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.
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.
Finding 2022-001 ? Non-compliance with Cash Management Requirements of the Capital Fund Program (Other Non-Compliance) Capital Fund Program ? Assistance Listing No. 14.872, Grant Period: Fiscal Year-End September 30, 2022 Criteria Uniform Guidance Cash Management requirements of the Capital Fund Program require the Authority to minimize time elapsing between the transfer of funds from the U.S. Treasury and disbursement to the applicable contractors or vendors (2 CFR Section 200.305.b). Condition As of the beginning of fiscal year 2022 the Authority held $122,491 of unexpended grant draws, which were allocated within the grant budgets for capital improvement expenditures, from the 2019 and 2020 Capital Fund Program grants. Instead of funding capital improvement expenditures from these unexpended funds during the fiscal year 2022, the Authority continued to draw funds from Capital Fund Program grants to fund fiscal year 2022 capital expenditures. Also, during fiscal year 2022 the Authority drew down an additional $141,810 of grant draws, which were allocated within the grant budgets for capital improvement expenditures, from the 2019; 2020 and 2021 Capital Fund Program grants in excess of applicable fiscal year 2022 grant expenditures, which resulted in cumulative unexpended grant draws (unearned grant revenue) as of September 30, 2022 of $264,301. Questioned Costs - None Cause The failure to expend the $122,491 of unexpended grant draws which were held as of the beginning of the fiscal year appears to be a result of A) the Authority not posting applicable prior year audit adjustments into its general ledger accounting software, and B) failure to attain an understanding of certain account balances as of the beginning of the fiscal year. The excess, unexpended draw-downs which occurred during fiscal year 2022 of $141,810 appear to be a result of a failure to adequately track grant expenditures to applicable grants, as these expenditures of $141,810 were funded during fiscal year 2022 with grant draws from a HOME Investment Partnerships Program grant. Effect Non-compliance with Uniform Guidance Cash Management requirements of the Capital Fund Program. Recommendation We recommend that the Authority expend the unexpended Capital Fund Program grant proceeds held, prior to drawing down additional funding from Capital Fund Program grant allocations which are budgeted for capital improvements. Management?s Response The Authority will expend the unexpended Capital Fund Program grant proceeds held, prior to drawing down additional funding from Capital Fund Program grant allocations which are budgeted for capital improvements. The Authority?s Executive Director, Jeff Sklet has assumed the responsibility of executing this corrective action as of March 31, 2024.
Finding 2022-001 Lack of Internal Controls over Cash Management Federal Agency: U.S. Department of the Interior Federal Programs: Tribal Management Subsistence Assistance Listing Numbers: 15.036 Award Numbers: A21AV01012, A20AV01058 Award Years: 2021, 2020, respectively Type of Finding: Material weakness in internal control over compliance and material noncompliance. Criteria: The requirements for cash management contained in 2 CFR Section 200.305 state advanced cash payments must be used only for applicable grant programs. Condition and Context: Procedures related to cash management were inadequate to ensure that grant funds drawn down were used for grant expenditures in the program, which received the program advances. We compared the unearned revenue balances of the grant funds with the available cash balances at year end. AITRC?s cash balances amounted to $683,313 at September 30, 2022. The unearned revenues were $713,247, which resulted in a shortfall of $29,934. The Tribal Management Subsistence Program had unearned revenues of $543,071 at September 30, 2022. Cause: Inadequate internal controls over the use of restricted program funds. The shortfall also results from the timing difference from when AITRC pays for expenditures and receives reimbursement from granting agencies. Effect: Unearned revenue balances exceeded cash balances at year end. Questioned Costs: $29,934, which is the difference between deferred revenue and cash balances as of September 30, 2022. Repeat Finding: This is believed to be an isolated incident as this is not a repeat finding. Recommendation: Management should implement internal controls and policies to limit the timing between cash outflows and reimbursement from granting agencies. Management Response: Management agrees with this finding, see Corrective Action Plan.
2022-004 Significant Deficiency in Compliance ? Special Tests ? Collateralization, repeat of 2022-002 Identification of federal programs: 21.027 Coronavirus State and Local Fiscal Recover Funds 2022-002 Collateralization ? Significant Deficiency in Compliance and Internal Controls over Compliance ? Special Tests Criteria: 2 CFR part 200 subpart -D section 200.305(b)(7)(ii) states that ?Advance payments of Federal funds must be deposited and maintained in insured accounts whenever possible.? Condition: The accounts at the banking institution were not collateralized. Cause: Klawock Cooperative Association has changed banking institution and has not set up the collateralization at the new bank. Effect or potential effect: The Association was not in compliance with Federal compliance requirements. Additionally, if the bank fails, federal funds would be put at risk. Recommendation: Klawock Cooperative should immediately have the bank provide collateralization. Views of Responsible Officials: Management agrees. See Corrective Action Plan
Item 2022-001 Uniform Guidance Written Policies, Procedures and Standards of Conduct (Repeat Item 2019-001) U.S. Department of Agriculture Water and Waste Disposal Systems for Rural Communities Assistance Listing #10.760 Year Ended September 30, 2022 Criteria ? Grantees should have written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. 2 CFR 200, Subparts D & E requires the non-Federal entity to establish and maintain written policies, procedures, and standards of conduct including internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award. Specific requirements relate to the following: ? ? 200.302 Financial management ? ? 200.305 Payment Condition ? The City does not have written policies, procedures and standards of conduct. Cause ? The entity has failed to prepare written policies, procedures, and standards of conduct as required by 2 CFR 200, Subparts D & E of the Uniform Guidance. Questioned Costs ? Not determinable Effect ? Lack of written policies, procedures, and standards of conduct could result in noncompliance related to federal awards. Recommendation ? We recommend that the Commission prepare written policies, procedures, and standards of conduct to include all the required elements as provided in 2 CFR 200, Subparts D & E of the Uniform Guidance. Management?s Response ? The City will consider all recommendations.
Material Instance of Non-Compliance Cash Management of Federal Funds This finding impacts the cash management compliance requirement for the major program, Health Center Program Cluster, Assistance Listing Numbers 93.224 - Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and 93.527 - Grants for New and Expanded Services under the Health Center Program, funded by the Health Resources and Services Administration, Department of Health and Human Services. Criteria: The Health Center must follow the cash management standards set out in 2 CFR section 200.305 whereby they must minimize the time elapsing between the transfer of funds from the Federal awarding agency and disbursing the funds if they are not following the reimbursement method. Condition: During our audit of the Health Center, we noted unearned revenue (conditional grant advance) of $2,081,951 of Federal funds related to the Health Center Program Cluster. Cause: During fiscal year 2022, the Health Center had planned expenditures late in the fiscal year that they could fund from the Health Center Program. In order to have the cash on hand to fund these expenditures, they drew the funds in advance of incurring the expenses. Circumstances changed and they were unable to spend the funds in a timely manner and, therefore, the Health Center did not incur allowable expenses to recognize the revenue during fiscal year 2022. Effect: The Health Center is not in compliance with Federal regulations regarding cash management. Recommendation: Management should do a thorough review of all contracts to ensure they are not drawing funds prior to incurring expenditures to ensure they are properly following cash management regulations for Federal contracts. Management Response: Codman Square Health Center, Inc. (the Health Center) received a two-year $4.053 million HRSA Workforce Development grant from April 1, 2021, through March 31, 2023. The funding was provided to support staffing recruitment and retention efforts as summarized by HRSA ? ?On Thursday, April 1, 2021, HRSA awarded more than $6.1 billion in funding provided by the American Rescue Plan Act (ARPA) to 1,377 HRSA-funded health centers (activity code H8F). The purposes of the ARPA funding are to prevent, mitigate, and respond to Coronavirus disease 2019 (COVID-19) and to enhance health care services and infrastructure. Consistent with these purposes, funding may support a wide range of in-scope activities, which may change as COVID-19 circumstances and related community, patient, and organizational needs evolve over the two-year period of performance?. We began program implementation on September 6, 2021, and management drew down $1 million on November 17, 2021, to cover eligible spent monies for that period. An additional $1 million was drawn down on June 1, 2022, to cover eligible expenditures as of May 2022, in the amount of $1,176,844. It was anticipated that there was a total of $1.9 million in eligible expenses to be spent in the month of September 2022 which included items such as retention bonuses, leadership training, staff recruitment, and placement costs. These expenses were never realized prior to August 2022 draw down. The remaining HRSA ARPA funds were expended by March 31, 2023. The Health Center was consistent with adhering to the proper grant billing procedures for the first two drawdowns. The Health Center will follow HRSA Compliance requirements detailed in Compliance Requirements - Cash Management and will draw down HRSA grants on an incurred cost reimbursement basis.
Material Instance of Non-Compliance Cash Management of Federal Funds This finding impacts the cash management compliance requirement for the major program, Health Center Program Cluster, Assistance Listing Numbers 93.224 - Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and 93.527 - Grants for New and Expanded Services under the Health Center Program, funded by the Health Resources and Services Administration, Department of Health and Human Services. Criteria: The Health Center must follow the cash management standards set out in 2 CFR section 200.305 whereby they must minimize the time elapsing between the transfer of funds from the Federal awarding agency and disbursing the funds if they are not following the reimbursement method. Condition: During our audit of the Health Center, we noted unearned revenue (conditional grant advance) of $2,081,951 of Federal funds related to the Health Center Program Cluster. Cause: During fiscal year 2022, the Health Center had planned expenditures late in the fiscal year that they could fund from the Health Center Program. In order to have the cash on hand to fund these expenditures, they drew the funds in advance of incurring the expenses. Circumstances changed and they were unable to spend the funds in a timely manner and, therefore, the Health Center did not incur allowable expenses to recognize the revenue during fiscal year 2022. Effect: The Health Center is not in compliance with Federal regulations regarding cash management. Recommendation: Management should do a thorough review of all contracts to ensure they are not drawing funds prior to incurring expenditures to ensure they are properly following cash management regulations for Federal contracts. Management Response: Codman Square Health Center, Inc. (the Health Center) received a two-year $4.053 million HRSA Workforce Development grant from April 1, 2021, through March 31, 2023. The funding was provided to support staffing recruitment and retention efforts as summarized by HRSA ? ?On Thursday, April 1, 2021, HRSA awarded more than $6.1 billion in funding provided by the American Rescue Plan Act (ARPA) to 1,377 HRSA-funded health centers (activity code H8F). The purposes of the ARPA funding are to prevent, mitigate, and respond to Coronavirus disease 2019 (COVID-19) and to enhance health care services and infrastructure. Consistent with these purposes, funding may support a wide range of in-scope activities, which may change as COVID-19 circumstances and related community, patient, and organizational needs evolve over the two-year period of performance?. We began program implementation on September 6, 2021, and management drew down $1 million on November 17, 2021, to cover eligible spent monies for that period. An additional $1 million was drawn down on June 1, 2022, to cover eligible expenditures as of May 2022, in the amount of $1,176,844. It was anticipated that there was a total of $1.9 million in eligible expenses to be spent in the month of September 2022 which included items such as retention bonuses, leadership training, staff recruitment, and placement costs. These expenses were never realized prior to August 2022 draw down. The remaining HRSA ARPA funds were expended by March 31, 2023. The Health Center was consistent with adhering to the proper grant billing procedures for the first two drawdowns. The Health Center will follow HRSA Compliance requirements detailed in Compliance Requirements - Cash Management and will draw down HRSA grants on an incurred cost reimbursement basis.
Material Instance of Non-Compliance Cash Management of Federal Funds This finding impacts the cash management compliance requirement for the major program, Health Center Program Cluster, Assistance Listing Numbers 93.224 - Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) and 93.527 - Grants for New and Expanded Services under the Health Center Program, funded by the Health Resources and Services Administration, Department of Health and Human Services. Criteria: The Health Center must follow the cash management standards set out in 2 CFR section 200.305 whereby they must minimize the time elapsing between the transfer of funds from the Federal awarding agency and disbursing the funds if they are not following the reimbursement method. Condition: During our audit of the Health Center, we noted unearned revenue (conditional grant advance) of $2,081,951 of Federal funds related to the Health Center Program Cluster. Cause: During fiscal year 2022, the Health Center had planned expenditures late in the fiscal year that they could fund from the Health Center Program. In order to have the cash on hand to fund these expenditures, they drew the funds in advance of incurring the expenses. Circumstances changed and they were unable to spend the funds in a timely manner and, therefore, the Health Center did not incur allowable expenses to recognize the revenue during fiscal year 2022. Effect: The Health Center is not in compliance with Federal regulations regarding cash management. Recommendation: Management should do a thorough review of all contracts to ensure they are not drawing funds prior to incurring expenditures to ensure they are properly following cash management regulations for Federal contracts. Management Response: Codman Square Health Center, Inc. (the Health Center) received a two-year $4.053 million HRSA Workforce Development grant from April 1, 2021, through March 31, 2023. The funding was provided to support staffing recruitment and retention efforts as summarized by HRSA ? ?On Thursday, April 1, 2021, HRSA awarded more than $6.1 billion in funding provided by the American Rescue Plan Act (ARPA) to 1,377 HRSA-funded health centers (activity code H8F). The purposes of the ARPA funding are to prevent, mitigate, and respond to Coronavirus disease 2019 (COVID-19) and to enhance health care services and infrastructure. Consistent with these purposes, funding may support a wide range of in-scope activities, which may change as COVID-19 circumstances and related community, patient, and organizational needs evolve over the two-year period of performance?. We began program implementation on September 6, 2021, and management drew down $1 million on November 17, 2021, to cover eligible spent monies for that period. An additional $1 million was drawn down on June 1, 2022, to cover eligible expenditures as of May 2022, in the amount of $1,176,844. It was anticipated that there was a total of $1.9 million in eligible expenses to be spent in the month of September 2022 which included items such as retention bonuses, leadership training, staff recruitment, and placement costs. These expenses were never realized prior to August 2022 draw down. The remaining HRSA ARPA funds were expended by March 31, 2023. The Health Center was consistent with adhering to the proper grant billing procedures for the first two drawdowns. The Health Center will follow HRSA Compliance requirements detailed in Compliance Requirements - Cash Management and will draw down HRSA grants on an incurred cost reimbursement basis.
2022-006 AL# 66.468 – Capitalization Grants for Drinking Water State Revolving Funds Environmental Protection Agency – Passed Through the Alabama State Department of Environmental Management C – Cash Management Material Weakness and Noncompliance Criteria: The SRF Loan program is a reimbursable grant administered by ADEM. When non-Federal entities are funded under the reimbursement method, the entity they request reimbursement for expenses paid that are allowable to the grant under (2CFR section 200.305(b)(3)) and Section 2.2(b) of the Special Conditions Loan Agreement. Condition: During test work, instances were noted where The Water Works and Gas Board of the City of Red Bay did not pay the cost of the invoices prior to requesting reimbursement. The expenditures were allowable and approved by Alabama State Department of Environmental Management for reimbursement, but the invoices were not paid prior to requesting the reimbursement from Alabama State Department of Environmental Management. Context: The Water Works and Gas Board of the City of Red Bay did not ensure that invoices were paid prior to submitting them for reimbursement to Alabama State Department of Environmental Management. Effect: The entity is not in compliance with 2 CFR section 200.305(b)(3) and Section 2.2(b) of the Special Conditions Loan Agreement. Cause: The Water Works and Gas Board of the City of Red Bay did not ensure that invoices were paid prior to requesting reimbursement. Repeat Finding: No Recommendation: The Water Works and Gas Board of the City of Red Bay should ensure that invoices are paid prior to requesting reimbursement from the pass-through entity. Board’s Response: The Water Works and Gas Board of the City of Red Bay will ensure payments under reimbursable grants are made prior to reimbursement requests.
2022-006 Department of State ? Bureau of Population, Refugees, and MigrationFederal Financial Assistance Listing #19.517, Overseas Refugee Assistance Programs for Africa Agency for International DevelopmentDepartment of State - Federal Financial Assistance Listing #98.001, USAID Foreign Assistance for Programs OverseasCash ManagementType of Finding: Significant Deficiency in Internal Control over ComplianceGrant Award Number: Affects all grant awards included under Federal Financial Assistance Listing #19.517 on the Schedule, and award number 720BHA22GR00046 under Federal Financial Assistance Listing #98.001 on the Schedule.Criteria: Uniform Guidance and 2 CFR section 200.305 sets forth the advance payments? standards non-federal entities, other than states, must follow when operating federal programs and the requirement that cash advances be placed in an interest-bearing account. CVT?s internal control structure should be designed to properly place funds received as cash advances are placed in an interest-bearing account.Condition: CVT does not have internal control system designed to ensure advance payments are placed in an interest-bearing account.Cause: Controls were not adequately designed due to lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections.Effect: Risk of interest income that should be earned and reported.Questioned Costs: None reportedContext/Sampling: For Federal Financial Assistance Listing #19.517, a nonstatistical sample of 6 requests out of 31 total requests were selected for testing. For Federal Financial Assistance Listing #98.001, a nonstatistical sample of 4 requests out of 17 total requests were selected for testing.Repeat Finding from Prior Year: NoRecommendation: We recommend management complete an extensive review over cash management policies to make sure requirements under the CFR section are met.Views of Responsible Officials: Management agrees with this finding.
2022-006 Department of State ? Bureau of Population, Refugees, and MigrationFederal Financial Assistance Listing #19.517, Overseas Refugee Assistance Programs for Africa Agency for International DevelopmentDepartment of State - Federal Financial Assistance Listing #98.001, USAID Foreign Assistance for Programs OverseasCash ManagementType of Finding: Significant Deficiency in Internal Control over ComplianceGrant Award Number: Affects all grant awards included under Federal Financial Assistance Listing #19.517 on the Schedule, and award number 720BHA22GR00046 under Federal Financial Assistance Listing #98.001 on the Schedule.Criteria: Uniform Guidance and 2 CFR section 200.305 sets forth the advance payments? standards non-federal entities, other than states, must follow when operating federal programs and the requirement that cash advances be placed in an interest-bearing account. CVT?s internal control structure should be designed to properly place funds received as cash advances are placed in an interest-bearing account.Condition: CVT does not have internal control system designed to ensure advance payments are placed in an interest-bearing account.Cause: Controls were not adequately designed due to lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections.Effect: Risk of interest income that should be earned and reported.Questioned Costs: None reportedContext/Sampling: For Federal Financial Assistance Listing #19.517, a nonstatistical sample of 6 requests out of 31 total requests were selected for testing. For Federal Financial Assistance Listing #98.001, a nonstatistical sample of 4 requests out of 17 total requests were selected for testing.Repeat Finding from Prior Year: NoRecommendation: We recommend management complete an extensive review over cash management policies to make sure requirements under the CFR section are met.Views of Responsible Officials: Management agrees with this finding.
2022-006 Department of State ? Bureau of Population, Refugees, and MigrationFederal Financial Assistance Listing #19.517, Overseas Refugee Assistance Programs for Africa Agency for International DevelopmentDepartment of State - Federal Financial Assistance Listing #98.001, USAID Foreign Assistance for Programs OverseasCash ManagementType of Finding: Significant Deficiency in Internal Control over ComplianceGrant Award Number: Affects all grant awards included under Federal Financial Assistance Listing #19.517 on the Schedule, and award number 720BHA22GR00046 under Federal Financial Assistance Listing #98.001 on the Schedule.Criteria: Uniform Guidance and 2 CFR section 200.305 sets forth the advance payments? standards non-federal entities, other than states, must follow when operating federal programs and the requirement that cash advances be placed in an interest-bearing account. CVT?s internal control structure should be designed to properly place funds received as cash advances are placed in an interest-bearing account.Condition: CVT does not have internal control system designed to ensure advance payments are placed in an interest-bearing account.Cause: Controls were not adequately designed due to lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections.Effect: Risk of interest income that should be earned and reported.Questioned Costs: None reportedContext/Sampling: For Federal Financial Assistance Listing #19.517, a nonstatistical sample of 6 requests out of 31 total requests were selected for testing. For Federal Financial Assistance Listing #98.001, a nonstatistical sample of 4 requests out of 17 total requests were selected for testing.Repeat Finding from Prior Year: NoRecommendation: We recommend management complete an extensive review over cash management policies to make sure requirements under the CFR section are met.Views of Responsible Officials: Management agrees with this finding.
2022-006 Department of State ? Bureau of Population, Refugees, and MigrationFederal Financial Assistance Listing #19.517, Overseas Refugee Assistance Programs for Africa Agency for International DevelopmentDepartment of State - Federal Financial Assistance Listing #98.001, USAID Foreign Assistance for Programs OverseasCash ManagementType of Finding: Significant Deficiency in Internal Control over ComplianceGrant Award Number: Affects all grant awards included under Federal Financial Assistance Listing #19.517 on the Schedule, and award number 720BHA22GR00046 under Federal Financial Assistance Listing #98.001 on the Schedule.Criteria: Uniform Guidance and 2 CFR section 200.305 sets forth the advance payments? standards non-federal entities, other than states, must follow when operating federal programs and the requirement that cash advances be placed in an interest-bearing account. CVT?s internal control structure should be designed to properly place funds received as cash advances are placed in an interest-bearing account.Condition: CVT does not have internal control system designed to ensure advance payments are placed in an interest-bearing account.Cause: Controls were not adequately designed due to lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections.Effect: Risk of interest income that should be earned and reported.Questioned Costs: None reportedContext/Sampling: For Federal Financial Assistance Listing #19.517, a nonstatistical sample of 6 requests out of 31 total requests were selected for testing. For Federal Financial Assistance Listing #98.001, a nonstatistical sample of 4 requests out of 17 total requests were selected for testing.Repeat Finding from Prior Year: NoRecommendation: We recommend management complete an extensive review over cash management policies to make sure requirements under the CFR section are met.Views of Responsible Officials: Management agrees with this finding.
2022-006 Department of State ? Bureau of Population, Refugees, and MigrationFederal Financial Assistance Listing #19.517, Overseas Refugee Assistance Programs for Africa Agency for International DevelopmentDepartment of State - Federal Financial Assistance Listing #98.001, USAID Foreign Assistance for Programs OverseasCash ManagementType of Finding: Significant Deficiency in Internal Control over ComplianceGrant Award Number: Affects all grant awards included under Federal Financial Assistance Listing #19.517 on the Schedule, and award number 720BHA22GR00046 under Federal Financial Assistance Listing #98.001 on the Schedule.Criteria: Uniform Guidance and 2 CFR section 200.305 sets forth the advance payments? standards non-federal entities, other than states, must follow when operating federal programs and the requirement that cash advances be placed in an interest-bearing account. CVT?s internal control structure should be designed to properly place funds received as cash advances are placed in an interest-bearing account.Condition: CVT does not have internal control system designed to ensure advance payments are placed in an interest-bearing account.Cause: Controls were not adequately designed due to lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections.Effect: Risk of interest income that should be earned and reported.Questioned Costs: None reportedContext/Sampling: For Federal Financial Assistance Listing #19.517, a nonstatistical sample of 6 requests out of 31 total requests were selected for testing. For Federal Financial Assistance Listing #98.001, a nonstatistical sample of 4 requests out of 17 total requests were selected for testing.Repeat Finding from Prior Year: NoRecommendation: We recommend management complete an extensive review over cash management policies to make sure requirements under the CFR section are met.Views of Responsible Officials: Management agrees with this finding.
2022-006 Department of State ? Bureau of Population, Refugees, and MigrationFederal Financial Assistance Listing #19.517, Overseas Refugee Assistance Programs for Africa Agency for International DevelopmentDepartment of State - Federal Financial Assistance Listing #98.001, USAID Foreign Assistance for Programs OverseasCash ManagementType of Finding: Significant Deficiency in Internal Control over ComplianceGrant Award Number: Affects all grant awards included under Federal Financial Assistance Listing #19.517 on the Schedule, and award number 720BHA22GR00046 under Federal Financial Assistance Listing #98.001 on the Schedule.Criteria: Uniform Guidance and 2 CFR section 200.305 sets forth the advance payments? standards non-federal entities, other than states, must follow when operating federal programs and the requirement that cash advances be placed in an interest-bearing account. CVT?s internal control structure should be designed to properly place funds received as cash advances are placed in an interest-bearing account.Condition: CVT does not have internal control system designed to ensure advance payments are placed in an interest-bearing account.Cause: Controls were not adequately designed due to lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections.Effect: Risk of interest income that should be earned and reported.Questioned Costs: None reportedContext/Sampling: For Federal Financial Assistance Listing #19.517, a nonstatistical sample of 6 requests out of 31 total requests were selected for testing. For Federal Financial Assistance Listing #98.001, a nonstatistical sample of 4 requests out of 17 total requests were selected for testing.Repeat Finding from Prior Year: NoRecommendation: We recommend management complete an extensive review over cash management policies to make sure requirements under the CFR section are met.Views of Responsible Officials: Management agrees with this finding.
2022-006 Department of State ? Bureau of Population, Refugees, and MigrationFederal Financial Assistance Listing #19.517, Overseas Refugee Assistance Programs for Africa Agency for International DevelopmentDepartment of State - Federal Financial Assistance Listing #98.001, USAID Foreign Assistance for Programs OverseasCash ManagementType of Finding: Significant Deficiency in Internal Control over ComplianceGrant Award Number: Affects all grant awards included under Federal Financial Assistance Listing #19.517 on the Schedule, and award number 720BHA22GR00046 under Federal Financial Assistance Listing #98.001 on the Schedule.Criteria: Uniform Guidance and 2 CFR section 200.305 sets forth the advance payments? standards non-federal entities, other than states, must follow when operating federal programs and the requirement that cash advances be placed in an interest-bearing account. CVT?s internal control structure should be designed to properly place funds received as cash advances are placed in an interest-bearing account.Condition: CVT does not have internal control system designed to ensure advance payments are placed in an interest-bearing account.Cause: Controls were not adequately designed due to lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections.Effect: Risk of interest income that should be earned and reported.Questioned Costs: None reportedContext/Sampling: For Federal Financial Assistance Listing #19.517, a nonstatistical sample of 6 requests out of 31 total requests were selected for testing. For Federal Financial Assistance Listing #98.001, a nonstatistical sample of 4 requests out of 17 total requests were selected for testing.Repeat Finding from Prior Year: NoRecommendation: We recommend management complete an extensive review over cash management policies to make sure requirements under the CFR section are met.Views of Responsible Officials: Management agrees with this finding.
2022-006 Department of State ? Bureau of Population, Refugees, and MigrationFederal Financial Assistance Listing #19.517, Overseas Refugee Assistance Programs for Africa Agency for International DevelopmentDepartment of State - Federal Financial Assistance Listing #98.001, USAID Foreign Assistance for Programs OverseasCash ManagementType of Finding: Significant Deficiency in Internal Control over ComplianceGrant Award Number: Affects all grant awards included under Federal Financial Assistance Listing #19.517 on the Schedule, and award number 720BHA22GR00046 under Federal Financial Assistance Listing #98.001 on the Schedule.Criteria: Uniform Guidance and 2 CFR section 200.305 sets forth the advance payments? standards non-federal entities, other than states, must follow when operating federal programs and the requirement that cash advances be placed in an interest-bearing account. CVT?s internal control structure should be designed to properly place funds received as cash advances are placed in an interest-bearing account.Condition: CVT does not have internal control system designed to ensure advance payments are placed in an interest-bearing account.Cause: Controls were not adequately designed due to lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections.Effect: Risk of interest income that should be earned and reported.Questioned Costs: None reportedContext/Sampling: For Federal Financial Assistance Listing #19.517, a nonstatistical sample of 6 requests out of 31 total requests were selected for testing. For Federal Financial Assistance Listing #98.001, a nonstatistical sample of 4 requests out of 17 total requests were selected for testing.Repeat Finding from Prior Year: NoRecommendation: We recommend management complete an extensive review over cash management policies to make sure requirements under the CFR section are met.Views of Responsible Officials: Management agrees with this finding.
2022-006 Department of State ? Bureau of Population, Refugees, and MigrationFederal Financial Assistance Listing #19.517, Overseas Refugee Assistance Programs for Africa Agency for International DevelopmentDepartment of State - Federal Financial Assistance Listing #98.001, USAID Foreign Assistance for Programs OverseasCash ManagementType of Finding: Significant Deficiency in Internal Control over ComplianceGrant Award Number: Affects all grant awards included under Federal Financial Assistance Listing #19.517 on the Schedule, and award number 720BHA22GR00046 under Federal Financial Assistance Listing #98.001 on the Schedule.Criteria: Uniform Guidance and 2 CFR section 200.305 sets forth the advance payments? standards non-federal entities, other than states, must follow when operating federal programs and the requirement that cash advances be placed in an interest-bearing account. CVT?s internal control structure should be designed to properly place funds received as cash advances are placed in an interest-bearing account.Condition: CVT does not have internal control system designed to ensure advance payments are placed in an interest-bearing account.Cause: Controls were not adequately designed due to lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections.Effect: Risk of interest income that should be earned and reported.Questioned Costs: None reportedContext/Sampling: For Federal Financial Assistance Listing #19.517, a nonstatistical sample of 6 requests out of 31 total requests were selected for testing. For Federal Financial Assistance Listing #98.001, a nonstatistical sample of 4 requests out of 17 total requests were selected for testing.Repeat Finding from Prior Year: NoRecommendation: We recommend management complete an extensive review over cash management policies to make sure requirements under the CFR section are met.Views of Responsible Officials: Management agrees with this finding.
FINDING 2022-003 – Cash Draw Downs and Internal Control over Cash Management MATERIAL WEAKNESS, MATERIAL NONCOMPLIANCE Identification of the Federal Program: U.S. Department of Health and Human Services 93.224/93.527 Health Center Program Cluster 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 Center 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 52.2160-7(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 draw requests, we noted certain draw requests were made prior to the related costs being incurred. Although the funds were ultimately expended on items approved by the federal award, they were not expended in a timely manner. Cause: The Center did not maintain detailed listings of eligible costs incurred at the time of the draw request to support the amount requested in the Payment Management System. Additionally, the Center did not maintain documentation of such review or approval that such costs were incurred prior to the draw request, or the amount requested was in accordance with 2 CFR Section 200.305. Effect or Potential Effect: Requests for draws per the Payment Management System may not have minimized the time elapsing between payment by the federal agency or pass-through entity and disbursement by the Center and the amounts drawn down may be inaccurate. Questioned Costs: None Context: We selected a sample of draw requests submitted through the Payment Management System during the year ended September 30, 2022. The Center was unable to provide evidence of timely review and approval of two requests out of 44, totaling $352,340. Repeat Finding: No Recommendation: We recommend the Center establish formal internal controls and documentation of its performance relating to the determination of cash drawn downs and review and approval of drawn downs by appropriate personnel who are knowledgeable of such requirements. View of Responsible Officials: See accompanying Corrective Action Plan.
FINDING 2022-003 – Cash Draw Downs and Internal Control over Cash Management MATERIAL WEAKNESS, MATERIAL NONCOMPLIANCE Identification of the Federal Program: U.S. Department of Health and Human Services 93.224/93.527 Health Center Program Cluster 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 Center 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 52.2160-7(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 draw requests, we noted certain draw requests were made prior to the related costs being incurred. Although the funds were ultimately expended on items approved by the federal award, they were not expended in a timely manner. Cause: The Center did not maintain detailed listings of eligible costs incurred at the time of the draw request to support the amount requested in the Payment Management System. Additionally, the Center did not maintain documentation of such review or approval that such costs were incurred prior to the draw request, or the amount requested was in accordance with 2 CFR Section 200.305. Effect or Potential Effect: Requests for draws per the Payment Management System may not have minimized the time elapsing between payment by the federal agency or pass-through entity and disbursement by the Center and the amounts drawn down may be inaccurate. Questioned Costs: None Context: We selected a sample of draw requests submitted through the Payment Management System during the year ended September 30, 2022. The Center was unable to provide evidence of timely review and approval of two requests out of 44, totaling $352,340. Repeat Finding: No Recommendation: We recommend the Center establish formal internal controls and documentation of its performance relating to the determination of cash drawn downs and review and approval of drawn downs by appropriate personnel who are knowledgeable of such requirements. View of Responsible Officials: See accompanying Corrective Action Plan.
FINDING 2022-003 – Cash Draw Downs and Internal Control over Cash Management MATERIAL WEAKNESS, MATERIAL NONCOMPLIANCE Identification of the Federal Program: U.S. Department of Health and Human Services 93.224/93.527 Health Center Program Cluster 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 Center 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 52.2160-7(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 draw requests, we noted certain draw requests were made prior to the related costs being incurred. Although the funds were ultimately expended on items approved by the federal award, they were not expended in a timely manner. Cause: The Center did not maintain detailed listings of eligible costs incurred at the time of the draw request to support the amount requested in the Payment Management System. Additionally, the Center did not maintain documentation of such review or approval that such costs were incurred prior to the draw request, or the amount requested was in accordance with 2 CFR Section 200.305. Effect or Potential Effect: Requests for draws per the Payment Management System may not have minimized the time elapsing between payment by the federal agency or pass-through entity and disbursement by the Center and the amounts drawn down may be inaccurate. Questioned Costs: None Context: We selected a sample of draw requests submitted through the Payment Management System during the year ended September 30, 2022. The Center was unable to provide evidence of timely review and approval of two requests out of 44, totaling $352,340. Repeat Finding: No Recommendation: We recommend the Center establish formal internal controls and documentation of its performance relating to the determination of cash drawn downs and review and approval of drawn downs by appropriate personnel who are knowledgeable of such requirements. View of Responsible Officials: See accompanying Corrective Action Plan.
FINDING 2022-003 – Cash Draw Downs and Internal Control over Cash Management MATERIAL WEAKNESS, MATERIAL NONCOMPLIANCE Identification of the Federal Program: U.S. Department of Health and Human Services 93.224/93.527 Health Center Program Cluster 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 Center 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 52.2160-7(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 draw requests, we noted certain draw requests were made prior to the related costs being incurred. Although the funds were ultimately expended on items approved by the federal award, they were not expended in a timely manner. Cause: The Center did not maintain detailed listings of eligible costs incurred at the time of the draw request to support the amount requested in the Payment Management System. Additionally, the Center did not maintain documentation of such review or approval that such costs were incurred prior to the draw request, or the amount requested was in accordance with 2 CFR Section 200.305. Effect or Potential Effect: Requests for draws per the Payment Management System may not have minimized the time elapsing between payment by the federal agency or pass-through entity and disbursement by the Center and the amounts drawn down may be inaccurate. Questioned Costs: None Context: We selected a sample of draw requests submitted through the Payment Management System during the year ended September 30, 2022. The Center was unable to provide evidence of timely review and approval of two requests out of 44, totaling $352,340. Repeat Finding: No Recommendation: We recommend the Center establish formal internal controls and documentation of its performance relating to the determination of cash drawn downs and review and approval of drawn downs by appropriate personnel who are knowledgeable of such requirements. View of Responsible Officials: See accompanying Corrective Action Plan.
FINDING 2022-003 – Cash Draw Downs and Internal Control over Cash Management MATERIAL WEAKNESS, MATERIAL NONCOMPLIANCE Identification of the Federal Program: U.S. Department of Health and Human Services 93.224/93.527 Health Center Program Cluster 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 Center 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 52.2160-7(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 draw requests, we noted certain draw requests were made prior to the related costs being incurred. Although the funds were ultimately expended on items approved by the federal award, they were not expended in a timely manner. Cause: The Center did not maintain detailed listings of eligible costs incurred at the time of the draw request to support the amount requested in the Payment Management System. Additionally, the Center did not maintain documentation of such review or approval that such costs were incurred prior to the draw request, or the amount requested was in accordance with 2 CFR Section 200.305. Effect or Potential Effect: Requests for draws per the Payment Management System may not have minimized the time elapsing between payment by the federal agency or pass-through entity and disbursement by the Center and the amounts drawn down may be inaccurate. Questioned Costs: None Context: We selected a sample of draw requests submitted through the Payment Management System during the year ended September 30, 2022. The Center was unable to provide evidence of timely review and approval of two requests out of 44, totaling $352,340. Repeat Finding: No Recommendation: We recommend the Center establish formal internal controls and documentation of its performance relating to the determination of cash drawn downs and review and approval of drawn downs by appropriate personnel who are knowledgeable of such requirements. View of Responsible Officials: See accompanying Corrective Action Plan.
2022-003—Excess Drawdown of Federal Funds Type of Finding: (F) Instance of Noncompliance Related to Federal Awards Funding Agency: U.S. Department of Health and Human Services AL #: 93.137 – Community Programs to Improve Minority Health Grant Program Award #: 5 AIAMP170017-05-00 Award Period: 07/01/2021 – 07/29/2022 Estimated Questioned Costs: $26,426 Compliance Requirement: Cash Management Statement of Condition During our analysis of total grant revenues and expenditures reported on the SEFA, we noted that the entity had drawn down $26,426 more in federal funds than it expended under the Community Programs to Improve Minority Health grant. The excess drawdown remained outstanding as of September 30, 2022, the end of the audit period, and as of the date of this report. Criteria In accordance with 2 CFR § 200.305(b), non-federal entities must minimize the time elapsing between the drawdown of federal funds and the disbursement for program purposes. Additionally, per 2 CFR § 200.302(b)(6), entities must maintain effective internal controls over cash management to ensure that drawdowns are based on actual, allowable expenditures. Effect The entity is not in compliance with federal cash management requirements. The federal award has an outstanding overdrawn balance of $26,426, which may be subject to repayment to the federal awarding agency. Cause The excess drawdown appears to have resulted from an error during the drawdown request process. The entity indicated it was likely due to administrative oversight but was unable to provide specific details due to the passage of time. The discrepancy was disclosed to the auditor during the audit. Recommendation We recommend that the entity remit the excess federal funds or consult with the awarding agency to determine the appropriate resolution. In addition, the entity should strengthen its procedures to reconcile cash drawdowns to actual expenditures on a timely basis to prevent similar overdraws in the future.
Finding 2022 – 007: Cash Collateralization Criteria: Uniform Guidance 2 CFR § 200.305(b)(7) requires advance payments of Federal funds to be deposited and maintained in insured accounts whenever possible. Condition: During our review of the Organization’s cash, it was noted that as of September 30, 2022, they have not collateralized cash balances in excess of the amounts insured by the Federal Deposit Insurance Corporation. Cash balances of $11,685,898 were uninsured at September 30, 2022. Unearned revenue was reported at approximately $10,704,037 which includes advance payments of Federal funds. Questioned Costs: None. Cause: The Organization has not entered into a cash collateralization agreement with their financial institution. Effect: The Organization is not in compliance with Uniform Guidance 2 CFR § 200.305(b)(7) as not all cash balances received in advance from the funding agency were adequately insured or collateralized and were exposed to custodial credit risk in the event of a bank failure. Recommendation: We recommend the Organization enter into a cash collateralization agreement with their financial institution to ensure that all amounts related to grant agreements and awards received in advance are not exposed to custodial credit risk in the event of a bank failure. Views of Responsible Officials: See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding 2022 – 007: Cash Collateralization Criteria: Uniform Guidance 2 CFR § 200.305(b)(7) requires advance payments of Federal funds to be deposited and maintained in insured accounts whenever possible. Condition: During our review of the Organization’s cash, it was noted that as of September 30, 2022, they have not collateralized cash balances in excess of the amounts insured by the Federal Deposit Insurance Corporation. Cash balances of $11,685,898 were uninsured at September 30, 2022. Unearned revenue was reported at approximately $10,704,037 which includes advance payments of Federal funds. Questioned Costs: None. Cause: The Organization has not entered into a cash collateralization agreement with their financial institution. Effect: The Organization is not in compliance with Uniform Guidance 2 CFR § 200.305(b)(7) as not all cash balances received in advance from the funding agency were adequately insured or collateralized and were exposed to custodial credit risk in the event of a bank failure. Recommendation: We recommend the Organization enter into a cash collateralization agreement with their financial institution to ensure that all amounts related to grant agreements and awards received in advance are not exposed to custodial credit risk in the event of a bank failure. Views of Responsible Officials: See the corrective action plan that accompanies the schedule of findings and questioned costs.
Finding No.: 2022-016 Federal Agency: U.S. Department of Education AL Program: 84.047A TRIO Upward Bound Federal Award No.: P047A171556-21 Area: Cash Management Questioned Costs: $ Undeterminable Criteria: Per OMB Compliance Supplement April 2022, non-federal entities must establish written procedures to implement the requirements of 2 CFR section 200.305. Specifically, 2 CFR section 200.305(b) states that for recipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency and the disbursement of funds by the recipient. Furthermore, 2 CFR 200.303(a) states that the subrecipient must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the COSO. Condition: The College does not have written procedures to implement the requirements set in the criteria above. Furthermore, no detailed listing of expenditures supporting the following drawdowns during the year was on file to ascertain whether the expenditures were incurred prior to the date of the reimbursement request: Drawdown Amount $ 31,928 $ 31,929 $ 44,991 $ 41,652 $112,832 Cause: The College lacks written policies and procedures over cash management, including retaining documentation supporting cash drawdowns. Effect: The College is not in compliance with the applicable cash management requirements. Questioned costs, if any, that may result from inadequate records are not determinable. Recommendation: College management should establish written internal control policies and procedures, including retaining documentation supporting cash drawdowns. Views of Auditee and Planned Corrective Actions: The College agrees with the finding and provides details in its Corrective Action Plan.
Finding No.: 2022-021 Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund AL Sub-Program: 84.425E Higher Education Emergency Relief Fund (HEERF) - Student Aid Portion Federal Award No.: COVID-19 P425E204126 AL Sub-Program: 84.425F HEERF - Institutional Portion Federal Award No.: COVID-19 P425F202732 AL Sub-Program: 84.425L HEERF - Minority Serving Institution Federal Award No.: COVID-19 P425L200219 Area: Cash Management Questioned Costs: $ Undeterminable Criteria: Per OMB Compliance Supplement April 2022, non-federal entities must establish written procedures to implement the requirements of 2 CFR section 200.305. Specifically, 2 CFR section 200.305(b) states that for recipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency and the disbursement of funds by the recipient. Furthermore, per OMB Compliance Supplement April 2022, for CRRSAA HEERF II and ARP HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from ED’s G5 grants system and Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within 3 calendar days of the drawdown from G5. Furthermore, 2 CFR 200.303(a) states that the subrecipient must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the COSO. Condition: The College does not have written procedures to implement the requirements set in the criteria above. Furthermore, monitoring of actual disbursements of the following drawdowns during the year was not performed: AL Sub-Program Drawdown Amount 84.425E $750,000 84.425E $250,000 84.425E $650,000 84.425F $350,000 84.425F $552,500 84.425F $900,000 84.425F $550,000 84.425F $351,000 84.425F $350,000 84.425F $450,000 84.425F $820,000 84.425F $250,000 84.425F $350,000 84.425F $292,650 84.425F $150,000 84.425F $150,000 84.425L $750,000 84.425L $360,589 84.425L $1,150,000 84.425L $350,000 84.425L $150,000 Cause: The College lacks written policies and procedures over cash management, including monitoring of actual disbursements of drawdowns. Effect: The College is not in compliance with the applicable cash management requirements. Questioned costs, if any, that may result from non-monitoring of actual disbursements are not determinable. Recommendation: College management should establish written policies and procedures over cash management, including monitoring of actual disbursements of drawdowns. Views of Auditee and Planned Corrective Actions: The College agrees with the finding and provides details in its Corrective Action Plan.
2021-002 Overdrawing of federal funds Information on Federal Programs: Assistance Listing #: 93.421, 93.318, 93.185 Federal Agency: United States Department of Heath and Human Services Criteria: Cash management compliance requirements under Subpart B of 31 CFR Part 205 require that nonfederal entities minimize the time elapsing between the transfer of funds from the Payment Management System (PMS) or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. (2 CFR section 200.305(b)). Condition: There was an overdraw of funds of $200,000 where costs had not been incurred to support the draw, nor were all the funds spent prior within a reasonable time frame. Effect: There is a refundable advance on the books for $131,858 for funds that were drawn and unspent at year end. Cause: Due to changes in staffing around this time, a draw was made for part of the funds and then a second draw was made for the full amount of expenses, without accounting for the previously drawn funds. Recommendation: We recommend that the Organization ensure there controls in place for review and approval of all draws and a reconciliation be done at each draw to ensure that there are sufficient expenditures to support the draw. Any overdraws should be caught immediately and steps taken to remedy the draw or to expend the funds within a reasonable timeframe.
2021-002 Overdrawing of federal funds Information on Federal Programs: Assistance Listing #: 93.421, 93.318, 93.185 Federal Agency: United States Department of Heath and Human Services Criteria: Cash management compliance requirements under Subpart B of 31 CFR Part 205 require that nonfederal entities minimize the time elapsing between the transfer of funds from the Payment Management System (PMS) or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. (2 CFR section 200.305(b)). Condition: There was an overdraw of funds of $200,000 where costs had not been incurred to support the draw, nor were all the funds spent prior within a reasonable time frame. Effect: There is a refundable advance on the books for $131,858 for funds that were drawn and unspent at year end. Cause: Due to changes in staffing around this time, a draw was made for part of the funds and then a second draw was made for the full amount of expenses, without accounting for the previously drawn funds. Recommendation: We recommend that the Organization ensure there controls in place for review and approval of all draws and a reconciliation be done at each draw to ensure that there are sufficient expenditures to support the draw. Any overdraws should be caught immediately and steps taken to remedy the draw or to expend the funds within a reasonable timeframe.
2021-002 Overdrawing of federal funds Information on Federal Programs: Assistance Listing #: 93.421, 93.318, 93.185 Federal Agency: United States Department of Heath and Human Services Criteria: Cash management compliance requirements under Subpart B of 31 CFR Part 205 require that nonfederal entities minimize the time elapsing between the transfer of funds from the Payment Management System (PMS) or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. (2 CFR section 200.305(b)). Condition: There was an overdraw of funds of $200,000 where costs had not been incurred to support the draw, nor were all the funds spent prior within a reasonable time frame. Effect: There is a refundable advance on the books for $131,858 for funds that were drawn and unspent at year end. Cause: Due to changes in staffing around this time, a draw was made for part of the funds and then a second draw was made for the full amount of expenses, without accounting for the previously drawn funds. Recommendation: We recommend that the Organization ensure there controls in place for review and approval of all draws and a reconciliation be done at each draw to ensure that there are sufficient expenditures to support the draw. Any overdraws should be caught immediately and steps taken to remedy the draw or to expend the funds within a reasonable timeframe.
Finding 2022-001: Cash Management ? Disbursement U.S. Department of Education ? Education Stabilization Fund COVID-19 Supplemental Assistance to Institutions of Higher Education Program ? ALN 84.425S Criteria: 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)). Condition: Management implemented a financial management system that meets the specified standards for fund control and accountability, but the system failed to ensure disbursement of funds within the required timeframe. Management self-identified the issue, and self-corrected as they became aware of the requirement. Questioned Costs: None noted. Repeat Finding: This is not a repeat finding. Cause: Management did not accurately identify the required timeframe of disbursement for funds received under the SAIHE subprogram. A mitigating factor is the uniqueness of the SAIHE subprogram. Effect: The portion of the SAIHE funds allocated to provide financial aid grants to students was not disbursed within the required 15 calendar days of the drawdown from ED?s G5 grants system. Recommendation: Before drawing down from ED?s G5 grants system, management should familiarize themselves with the applicable terms, conditions, and requirements governing the organization?s use of the grant funds, and then implement a system of controls that will ensure compliance with those terms. Views of Responsible Parties and Corrective Action Plan: Management concurs with the finding and has implemented a system to minimize the time elapsing between the transfer of funds from ED?s G5 grants system and disbursement by the organization for both institutional aid and student financial aid purposes. In addition, management has designated a responsible and capable employee to monitor the new system and to review the terms, conditions, and requirements governing any future grants to ensure the system?s compatibility. Implementation of the corrective action is further evidenced by timely disbursement of subsequent drawdowns from ED?s G5 grants system in FY22.
Finding No. 2022-001 Cash Management U.S. Department of the Education Upward Bound Program ? CFDA #84.047A Talent Search Program - CFDA #84.044A Criterion: 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 project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). Condition: Based upon our testwork, we noted the Organization did not have support for funds being drawndown on a consistent basis. Cause and Effect: Management did not follow the established process for drawdown requests to ensure that the amount of funds being drawn down were property supported to a specific federal program. Therefore, the resulting effect was excess funds on hands. Questioned Cost: None Recommendation: We recommend that management enhance the design of its control activities to ensure that the amount of funds being drawn down are properly allocated to the appropriate Federal programs. View of Responsible Officials: Management agrees with the findings and has hired a Contract Manager to oversee office management processes. In addition, all drawdowns in the future will be scheduled and done bi-monthly.
Finding No. 2022-001 Cash Management U.S. Department of the Education Upward Bound Program ? CFDA #84.047A Talent Search Program - CFDA #84.044A Criterion: 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 project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). Condition: Based upon our testwork, we noted the Organization did not have support for funds being drawndown on a consistent basis. Cause and Effect: Management did not follow the established process for drawdown requests to ensure that the amount of funds being drawn down were property supported to a specific federal program. Therefore, the resulting effect was excess funds on hands. Questioned Cost: None Recommendation: We recommend that management enhance the design of its control activities to ensure that the amount of funds being drawn down are properly allocated to the appropriate Federal programs. View of Responsible Officials: Management agrees with the findings and has hired a Contract Manager to oversee office management processes. In addition, all drawdowns in the future will be scheduled and done bi-monthly.
Finding No. 2022-001 Cash Management U.S. Department of the Education Upward Bound Program ? CFDA #84.047A Talent Search Program - CFDA #84.044A Criterion: 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 project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). Condition: Based upon our testwork, we noted the Organization did not have support for funds being drawndown on a consistent basis. Cause and Effect: Management did not follow the established process for drawdown requests to ensure that the amount of funds being drawn down were property supported to a specific federal program. Therefore, the resulting effect was excess funds on hands. Questioned Cost: None Recommendation: We recommend that management enhance the design of its control activities to ensure that the amount of funds being drawn down are properly allocated to the appropriate Federal programs. View of Responsible Officials: Management agrees with the findings and has hired a Contract Manager to oversee office management processes. In addition, all drawdowns in the future will be scheduled and done bi-monthly.
Finding No. 2022-001 Cash Management U.S. Department of the Education Upward Bound Program ? CFDA #84.047A Talent Search Program - CFDA #84.044A Criterion: 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 project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). Condition: Based upon our testwork, we noted the Organization did not have support for funds being drawndown on a consistent basis. Cause and Effect: Management did not follow the established process for drawdown requests to ensure that the amount of funds being drawn down were property supported to a specific federal program. Therefore, the resulting effect was excess funds on hands. Questioned Cost: None Recommendation: We recommend that management enhance the design of its control activities to ensure that the amount of funds being drawn down are properly allocated to the appropriate Federal programs. View of Responsible Officials: Management agrees with the findings and has hired a Contract Manager to oversee office management processes. In addition, all drawdowns in the future will be scheduled and done bi-monthly.
Finding No. 2022-001 Cash Management U.S. Department of the Education Upward Bound Program ? CFDA #84.047A Talent Search Program - CFDA #84.044A Criterion: 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 project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). Condition: Based upon our testwork, we noted the Organization did not have support for funds being drawndown on a consistent basis. Cause and Effect: Management did not follow the established process for drawdown requests to ensure that the amount of funds being drawn down were property supported to a specific federal program. Therefore, the resulting effect was excess funds on hands. Questioned Cost: None Recommendation: We recommend that management enhance the design of its control activities to ensure that the amount of funds being drawn down are properly allocated to the appropriate Federal programs. View of Responsible Officials: Management agrees with the findings and has hired a Contract Manager to oversee office management processes. In addition, all drawdowns in the future will be scheduled and done bi-monthly.
Condition: The Center?s written policies and procedures related to financial management do not meet the requirements of 2 CFR 200, Subpart D and Subpart E. Criteria: According to 2 CFR Section 200.302.b and 2 CFR Section 200.305 of the Uniform Guidance, the Center is required to have a written financial management policy. Cause: The Center was unaware of requirements regarding policies and procedures outlined in the Uniform Guidance. Effect: Written policies necessary for non-Federal entities receiving federal funds were not in place. Repeat Finding: No Questioned Costs: None reported Recommendation: We recommend that the Center update their written policies and procedures that meet the requirements of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Views of Responsible Officials and Planned Corrective Action: We concur with the auditor?s finding and will update the Center?s written policies and procedures for the Uniform Guidance requirements.