down requests are reviewed and approved to ensure costs were accurately reported and paid before requesting reimbursement.
Condition: During our review of the December 31, 2022 Schedule of Expenditures of Federal Awards (SEFA) prepared by management, we noted that controls over revenue recognition and preparation of the SEFA were not properly designed resulting in material adjustments to several grants and to the SEFA identified during the audit. Criteria: The Code of Federal Regulations (CFR) Section 200.510(b) states in part, “The auditee must also prepare a schedule of federal expenditures for the period covered by the auditee’s consolidated financial statements which must include the total Federal awards expended as determined in accordance with 200.502.” Also, in accordance with CFR Section 200.302(b) – Financial Management, the auditees financial management system must provide 1) identification of all federal awards received and expended; 2) accurate, current, and complete disclosure of the financial results of each federal award or program; 3) records that identify adequately the source and application of funds for federally-funded activities; 4) effective control over, and accountability for, all funds, property, and other assets; 5) comparison of expenditures with budget amounts for each Federal award; 6) written procedures to implement the requirements of section 200.305 and; 7) written procedures for determining the allowability of costs in accordance with Subpart E and the terms and conditions of the Federal award. Further, revenue from grants is to be accounted for in accordance with ASU 2018-08 (Topic 958) Clarifying the Scope and Accounting Guidance for Contributions Received and Contributions Made. As most of the Federal grants received are conditional upon expenditure and expenditure in accordance with cost principles, revenue should not be recognized until the relating conditions have been met and therefore right of return is overcome. Cause: Internal controls over revenue recognition and preparation of the SEFA are not designed effectively to ensure completeness and accuracy of revenues reported and the SEFA. Effect: As a result of the condition noted above, material audit adjustments were required to be posted to several grants and to the SEFA to properly report federal expenditures in the correct period, as well as revenues reported on the consolidated statement of activities. Recommendation: We recommend that management review current internal controls over revenue recognition and preparation and tracking of federal expenditures to ensure that revenue is properly reported and, all federal awards are captured and reported in the correct period and that internal controls are properly designed to detect and correct errors to the SEFA.
U.S. Department of Health and Human Services 2022-003 Cash Management/Reporting Program(s) Name of Federal Program (Assistance Listing Number) Urban Indian Health Services (93.193) Special Diabetes Program for Indians - Diabetes Prevention and Treatment Projects (93.237) Criteria - Recipients of federal awards must minimize the time elapsing between the receipt of funds from the U.S. Treasury and disbursement by the Organization set out at 2 CFR section 200.305(b). Context and Condition - We compared two quarterly Federal Cash Transaction Reports to total disbursements reported by these two programs in the Organization’s job-costing system. In both reports we found that the amounts requested did not match the amounts in the job-costing system. Cause - Due to increased funding the Organization received to address the impact of COVID-19, disbursements were not always correctly assigned to a program when incurred. Requests for federal funds were made based on those incomplete reports that were changed subsequently and no longer represent the amounts requested. The original reports were not maintained to support the requests made. Effect - A federal program could disburse funds prior to the disbursement by the Organization. We identified that both programs had requested funds in excess of disbursements. Questioned Costs - No costs were questioned. Repeat finding - Yes Statistically valid - Yes Recommendation - We recommend the Organization 1) maintains timely and accurate recording of disbursements in its job-costing system and 2) regularly request grant funds based on amounts expended as report in the Organization’s job-costing system. Views of responsible officials - The Organization is implementing a grant tracking system in addition to its job-costing system to better comply with these requirements. Together, these systems will be used to request only the amount attributable to the program for reimbursement.
U.S. Department of Health and Human Services 2022-003 Cash Management/Reporting Program(s) Name of Federal Program (Assistance Listing Number) Urban Indian Health Services (93.193) Special Diabetes Program for Indians - Diabetes Prevention and Treatment Projects (93.237) Criteria - Recipients of federal awards must minimize the time elapsing between the receipt of funds from the U.S. Treasury and disbursement by the Organization set out at 2 CFR section 200.305(b). Context and Condition - We compared two quarterly Federal Cash Transaction Reports to total disbursements reported by these two programs in the Organization’s job-costing system. In both reports we found that the amounts requested did not match the amounts in the job-costing system. Cause - Due to increased funding the Organization received to address the impact of COVID-19, disbursements were not always correctly assigned to a program when incurred. Requests for federal funds were made based on those incomplete reports that were changed subsequently and no longer represent the amounts requested. The original reports were not maintained to support the requests made. Effect - A federal program could disburse funds prior to the disbursement by the Organization. We identified that both programs had requested funds in excess of disbursements. Questioned Costs - No costs were questioned. Repeat finding - Yes Statistically valid - Yes Recommendation - We recommend the Organization 1) maintains timely and accurate recording of disbursements in its job-costing system and 2) regularly request grant funds based on amounts expended as report in the Organization’s job-costing system. Views of responsible officials - The Organization is implementing a grant tracking system in addition to its job-costing system to better comply with these requirements. Together, these systems will be used to request only the amount attributable to the program for reimbursement.
2 CFR 1201.1 gives regulatory effect to the Department of Transportation for 2 CFR 200.305(b)(3), which states, in part, when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper.The County receives grants, tax rebates, and farebox revenues that are reported to reduce the total expenditures eligible for reimbursement. In the first half of 2022, the formula to calculate the drawdown contained an error that resulted in overstated expenditures. The reimbursement request was submitted based on this work paper and due to the formula error, the drawdown of funds in excess of the eligible expenditures by $50,946.By requesting funds in excess of the calculated eligible expenditures, the County cannot properly account for and expend these funds within the 30 calendar days allotted for the reimbursement method, ultimately resulting in a noncompliance.We recommend the County add additional procedures or controls to further test the accuracy of the work papers used to calculate the reimbursements, prior to submitting them.
2 CFR 1201.1 gives regulatory effect to the Department of Transportation for 2 CFR 200.305(b)(3), which states, in part, when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper.The County receives grants, tax rebates, and farebox revenues that are reported to reduce the total expenditures eligible for reimbursement. In the first half of 2022, the formula to calculate the drawdown contained an error that resulted in overstated expenditures. The reimbursement request was submitted based on this work paper and due to the formula error, the drawdown of funds in excess of the eligible expenditures by $50,946.By requesting funds in excess of the calculated eligible expenditures, the County cannot properly account for and expend these funds within the 30 calendar days allotted for the reimbursement method, ultimately resulting in a noncompliance.We recommend the County add additional procedures or controls to further test the accuracy of the work papers used to calculate the reimbursements, prior to submitting them.
Criteria: In accordance with 2 CFR Section 200.305, non-Federal entities must minimize the time elapsing between the transfer of funds from the Federal agency or pass-through entity and disbursement by the Corporation for program costs and proportionate share of allowable indirect costs. Additionally, 2 CFR Section 200.302(b)(c) requires non-Federal entities to establish written procedures to implement the requirements 2 CFR Section 200.305. The Federal Acquisition Regulation clause at 48 CFR section 52.216-7(b)(1) requires that the non-Federal entity request reimbursement for only allocable, allowable, and reasonable contract costs that have already been paid or incurred. Condition: During our testing of reimbursement requests, we noted that 12 out of 34 sampled requests did not have adequate supporting documentation as to evidence of timely review and approval. Cause: The Corporation did not maintain detailed listings of eligible costs incurred at the time of reimbursement request to support the amount of reimbursement requested in the Payment Management System. Additionally, the Corporation did not maintain documentation of such review or approval that such costs were incurred prior to request for reimbursement, or the amount requested was in accordance with 2 CFR Section 200.305. Eligible cost listings to support amounts drawn during the grant period in total were reconstructed to support annual activity. Effect or Potential Effect: Requests for reimbursement per the Payment Management System may not have minimized the time elapsing between payment by the Federal agency or pass through and disbursement by the Corporation and the amounts requested for reimbursement may be inaccurate. Questioned costs: Unknown Context: We selected 34 reimbursement requests submitted through the Payment Management System and DC Portal during the year ended December 31, 2022. The Corporation was unable to provide evidence of timely review and approval of 12 requests out of 34. Additionally, cost listings were not maintained and were recreated to validate amount of the draw downs during the fiscal year. This is a condition identified per review of the Corporation’s compliance with specified requirements using a statistically valid sample. Repeat finding: This is a repeat finding from prior year. This was reported as finding 2021-009 in the 2021 report. Recommendation: We recommend the Corporation establish formal internal controls, and documentation of their performance, relating to the determination of cash drawn downs and review and approval of drawn downs by appropriate personnel who is knowledgeable of such requirements. View of Responsible Officials: Due to turnover of several key financial executives and personnel and lack of formal documentation of current policies and procedures, the Corporation neither retained support eligible cost listings at the time of reimbursement request nor documented review or approval of such reimbursement request.
Criteria: In accordance with 2 CFR Section 200.305, non-Federal entities must minimize the time elapsing between the transfer of funds from the Federal agency or pass-through entity and disbursement by the Corporation for program costs and proportionate share of allowable indirect costs. Additionally, 2 CFR Section 200.302(b)(c) requires non-Federal entities to establish written procedures to implement the requirements 2 CFR Section 200.305. The Federal Acquisition Regulation clause at 48 CFR section 52.216-7(b)(1) requires that the non-Federal entity request reimbursement for only allocable, allowable, and reasonable contract costs that have already been paid or incurred. Condition: During our testing of reimbursement requests, we noted that 12 out of 34 sampled requests did not have adequate supporting documentation as to evidence of timely review and approval. Cause: The Corporation did not maintain detailed listings of eligible costs incurred at the time of reimbursement request to support the amount of reimbursement requested in the Payment Management System. Additionally, the Corporation did not maintain documentation of such review or approval that such costs were incurred prior to request for reimbursement, or the amount requested was in accordance with 2 CFR Section 200.305. Eligible cost listings to support amounts drawn during the grant period in total were reconstructed to support annual activity. Effect or Potential Effect: Requests for reimbursement per the Payment Management System may not have minimized the time elapsing between payment by the Federal agency or pass through and disbursement by the Corporation and the amounts requested for reimbursement may be inaccurate. Questioned costs: Unknown Context: We selected 34 reimbursement requests submitted through the Payment Management System and DC Portal during the year ended December 31, 2022. The Corporation was unable to provide evidence of timely review and approval of 12 requests out of 34. Additionally, cost listings were not maintained and were recreated to validate amount of the draw downs during the fiscal year. This is a condition identified per review of the Corporation’s compliance with specified requirements using a statistically valid sample. Repeat finding: This is a repeat finding from prior year. This was reported as finding 2021-009 in the 2021 report. Recommendation: We recommend the Corporation establish formal internal controls, and documentation of their performance, relating to the determination of cash drawn downs and review and approval of drawn downs by appropriate personnel who is knowledgeable of such requirements. View of Responsible Officials: Due to turnover of several key financial executives and personnel and lack of formal documentation of current policies and procedures, the Corporation neither retained support eligible cost listings at the time of reimbursement request nor documented review or approval of such reimbursement request.
Criteria: In accordance with 2 CFR Section 200.305, non-Federal entities must minimize the time elapsing between the transfer of funds from the Federal agency or pass-through entity and disbursement by the Corporation for program costs and proportionate share of allowable indirect costs. Additionally, 2 CFR Section 200.302(b)(c) requires non-Federal entities to establish written procedures to implement the requirements 2 CFR Section 200.305. The Federal Acquisition Regulation clause at 48 CFR section 52.216-7(b)(1) requires that the non-Federal entity request reimbursement for only allocable, allowable, and reasonable contract costs that have already been paid or incurred. Condition: During our testing of reimbursement requests, we noted that 12 out of 34 sampled requests did not have adequate supporting documentation as to evidence of timely review and approval. Cause: The Corporation did not maintain detailed listings of eligible costs incurred at the time of reimbursement request to support the amount of reimbursement requested in the Payment Management System. Additionally, the Corporation did not maintain documentation of such review or approval that such costs were incurred prior to request for reimbursement, or the amount requested was in accordance with 2 CFR Section 200.305. Eligible cost listings to support amounts drawn during the grant period in total were reconstructed to support annual activity. Effect or Potential Effect: Requests for reimbursement per the Payment Management System may not have minimized the time elapsing between payment by the Federal agency or pass through and disbursement by the Corporation and the amounts requested for reimbursement may be inaccurate. Questioned costs: Unknown Context: We selected 34 reimbursement requests submitted through the Payment Management System and DC Portal during the year ended December 31, 2022. The Corporation was unable to provide evidence of timely review and approval of 12 requests out of 34. Additionally, cost listings were not maintained and were recreated to validate amount of the draw downs during the fiscal year. This is a condition identified per review of the Corporation’s compliance with specified requirements using a statistically valid sample. Repeat finding: This is a repeat finding from prior year. This was reported as finding 2021-009 in the 2021 report. Recommendation: We recommend the Corporation establish formal internal controls, and documentation of their performance, relating to the determination of cash drawn downs and review and approval of drawn downs by appropriate personnel who is knowledgeable of such requirements. View of Responsible Officials: Due to turnover of several key financial executives and personnel and lack of formal documentation of current policies and procedures, the Corporation neither retained support eligible cost listings at the time of reimbursement request nor documented review or approval of such reimbursement request.
Information on the Federal Program(s): 10.760 Water and Waste Disposal Systems for Rural Communities, Department of Agriculture 14.228 Community Development Block Grants/State’s Program, Department of Housing and Urban Development Compliance Requirements: Cash Management. Type of Finding: Material Noncompliance. Criteria: 2 CFR § 200.302(b)(6) requires that each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR § 200.305 Payment. Condition: We noted that the City did not have written procedures to implement the requirements of 2 CFR § 200.305 Payment during fiscal year 2022. Cause: The City was not aware of the requirement to have written procedures to implement the requirements of 2 CFR § 200.305 Payment. Effect: Failure to have written procedures to ensure the compliance with the 2 CFR § 200.305 Payment could result in federal award drawdown requests by the City to be overstated as to immediate cash flow needs, noncompliance with Uniform Guidance requirements, and terms and conditions of the Federal award. Questioned Costs: There are no questioned costs. Recommendation: We recommend that the City identify grants that are subject to the Uniform Guidance on a timely basis to ensure all compliance requirements are met and develop written procedures where required. Views of Responsible Officials and Planned Corrective Action: The City has identified federal grants subject to the Uniform Guidance and will develop written procedures to implement the requirements of 2 CFR § 200.305 Payment.
Information on the Federal Program(s): 10.760 Water and Waste Disposal Systems for Rural Communities, Department of Agriculture 14.228 Community Development Block Grants/State’s Program, Department of Housing and Urban Development Compliance Requirements: Cash Management. Type of Finding: Material Noncompliance. Criteria: 2 CFR § 200.302(b)(6) requires that each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR § 200.305 Payment. Condition: We noted that the City did not have written procedures to implement the requirements of 2 CFR § 200.305 Payment during fiscal year 2022. Cause: The City was not aware of the requirement to have written procedures to implement the requirements of 2 CFR § 200.305 Payment. Effect: Failure to have written procedures to ensure the compliance with the 2 CFR § 200.305 Payment could result in federal award drawdown requests by the City to be overstated as to immediate cash flow needs, noncompliance with Uniform Guidance requirements, and terms and conditions of the Federal award. Questioned Costs: There are no questioned costs. Recommendation: We recommend that the City identify grants that are subject to the Uniform Guidance on a timely basis to ensure all compliance requirements are met and develop written procedures where required. Views of Responsible Officials and Planned Corrective Action: The City has identified federal grants subject to the Uniform Guidance and will develop written procedures to implement the requirements of 2 CFR § 200.305 Payment.
Information on the Federal Program(s): 10.760 Water and Waste Disposal Systems for Rural Communities, Department of Agriculture 14.228 Community Development Block Grants/State’s Program, Department of Housing and Urban Development Compliance Requirements: Cash Management. Type of Finding: Material Noncompliance. Criteria: 2 CFR § 200.302(b)(6) requires that each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR § 200.305 Payment. Condition: We noted that the City did not have written procedures to implement the requirements of 2 CFR § 200.305 Payment during fiscal year 2022. Cause: The City was not aware of the requirement to have written procedures to implement the requirements of 2 CFR § 200.305 Payment. Effect: Failure to have written procedures to ensure the compliance with the 2 CFR § 200.305 Payment could result in federal award drawdown requests by the City to be overstated as to immediate cash flow needs, noncompliance with Uniform Guidance requirements, and terms and conditions of the Federal award. Questioned Costs: There are no questioned costs. Recommendation: We recommend that the City identify grants that are subject to the Uniform Guidance on a timely basis to ensure all compliance requirements are met and develop written procedures where required. Views of Responsible Officials and Planned Corrective Action: The City has identified federal grants subject to the Uniform Guidance and will develop written procedures to implement the requirements of 2 CFR § 200.305 Payment.
Finding 2022–002: Cash Management Federal Department: U.S. Department of Education Pass-through Agencies: State of South Carolina Department of Education, Minnesota Department of Education, and DC Office of the State Superintendent of Education Federal Program Name: Twenty-First Century Community Learning Centers Assistance Listing Number: 84.287 Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post-Federal Award Requirements Standards Section 200.305, Federal Payments states “when the reimbursement method is used, the Federal agency or pass-through entity must make payment within 30 calendar days after receipt of the payment request unless the Federal agency or pass-through entity reasonably believes the request to be improper.” 2 CFR section 200.305(b)(3) requires that expenditures be incurred prior to the date of the reimbursement request. Condition/Context During the current audit period, CDF is not in accordance with federal regulations regarding the cash management requirements. Exceptions noted in 30 of 30 tested reimbursement requests: For all 30 requests, we were not provided with adequate documentation to determine that expenditures were incurred prior to the date of the reimbursement request. We were only provided with system generated expenditures reports, instead of actual invoices, payroll registers, and payment support. For one request, we did not receive any supporting documentation to substantiate the amount requested. For two requests, we were not provided with the evidence to support the reimbursement requests were internally reviewed and approved prior to submission. Cause Based on our discussions with management, this finding occurred due to staff turnover. This resulted in consistent documentation not maintained to trace the reimbursement submissions to pass-through entities. Effect The failure to maintain adequate documentation to verify the reimbursement request submissions to pass-through entities could result in duplicate submissions of reimbursement requests and delayed reimbursements. Questioned Costs Unable to determine. Identification of Repeat Findings Not a repeat finding. Recommendation We recommend that CDF implement procedures to ensure all reimbursement requests are properly reviewed and approved and submission documentation is maintained in accordance with federal regulations. Views of Responsible Officials and Corrective Action Plan CDF agrees with the finding and recommendation. See CDF’s Corrective Action Plan on pages 17-18.
Finding 2022–002: Cash Management Federal Department: U.S. Department of Education Pass-through Agencies: State of South Carolina Department of Education, Minnesota Department of Education, and DC Office of the State Superintendent of Education Federal Program Name: Twenty-First Century Community Learning Centers Assistance Listing Number: 84.287 Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post-Federal Award Requirements Standards Section 200.305, Federal Payments states “when the reimbursement method is used, the Federal agency or pass-through entity must make payment within 30 calendar days after receipt of the payment request unless the Federal agency or pass-through entity reasonably believes the request to be improper.” 2 CFR section 200.305(b)(3) requires that expenditures be incurred prior to the date of the reimbursement request. Condition/Context During the current audit period, CDF is not in accordance with federal regulations regarding the cash management requirements. Exceptions noted in 30 of 30 tested reimbursement requests: For all 30 requests, we were not provided with adequate documentation to determine that expenditures were incurred prior to the date of the reimbursement request. We were only provided with system generated expenditures reports, instead of actual invoices, payroll registers, and payment support. For one request, we did not receive any supporting documentation to substantiate the amount requested. For two requests, we were not provided with the evidence to support the reimbursement requests were internally reviewed and approved prior to submission. Cause Based on our discussions with management, this finding occurred due to staff turnover. This resulted in consistent documentation not maintained to trace the reimbursement submissions to pass-through entities. Effect The failure to maintain adequate documentation to verify the reimbursement request submissions to pass-through entities could result in duplicate submissions of reimbursement requests and delayed reimbursements. Questioned Costs Unable to determine. Identification of Repeat Findings Not a repeat finding. Recommendation We recommend that CDF implement procedures to ensure all reimbursement requests are properly reviewed and approved and submission documentation is maintained in accordance with federal regulations. Views of Responsible Officials and Corrective Action Plan CDF agrees with the finding and recommendation. See CDF’s Corrective Action Plan on pages 17-18.
Finding 2022–002: Cash Management Federal Department: U.S. Department of Education Pass-through Agencies: State of South Carolina Department of Education, Minnesota Department of Education, and DC Office of the State Superintendent of Education Federal Program Name: Twenty-First Century Community Learning Centers Assistance Listing Number: 84.287 Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post-Federal Award Requirements Standards Section 200.305, Federal Payments states “when the reimbursement method is used, the Federal agency or pass-through entity must make payment within 30 calendar days after receipt of the payment request unless the Federal agency or pass-through entity reasonably believes the request to be improper.” 2 CFR section 200.305(b)(3) requires that expenditures be incurred prior to the date of the reimbursement request. Condition/Context During the current audit period, CDF is not in accordance with federal regulations regarding the cash management requirements. Exceptions noted in 30 of 30 tested reimbursement requests: For all 30 requests, we were not provided with adequate documentation to determine that expenditures were incurred prior to the date of the reimbursement request. We were only provided with system generated expenditures reports, instead of actual invoices, payroll registers, and payment support. For one request, we did not receive any supporting documentation to substantiate the amount requested. For two requests, we were not provided with the evidence to support the reimbursement requests were internally reviewed and approved prior to submission. Cause Based on our discussions with management, this finding occurred due to staff turnover. This resulted in consistent documentation not maintained to trace the reimbursement submissions to pass-through entities. Effect The failure to maintain adequate documentation to verify the reimbursement request submissions to pass-through entities could result in duplicate submissions of reimbursement requests and delayed reimbursements. Questioned Costs Unable to determine. Identification of Repeat Findings Not a repeat finding. Recommendation We recommend that CDF implement procedures to ensure all reimbursement requests are properly reviewed and approved and submission documentation is maintained in accordance with federal regulations. Views of Responsible Officials and Corrective Action Plan CDF agrees with the finding and recommendation. See CDF’s Corrective Action Plan on pages 17-18.
Finding 2022-001: Cash Management (Significant Deficiency) Information on the Federal Program: Research and Development Cluster Criteria: CFR §200.305 states when reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. It also states that excess cash should be returned. Condition: RoboNation received funds in excess of expenditures. Context: Our audit procedures consisted of compliance testwork over RoboNation's reimbursements for funds on all awards included within the research and development cluster. We consider our sample to be representative of the population and a statistically valid sample. Cause: RoboNation requested reimbursement of funds in excess of actual billings. Effect: RoboNation overbilled a grant and had excess cash on hand. This could lead to RoboNation having to return the funds. Questioned Costs: Undetermined Identification as Repeat Finding, if Applicable: 2021-002 Recommendation: We recommend that management of RoboNation be more mindful of the U.S. Government regulations with respect to billings and ensure billings are accurate and properly stated.
Finding 2022-001: Cash Management (Significant Deficiency) Information on the Federal Program: Research and Development Cluster Criteria: CFR §200.305 states when reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. It also states that excess cash should be returned. Condition: RoboNation received funds in excess of expenditures. Context: Our audit procedures consisted of compliance testwork over RoboNation's reimbursements for funds on all awards included within the research and development cluster. We consider our sample to be representative of the population and a statistically valid sample. Cause: RoboNation requested reimbursement of funds in excess of actual billings. Effect: RoboNation overbilled a grant and had excess cash on hand. This could lead to RoboNation having to return the funds. Questioned Costs: Undetermined Identification as Repeat Finding, if Applicable: 2021-002 Recommendation: We recommend that management of RoboNation be more mindful of the U.S. Government regulations with respect to billings and ensure billings are accurate and properly stated.
Finding 2022-001: Cash Management (Significant Deficiency) Information on the Federal Program: Research and Development Cluster Criteria: CFR §200.305 states when reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. It also states that excess cash should be returned. Condition: RoboNation received funds in excess of expenditures. Context: Our audit procedures consisted of compliance testwork over RoboNation's reimbursements for funds on all awards included within the research and development cluster. We consider our sample to be representative of the population and a statistically valid sample. Cause: RoboNation requested reimbursement of funds in excess of actual billings. Effect: RoboNation overbilled a grant and had excess cash on hand. This could lead to RoboNation having to return the funds. Questioned Costs: Undetermined Identification as Repeat Finding, if Applicable: 2021-002 Recommendation: We recommend that management of RoboNation be more mindful of the U.S. Government regulations with respect to billings and ensure billings are accurate and properly stated.
Finding 2022-001: Cash Management (Significant Deficiency) Information on the Federal Program: Research and Development Cluster Criteria: CFR §200.305 states when reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. It also states that excess cash should be returned. Condition: RoboNation received funds in excess of expenditures. Context: Our audit procedures consisted of compliance testwork over RoboNation's reimbursements for funds on all awards included within the research and development cluster. We consider our sample to be representative of the population and a statistically valid sample. Cause: RoboNation requested reimbursement of funds in excess of actual billings. Effect: RoboNation overbilled a grant and had excess cash on hand. This could lead to RoboNation having to return the funds. Questioned Costs: Undetermined Identification as Repeat Finding, if Applicable: 2021-002 Recommendation: We recommend that management of RoboNation be more mindful of the U.S. Government regulations with respect to billings and ensure billings are accurate and properly stated.
Finding 2022-001: Cash Management (Significant Deficiency) Information on the Federal Program: Research and Development Cluster Criteria: CFR §200.305 states when reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. It also states that excess cash should be returned. Condition: RoboNation received funds in excess of expenditures. Context: Our audit procedures consisted of compliance testwork over RoboNation's reimbursements for funds on all awards included within the research and development cluster. We consider our sample to be representative of the population and a statistically valid sample. Cause: RoboNation requested reimbursement of funds in excess of actual billings. Effect: RoboNation overbilled a grant and had excess cash on hand. This could lead to RoboNation having to return the funds. Questioned Costs: Undetermined Identification as Repeat Finding, if Applicable: 2021-002 Recommendation: We recommend that management of RoboNation be more mindful of the U.S. Government regulations with respect to billings and ensure billings are accurate and properly stated.
Finding 2022-001: Cash Management (Significant Deficiency) Information on the Federal Program: Research and Development Cluster Criteria: CFR §200.305 states when reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. It also states that excess cash should be returned. Condition: RoboNation received funds in excess of expenditures. Context: Our audit procedures consisted of compliance testwork over RoboNation's reimbursements for funds on all awards included within the research and development cluster. We consider our sample to be representative of the population and a statistically valid sample. Cause: RoboNation requested reimbursement of funds in excess of actual billings. Effect: RoboNation overbilled a grant and had excess cash on hand. This could lead to RoboNation having to return the funds. Questioned Costs: Undetermined Identification as Repeat Finding, if Applicable: 2021-002 Recommendation: We recommend that management of RoboNation be more mindful of the U.S. Government regulations with respect to billings and ensure billings are accurate and properly stated.
Finding 2022-001: Cash Management (Significant Deficiency) Information on the Federal Program: Research and Development Cluster Criteria: CFR §200.305 states when reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. It also states that excess cash should be returned. Condition: RoboNation received funds in excess of expenditures. Context: Our audit procedures consisted of compliance testwork over RoboNation's reimbursements for funds on all awards included within the research and development cluster. We consider our sample to be representative of the population and a statistically valid sample. Cause: RoboNation requested reimbursement of funds in excess of actual billings. Effect: RoboNation overbilled a grant and had excess cash on hand. This could lead to RoboNation having to return the funds. Questioned Costs: Undetermined Identification as Repeat Finding, if Applicable: 2021-002 Recommendation: We recommend that management of RoboNation be more mindful of the U.S. Government regulations with respect to billings and ensure billings are accurate and properly stated.
Finding 2022-001: Cash Management (Significant Deficiency) Information on the Federal Program: Research and Development Cluster Criteria: CFR §200.305 states when reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. It also states that excess cash should be returned. Condition: RoboNation received funds in excess of expenditures. Context: Our audit procedures consisted of compliance testwork over RoboNation's reimbursements for funds on all awards included within the research and development cluster. We consider our sample to be representative of the population and a statistically valid sample. Cause: RoboNation requested reimbursement of funds in excess of actual billings. Effect: RoboNation overbilled a grant and had excess cash on hand. This could lead to RoboNation having to return the funds. Questioned Costs: Undetermined Identification as Repeat Finding, if Applicable: 2021-002 Recommendation: We recommend that management of RoboNation be more mindful of the U.S. Government regulations with respect to billings and ensure billings are accurate and properly stated.
Finding 2022-001: Cash Management (Significant Deficiency) Information on the Federal Program: Research and Development Cluster Criteria: CFR §200.305 states when reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. It also states that excess cash should be returned. Condition: RoboNation received funds in excess of expenditures. Context: Our audit procedures consisted of compliance testwork over RoboNation's reimbursements for funds on all awards included within the research and development cluster. We consider our sample to be representative of the population and a statistically valid sample. Cause: RoboNation requested reimbursement of funds in excess of actual billings. Effect: RoboNation overbilled a grant and had excess cash on hand. This could lead to RoboNation having to return the funds. Questioned Costs: Undetermined Identification as Repeat Finding, if Applicable: 2021-002 Recommendation: We recommend that management of RoboNation be more mindful of the U.S. Government regulations with respect to billings and ensure billings are accurate and properly stated.
Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering & Office of Cyber Infrastructure AL No.: 47.050, 47.070, 47.079 & 47.080 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2022), OAC- 1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026),OISE-1855654 (05/15/2019 – 12/31/2023) & OAC-1664061 (10/01/17 – 09/30/2022) Pass Through Entity: Utah State University MW2022-007 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF EXPENDITURES Material Weakness Criteria CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the management of cash drawdowns and disbursements of federal funds. Federal funds should be disbursed in a timely manner for allowable costs that have been incurred. Cash advances must meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation. Condition CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation which details the requirements for advance fundings. During 2022, CUAHSI had advance drawdowns totaling $3,862,318 from the NSF. Of this amount, CUAHSI incurred $3,228,996 in eligible expenses for the year ended December 31, 2022. This resulted in $633,322 in excess federal advances as of year-end. The draw downs in excess of revenue recognized during the year ended December 31, 2022 are reported as part of advances payable in the accompanying Statement of Financial Position. Cause & Context CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter VIII.C.3 of the grant agreement.Effect Drawing down funds in advance of incurring eligible expenses could lead to non-compliance with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need to repay the funds, potential financial penalties, or disqualification from future federal funding. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2021-008. Recommendation The auditor recommends that CUAHSI develops and implements controls over policies consistent with 2 CFR 200.35. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering & Office of Cyber Infrastructure AL No.: 47.050, 47.070, 47.079 & 47.080 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2022), OAC- 1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026),OISE-1855654 (05/15/2019 – 12/31/2023) & OAC-1664061 (10/01/17 – 09/30/2022) Pass Through Entity: Utah State University MW2022-007 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF EXPENDITURES Material Weakness Criteria CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the management of cash drawdowns and disbursements of federal funds. Federal funds should be disbursed in a timely manner for allowable costs that have been incurred. Cash advances must meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation. Condition CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation which details the requirements for advance fundings. During 2022, CUAHSI had advance drawdowns totaling $3,862,318 from the NSF. Of this amount, CUAHSI incurred $3,228,996 in eligible expenses for the year ended December 31, 2022. This resulted in $633,322 in excess federal advances as of year-end. The draw downs in excess of revenue recognized during the year ended December 31, 2022 are reported as part of advances payable in the accompanying Statement of Financial Position. Cause & Context CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter VIII.C.3 of the grant agreement.Effect Drawing down funds in advance of incurring eligible expenses could lead to non-compliance with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need to repay the funds, potential financial penalties, or disqualification from future federal funding. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2021-008. Recommendation The auditor recommends that CUAHSI develops and implements controls over policies consistent with 2 CFR 200.35. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering & Office of Cyber Infrastructure AL No.: 47.050, 47.070, 47.079 & 47.080 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2022), OAC- 1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026),OISE-1855654 (05/15/2019 – 12/31/2023) & OAC-1664061 (10/01/17 – 09/30/2022) Pass Through Entity: Utah State University MW2022-007 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF EXPENDITURES Material Weakness Criteria CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the management of cash drawdowns and disbursements of federal funds. Federal funds should be disbursed in a timely manner for allowable costs that have been incurred. Cash advances must meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation. Condition CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation which details the requirements for advance fundings. During 2022, CUAHSI had advance drawdowns totaling $3,862,318 from the NSF. Of this amount, CUAHSI incurred $3,228,996 in eligible expenses for the year ended December 31, 2022. This resulted in $633,322 in excess federal advances as of year-end. The draw downs in excess of revenue recognized during the year ended December 31, 2022 are reported as part of advances payable in the accompanying Statement of Financial Position. Cause & Context CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter VIII.C.3 of the grant agreement.Effect Drawing down funds in advance of incurring eligible expenses could lead to non-compliance with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need to repay the funds, potential financial penalties, or disqualification from future federal funding. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2021-008. Recommendation The auditor recommends that CUAHSI develops and implements controls over policies consistent with 2 CFR 200.35. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering & Office of Cyber Infrastructure AL No.: 47.050, 47.070, 47.079 & 47.080 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2022), OAC- 1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026),OISE-1855654 (05/15/2019 – 12/31/2023) & OAC-1664061 (10/01/17 – 09/30/2022) Pass Through Entity: Utah State University MW2022-007 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF EXPENDITURES Material Weakness Criteria CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the management of cash drawdowns and disbursements of federal funds. Federal funds should be disbursed in a timely manner for allowable costs that have been incurred. Cash advances must meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation. Condition CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National Science Foundation which details the requirements for advance fundings. During 2022, CUAHSI had advance drawdowns totaling $3,862,318 from the NSF. Of this amount, CUAHSI incurred $3,228,996 in eligible expenses for the year ended December 31, 2022. This resulted in $633,322 in excess federal advances as of year-end. The draw downs in excess of revenue recognized during the year ended December 31, 2022 are reported as part of advances payable in the accompanying Statement of Financial Position. Cause & Context CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter VIII.C.3 of the grant agreement.Effect Drawing down funds in advance of incurring eligible expenses could lead to non-compliance with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need to repay the funds, potential financial penalties, or disqualification from future federal funding. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2021-008. Recommendation The auditor recommends that CUAHSI develops and implements controls over policies consistent with 2 CFR 200.35. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.
1. Provide staff training on proper cash management and documentation standards under 2 CFR § 200.305.
1. Provide staff training on proper cash management and documentation standards under 2 CFR § 200.305.
1. Provide staff training on proper cash management and documentation standards under 2 CFR § 200.305.
2 CFR 200.302(b)(6) requires that non-Federal entities establish written procedures to implement the requirements of 2 CFR 200.305. The FAR clause at 48 CFR section 52.216-7 applies to reimbursement payment. Paragraph (b)(1) of that clause requires that the non-federal entity request reimbursement for (a) only allocable, allowable, and reasonable contract costs that have already been paid, or (b) if the non-federal entity is not delinquent in paying costs of contract performance in the ordinary course of business, costs incurred, but not necessarily paid. Article V, Section B states: 1. Periodically, but not more frequently than once every 30 calendar days, the Non-Federal Sponsor shall provide the Government with a sufficient invoice for costs the Non-Federal Sponsor has incurred for the Project. 2. Upon receipt of such sufficient invoice, the Government shall review the costs identified therein and shall determine: (a) the amount to be included in total project costs, subject to the limitations in Article II.C. of this Agreement; (b) the total costs incurred by the parties to date (including the value of lands, easements, rights-of-way, and relocations, and the costs of permits determined in accordance with Article V of this Agreement); (c) each party’s share of total project costs and the costs of data recovery activities associated with historic preservation in accordance with Article II.P. of this Agreement incurred by the parties to date; (d) the costs incurred by each party to date; (e) the total amount of reimbursements the Government has made to date in accordance with this paragraph; (f) the balance of Federal funds available for the Project, as of the date of such review; (g) the amount of reimbursement, if any, due to the Non-Federal Sponsor; and (h) the amount that actually will be paid to the Non-Federal Sponsor (hereinafter the “payment amount”) if the amount of reimbursement determined above cannot be fully paid due to an insufficiency of Federal funds or the limitations of the Section 594 Program Limit for Ohio or the Section 102 Limit. Article I, Section K state the term “sufficient invoice” shall mean documentation provided by the Non-Federal Sponsor containing the following: (1) a written certification by the Non-Federal Sponsor to the Government that it has made specified payments to contractors, suppliers, or employees for performance of work in accordance with this Agreement, or a written certification by the Non-Federal Sponsor to the Government that it has received bills from contractors, suppliers, or employees for performance of work in accordance with this Agreement; (2) copies of all relevant invoices and evidence of such payments or bills received; (3) written identification of such costs that have been paid with Federal program funds and a copy of the written verification from the Federal agency that provided the funds; and (4) a written request for reimbursement for the amount of such specified payments or bills received. The Village received funding from various sources for the project. Due to cash flow issues, the Village often used alternate funding to meet federal obligations, leaving an accumulation of federal funds on hand during the year. The Village also does not have any formal policies in place regarding cash management requirements. We recommend that the Village more closely monitor its reimbursement requests in relation to actual expenditures paid to ensure that the Village does not accumulate federal funds. Additionally, the Village should adopt formal policies and procedures that address cash management requirements.
Federal Agency: U.S. Department of the Treasury Federal Programs: Coronavirus State and Local Fiscal Recovery Funds ALN: 21.027 Award Numbers: SLFRP3168/5205 Award Years: 2021 Type of Finding: Material weakness in internal control over compliance and material noncompliance Criteria: In accordance with 2 CFR Section 200.305, advanced federal funds held in depository institutions must be deposited and maintained in insured accounts. Condition and Context: Internal control procedures related to monitoring insured cash balances were inadequate. The Council had advanced federal funds (deferred revenue) of $10,512,764 as of September 30, 2022. Uninsured and uncollateralized cash balances were $9,328,634 as of September 30, 2022. Cause: Lack of internal controls over the monitoring of insured cash balances. Effect: Failure to follow granting agency requirements could result in loss of federal funding or at a minimum, the Council having to repay portions of the advanced federal funds. Questioned Costs: None. Repeat Finding: This is a repeat of Finding 2021-001, and since this is a repeat finding we believe it to be a systemic issue. Recommendation: We recommend that management that the Council establish policies and controls over special tests and provisions related to monitoring advanced funds to ensure federal funds are properly held in fully insured depository accounts. Management’s Response: Management concurs with this finding. See corrective action plan.
Reference Number: 2022-004 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Cash Management Type of Finding: Material Weakness, Non-compliance Criteria or specific requirement: Non-Federal Entities Other Than States 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)). What constitutes minimized elapsed time for funds transfer will depend on what payment system/method a non-federal entity uses. Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR section 200.3). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the US Treasury and disbursement by the non-federal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR section 200.305(b)(1)). Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. Division receives advance funds from the pass-through agency and incurred program expenditures. Of the Sixty (60) files selected for testing We noted that the Division: (1) Does not have written procedures that minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Cause: Division did not minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Effect: Division’s will be in noncompliance with its cash management compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Views of responsible officials: The Division will strive to minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division See corrective action plan.
Reference Number: 2022-004 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Cash Management Type of Finding: Material Weakness, Non-compliance Criteria or specific requirement: Non-Federal Entities Other Than States 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)). What constitutes minimized elapsed time for funds transfer will depend on what payment system/method a non-federal entity uses. Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR section 200.3). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the US Treasury and disbursement by the non-federal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR section 200.305(b)(1)). Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. Division receives advance funds from the pass-through agency and incurred program expenditures. Of the Sixty (60) files selected for testing We noted that the Division: (1) Does not have written procedures that minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Cause: Division did not minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Effect: Division’s will be in noncompliance with its cash management compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Views of responsible officials: The Division will strive to minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division See corrective action plan.
Reference Number: 2022-004 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Cash Management Type of Finding: Material Weakness, Non-compliance Criteria or specific requirement: Non-Federal Entities Other Than States 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)). What constitutes minimized elapsed time for funds transfer will depend on what payment system/method a non-federal entity uses. Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR section 200.3). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the US Treasury and disbursement by the non-federal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR section 200.305(b)(1)). Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. Division receives advance funds from the pass-through agency and incurred program expenditures. Of the Sixty (60) files selected for testing We noted that the Division: (1) Does not have written procedures that minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Cause: Division did not minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Effect: Division’s will be in noncompliance with its cash management compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Views of responsible officials: The Division will strive to minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division See corrective action plan.
Reference Number: 2022-004 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Cash Management Type of Finding: Material Weakness, Non-compliance Criteria or specific requirement: Non-Federal Entities Other Than States 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)). What constitutes minimized elapsed time for funds transfer will depend on what payment system/method a non-federal entity uses. Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR section 200.3). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the US Treasury and disbursement by the non-federal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR section 200.305(b)(1)). Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. Division receives advance funds from the pass-through agency and incurred program expenditures. Of the Sixty (60) files selected for testing We noted that the Division: (1) Does not have written procedures that minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Cause: Division did not minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Effect: Division’s will be in noncompliance with its cash management compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Views of responsible officials: The Division will strive to minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division See corrective action plan.
Reference Number: 2022-004 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Cash Management Type of Finding: Material Weakness, Non-compliance Criteria or specific requirement: Non-Federal Entities Other Than States 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)). What constitutes minimized elapsed time for funds transfer will depend on what payment system/method a non-federal entity uses. Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR section 200.3). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the US Treasury and disbursement by the non-federal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR section 200.305(b)(1)). Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. Division receives advance funds from the pass-through agency and incurred program expenditures. Of the Sixty (60) files selected for testing We noted that the Division: (1) Does not have written procedures that minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Cause: Division did not minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Effect: Division’s will be in noncompliance with its cash management compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Views of responsible officials: The Division will strive to minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division See corrective action plan.
Reference Number: 2022-004 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Cash Management Type of Finding: Material Weakness, Non-compliance Criteria or specific requirement: Non-Federal Entities Other Than States 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)). What constitutes minimized elapsed time for funds transfer will depend on what payment system/method a non-federal entity uses. Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR section 200.3). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the US Treasury and disbursement by the non-federal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR section 200.305(b)(1)). Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. Division receives advance funds from the pass-through agency and incurred program expenditures. Of the Sixty (60) files selected for testing We noted that the Division: (1) Does not have written procedures that minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Cause: Division did not minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Effect: Division’s will be in noncompliance with its cash management compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Views of responsible officials: The Division will strive to minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division See corrective action plan.
Reference Number: 2022-004 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Cash Management Type of Finding: Material Weakness, Non-compliance Criteria or specific requirement: Non-Federal Entities Other Than States 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)). What constitutes minimized elapsed time for funds transfer will depend on what payment system/method a non-federal entity uses. Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR section 200.3). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the US Treasury and disbursement by the non-federal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR section 200.305(b)(1)). Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. Division receives advance funds from the pass-through agency and incurred program expenditures. Of the Sixty (60) files selected for testing We noted that the Division: (1) Does not have written procedures that minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Cause: Division did not minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Effect: Division’s will be in noncompliance with its cash management compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Views of responsible officials: The Division will strive to minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division See corrective action plan.
Reference Number: 2022-004 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Cash Management Type of Finding: Material Weakness, Non-compliance Criteria or specific requirement: Non-Federal Entities Other Than States 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)). What constitutes minimized elapsed time for funds transfer will depend on what payment system/method a non-federal entity uses. Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR section 200.3). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the US Treasury and disbursement by the non-federal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR section 200.305(b)(1)). Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. Division receives advance funds from the pass-through agency and incurred program expenditures. Of the Sixty (60) files selected for testing We noted that the Division: (1) Does not have written procedures that minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Cause: Division did not minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Effect: Division’s will be in noncompliance with its cash management compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Views of responsible officials: The Division will strive to minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division See corrective action plan.
Reference Number: 2022-004 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Cash Management Type of Finding: Material Weakness, Non-compliance Criteria or specific requirement: Non-Federal Entities Other Than States 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)). What constitutes minimized elapsed time for funds transfer will depend on what payment system/method a non-federal entity uses. Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR section 200.3). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the US Treasury and disbursement by the non-federal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR section 200.305(b)(1)). Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. Division receives advance funds from the pass-through agency and incurred program expenditures. Of the Sixty (60) files selected for testing We noted that the Division: (1) Does not have written procedures that minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Cause: Division did not minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Effect: Division’s will be in noncompliance with its cash management compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Views of responsible officials: The Division will strive to minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division See corrective action plan.
Reference Number: 2022-004 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Cash Management Type of Finding: Material Weakness, Non-compliance Criteria or specific requirement: Non-Federal Entities Other Than States 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)). What constitutes minimized elapsed time for funds transfer will depend on what payment system/method a non-federal entity uses. Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR section 200.3). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the US Treasury and disbursement by the non-federal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR section 200.305(b)(1)). Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. Division receives advance funds from the pass-through agency and incurred program expenditures. Of the Sixty (60) files selected for testing We noted that the Division: (1) Does not have written procedures that minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Cause: Division did not minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Effect: Division’s will be in noncompliance with its cash management compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Views of responsible officials: The Division will strive to minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division See corrective action plan.
Reference Number: 2022-004 Prior Year Finding: No Federal Agency: U.S. Department of Homeland Security/FEMA Pass-through Agency: Various Federal Program: Emergency Food and Shelter National Board Program ALN Number: 97.024 Compliance Requirement: Cash Management Type of Finding: Material Weakness, Non-compliance Criteria or specific requirement: Non-Federal Entities Other Than States 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)). What constitutes minimized elapsed time for funds transfer will depend on what payment system/method a non-federal entity uses. Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR section 200.3). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the US Treasury and disbursement by the non-federal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR section 200.305(b)(1)). Condition: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. Division receives advance funds from the pass-through agency and incurred program expenditures. Of the Sixty (60) files selected for testing We noted that the Division: (1) Does not have written procedures that minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Cause: Division did not minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Effect: Division’s will be in noncompliance with its cash management compliance. Questioned costs: Cannot be determined. Recommendation: We recommend Division minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Views of responsible officials: The Division will strive to minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division See corrective action plan.
2022-002 COVID-19 Higher Education Emergency Relief Fund (HEERF) Condition: Repeat finding. The College did not have adequate internal controls in place to ensure proper record keeping for grant funds. Criteria: U. S. Department of Education cash management requirements are consistent with 2 CFR 200.305 which requires a grantee minimize the time elapsing between the transfer of funds from the United States Treasury and the disbursement by the non-Federal entity. According to the Higher Education Emergency Relief Fund (HEERF) II Frequently Asked Questions (FAQ) #17, grantees must pay the incurred obligation (liquidate) within 3 calendar days for HEERF ALN 84.425F (Institutional Portion) and within 15 days for HEERF ALN 84.425E (Student Portion) of receiving the funds. The design and implementation of proper internal controls and the corresponding proper record keeping procedures are essential to comply with cash management requirements. Cause: It was determined that the College drew down funds expended under both ALN 84.425E and ALN 84.425F from the wrong grants management system accounts. A portion of expenses for ALN 84.425E were drawn from and/or were recorded to the sub-fund for ALN 84.425F and a portion of expenses for ALN 84.425F were drawn from and/or were recorded to the sub-fund for ALN 84.425E. This incorrect recording resulted in substantial positive cash balances reported during the fiscal year under ALN 84.425F which were mostly offset with substantial negative cash balances reported under ALN 84.425E. However, at one point during the fiscal year, this incorrect reporting and drawing down of funds resulted in an overall substantial cash balance recorded for the combined funds." Effect: Due to a lack of properly designed and implemented internal controls, even though based on our test, their were no repeat instances of the College drawing down funds from the wrong grants, it was determined that the College has not put proper controls in place as of September 30, 2022 to sufficiently eliminate this finding in the current audit period. Recommendation: The College should design and implement internal controls to ensure proper record keeping for grant funds and monitor cash balances by individual grants. Views of Responsible Officials: Management agrees with this finding and has taken corrective action
Item 2022-001 Written policies, procedures, and standards of conduct Water and Waste Disposal Systems for Rural Communities Assistance Listing Number 10.760 U.S. Department of Agriculture Grant period: Year ended September 30, 2022 Questioned Costs ? $0 Condition ? The Board does not have all of the written policies, procedures and standards of conduct required by UG. Criteria ? Grantees should have written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. 2 CFR 200, Subparts D & E requires the non-Federal entity to establish and maintain written policies, procedures, and standards of conduct including internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award. Specific requirements relate to the following: ? ? 200.302 Financial management ? ? 200.305 Payment ? ? 200.319 Competition ? ? 200.320 Methods of procurement to be followed ? ? 200.430 Compensation?personal services ? ? 200.431 Compensation?fringe benefits Cause of Condition ? The Board has failed to prepare written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. Potential Effect of Condition ? Lack of written policies, procedures, and standards of conduct could result in noncompliance related to federal awards. Recommendation ? We recommend that the Board implement the required written policies and procedures. Audit finding 2022-001 relates to prior year 2021-001 finding. Updated reference number to current audit year 2022.
Finding 2022-001 ? Return of Interest Earned on Advance Payments Cluster: Research & Development Federal Agency: Department of Defense Assistance Listing Program Title and Number: Military Medical Research and Development ? 12.420 Award Name: Beta Blockers for the Prevention of Acute Exacerbations of COPD Award Identifying Number: W81XWH-15-1-0705 Award Year: 2021-2022 Criteria: UAB is subject to cash management compliance requirements pertaining to the use of advanced funds. 2 CFR section 200.305(b)(9) requires that interest earned by non-federal entities other than states on advances of federal funds be remitted annually to the US Department of Health and Human Services, Payment Management System. Up to $500 per year may be kept for administrative expenses. Condition: While testing UAB?s compliance with Cash Management compliance requirements for the R&D cluster, we identified that UAB had earned interest in excess of $500 (approximately $51,000 in total) on funds associated with one of only two advance payment method awards, but that this interest had not been remitted to the PMS system as required. Questioned Costs: $50,500 Cause: Although UAB does have a process to identify and remit interest earned on advanced payment awards in excess of $500, this process was interrupted by both an award extension request and staff turnover. Effect: Interest earned on advanced funds was not returned in a timely manner. Recommendation: The University should establish procedures to ensure that interest earned on advanced funds is identified and returned annually in accordance with 2 CFR section 200.305(b)(9). View of Responsible Officials: Refer to Management?s Corrective Action Plan for management?s view and corrective action plan for the finding described above.
Finding 2022-001 Lack of Internal Control Over Cash Management Federal Agency: U.S. Department of the Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Award Numbers: SLFRP3171/4774 Award Year: 2021 Type of Finding: Material weakness in internal control over compliance and material noncompliance Criteria: The requirement for cash management as contained in 2 CFR 200.305, states advanced cash payments must be used only for applicable grant programs. Condition and Context: Procedures related to cash management were inadequate to ensure that funds drawn down were not used for other grant expenditures. The Village?s cash balances for all governmental funds amounted to $6,020,657 at September 30, 2022. The unearned revenues were $6,488,378 which resulted in a shortfall of $467,721. The unearned revenue for the CSLFRF was $6,281,497. Cause: Lack of internal controls over cash management. Effect: The Village requested and received advances for various federal programs to cover expenditures. Deposits were used to fund other programs of the Council. Repeat Finding: This is a repeat of Finding 2021-001, and since it is a repeat Finding we believe this to be a systemic issue. Recommendation: We recommend that the Village monitor grant budgets and drawdowns throughout the year and ensure that program funds are not being lent or borrowed between programs in an effort to ensure that unearned revenue balances do not exceed total cash and investments. Management?s Response: Management concurs with this finding. See corrective action plan. Questioned Costs: $467,721, which is the shortfall between cash and the unearned revenue balances across all government funds.
2022-001 ? Cash Management Program: AL # 19.519 ? Overseas Refugee Assistance Program for Near East, Direct Award Number: SPRMC021CA3120, SPRMCO22CA0166 Sponsor Agency: U.S. Department of State Criteria: Non-Federal entities must minimize the time elapsing between the transfer of funds from the US Treasury. The non-federal agency must 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. The non-Federal entity must disburse funds available before requesting additional cash payments. Citation: 2 CFR 200.305 Condition: RSN does not have written procedures as required as outlined above. The process RSN uses to make requests for advance payments is to perform a detailed analysis of all expenses anticipated for the quarter. Cause: As a small entity, formal policies were not considered feasible. Effect: There is a risk that the time elapsing between transfer of funds from the U.S. Treasury and the disbursements to vendors may not be minimized. Questioned Costs: None. Context: The amount of cash on hand at the end of each period prior to a drawdown ranged from $12,777 to $174,531 on contract SPRMCO21CA3120. Cash on hand at year end for contract SPRMCO22CAO166 was $485,741. Repeat Finding: No Recommendation: We recommend that management create written procedures to minimize the time elapsing between transfer of funds from the U.S. Treasury. Requests for quarterly advances should factor in cash unspent at the end of the most recent period. Views of Responsible Officials: See Corrective Action Plan attached.
2022-001 ? Cash Management Program: AL # 19.519 ? Overseas Refugee Assistance Program for Near East, Direct Award Number: SPRMC021CA3120, SPRMCO22CA0166 Sponsor Agency: U.S. Department of State Criteria: Non-Federal entities must minimize the time elapsing between the transfer of funds from the US Treasury. The non-federal agency must 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. The non-Federal entity must disburse funds available before requesting additional cash payments. Citation: 2 CFR 200.305 Condition: RSN does not have written procedures as required as outlined above. The process RSN uses to make requests for advance payments is to perform a detailed analysis of all expenses anticipated for the quarter. Cause: As a small entity, formal policies were not considered feasible. Effect: There is a risk that the time elapsing between transfer of funds from the U.S. Treasury and the disbursements to vendors may not be minimized. Questioned Costs: None. Context: The amount of cash on hand at the end of each period prior to a drawdown ranged from $12,777 to $174,531 on contract SPRMCO21CA3120. Cash on hand at year end for contract SPRMCO22CAO166 was $485,741. Repeat Finding: No Recommendation: We recommend that management create written procedures to minimize the time elapsing between transfer of funds from the U.S. Treasury. Requests for quarterly advances should factor in cash unspent at the end of the most recent period. Views of Responsible Officials: See Corrective Action Plan attached.