Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. The Department of Education requires grantees to conspicuously post quarterly reports on the institution?s website no later than 10 days after the calendar quarter. Effective internal controls should include procedures to ensure reports are submitted timely. Uniform Grant Guidance (2 CFR 200.305(b)(3)) when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Condition: The University did not make payments to subrecipients within 30 days after receipt of invoices. Context: During out testing of 40 subrecipient payments, from a statistically valid sample, we noted 11 payments were not submitted within 30 days after receiving invoice from the subrecipients. Questioned costs: None Cause: Departments are responsible for entering requisitions and invoices as they are received. In these cases, there were delays in the administrative workflow which caused the invoices to not be paid timely. Effect: The University was not in compliance with the regulation to make payments to subrecipients within the required timeframe. Repeat finding: No Recommendation: We recommend that the University review and update current procedures to ensure subrecipient payments are paid timely.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
U.S. Department of Agriculture Passed through Michigan Department of Education Child Nutrition Cluster ? COVID-19 School Breakfast Program #10.553, National School Lunch Program #10.555, Summer Food Service Program for Children #10.559 #2022-002: Material Weakness in Controls over Compliance: Administrative Requirements of Uniform Guidance ? Administrative Policies This is a repeat of prior year finding #2021-002 Conditions and Criteria: Written policies associated with financial management, allowable costs, cash management and procurement do not meet the administrative requirements of Uniform Guidance (2 CFR 200). Cause/Context: Grand Rapids Christian Schools has written policies and procedures contained within the Schools? Policy Manual and the Accounting Procedures Manual that apply to the operations and administration of the Schools. Certain of these policies and procedures cover activities relevant to the federal awards programs and address some of the direct and material compliance matters important to the major federal program. However, the Schools has not adopted the policy requirements of Uniform Guidance related to financial management, allowable costs, cash management and procurement that apply to its federal programs. Recommendations: Grand Rapids Christian Schools should adopt the following written policies as required by Uniform Guidance: ?Financial Management (2 CFR 200.302) The financial management policy should include records documenting compliance, and the tracking of funds to determine that expenditures are in accordance with the terms and conditions of the federal awards. The financial management and reporting system must provide the following: ?Identification - Title of the award, federal assistance number ?Complete disclosure of accurate and current financial results of each federal award ?Source and application of funds for federal award activity ?Record retention and access ? define the time period for which records must be kept (can vary by grant agreement), and who has the ability to access the records (?200.333 - ?200.337) ?Written procedure to implement cash management requirements (see below) ?Written procedures for determining the allowability of costs (see below) ?Cash Management (2 CFR 200.305) A written policy is required by Uniform Guidance detailing the Schools? procedures to minimize the time that elapses between draw and expenditure of federal dollars. ?Allowable Costs (2 CFR 200.302(b)(7)) The Schools must have written procedures for determining the allowability of costs in accordance with Subpart E - Cost Principles of Uniform Guidance and the terms and conditions of the Federal award. This includes the determination of allowable costs and the review of this determination. The standard assumes policies and procedures are in place for disbursements, and the allowable cost policy will demonstrate how the School ensures compliance. The criteria for costs to be considered allowable are documented within 2 CFR 200.403. ?Procurement Standards (2 CFR 200.317 ? 200.326) The School must have and use documented procurement procedures, including written standards that promote full and open vendor competition. Written conflict of interest standards must cover the actions of employees engaged in the selection, award and administration of contracts. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Views of Responsible Officials and Planned Corrective Actions: ?Grand Rapids Christian Schools follows procurement and record retention standards provided by the USDA. ?GRCS does not have actual written policies and procedures for Financial Management, Cash Management, Allowable Costs, and Procurement Standards, but do have practices in place to follow USDA guidelines. In the case of cash management, the only location that takes cash is GRCHS. In that instance, along with Meal Magic, cash registers are zeroed out and balanced to Meal Magic and cash deposits are made daily. ?GRCS Business Office will work with the Food Service Director to begin formulating written policies and procedures specific to Grand Rapids Christian Schools. GRCS will utilize the resources from Uniform Guidance and the Code of Federal Regulations (CFR) to develop policies that are compliant with those requirements prior to June 30, 2023.
Assistance Listing Number: 84.425U Program Title: COVID-19 Education Stabilization Fund - American Rescue Plan ? ESSER III ? MFT & Operating Fund Federal Award Number: N/A Federal Award Year: 2021/2022 Pass Through Entity: Chicago Public Schools Criteria: In accordance with 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The Organization is either lacking or has nonconforming written policies and procedures for the following administrative functions, required by the Uniform Guidance: 1. Financial management - 2 CFR 200.302(b)(6) 2. Allowable Costs - 2 CFR 200.302(b)(7) 3. Federal payment - 2 CFR 200.305(b)(1) 4. Procurement - 2 CFR 200.318(a) and 2 CFR 200.318(c)(1) 5. Competition - 2 CFR 200.319(d) 6. Methods of procurement to be followed - 2 CFR 200.320 7. Compensation (Personal Services) - 2 CFR 200.430(a)(1) 8. Compensation (Fringe Benefits - Leave) - 2 CFR 200.431(b)(1) 9. Relocation costs of employees - 2 CFR 200.464(a)(2) 10. Travel costs - 2 CFR 200.474 Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our review of the Organization?s policies and procedures, which were found to be not in accordance with Uniform Guidance. Cause: The Organization was not aware of the specific Uniform Guidance requirements for certain written policies and procedures. Effect: The Organization did not have these policies and procedures in place to reasonably ensure that program functions are achieved effectively, efficiently and in compliance with Federal statutes, regulations, and the terms and conditions of the award. The Organization was not in compliance with the administrative requirements set forth in the Uniform Guidance. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization design procedures and implement internal control procedures to ensure that the Uniform Guidance administrative requirements are met. Views of Responsible Officials and Corrective Action Plan: Management agrees with this finding and plans on implementing the appropriate policies and procedures in accordance with Uniform Guidance.
Assistance Listing Number: 84.425U Program Title: COVID-19 Education Stabilization Fund - American Rescue Plan ? ESSER III ? MFT & Operating Fund Federal Award Number: N/A Federal Award Year: 2021/2022 Pass Through Entity: Chicago Public Schools Criteria: In accordance with 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The Organization is either lacking or has nonconforming written policies and procedures for the following administrative functions, required by the Uniform Guidance: 1. Financial management - 2 CFR 200.302(b)(6) 2. Allowable Costs - 2 CFR 200.302(b)(7) 3. Federal payment - 2 CFR 200.305(b)(1) 4. Procurement - 2 CFR 200.318(a) and 2 CFR 200.318(c)(1) 5. Competition - 2 CFR 200.319(d) 6. Methods of procurement to be followed - 2 CFR 200.320 7. Compensation (Personal Services) - 2 CFR 200.430(a)(1) 8. Compensation (Fringe Benefits - Leave) - 2 CFR 200.431(b)(1) 9. Relocation costs of employees - 2 CFR 200.464(a)(2) 10. Travel costs - 2 CFR 200.474 Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our review of the Organization?s policies and procedures, which were found to be not in accordance with Uniform Guidance. Cause: The Organization was not aware of the specific Uniform Guidance requirements for certain written policies and procedures. Effect: The Organization did not have these policies and procedures in place to reasonably ensure that program functions are achieved effectively, efficiently and in compliance with Federal statutes, regulations, and the terms and conditions of the award. The Organization was not in compliance with the administrative requirements set forth in the Uniform Guidance. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization design procedures and implement internal control procedures to ensure that the Uniform Guidance administrative requirements are met. Views of Responsible Officials and Corrective Action Plan: Management agrees with this finding and plans on implementing the appropriate policies and procedures in accordance with Uniform Guidance.
Criteria: Per 2 CFR section 200.305(b)(5), the entity is required to pay for the costs before the date of the reimbursement request. Condition: The Organization was unable to provide adequate audit support for reimbursement requests during the fiscal year under audit. Cause: The Organization did not have adequate internal controls to ensure documentation was maintained to support reimbursement requests. Effect: The lack of internal controls surrounding the cash management compliance requirement could lead to potential funding issues in the future. Questioned Costs: None. Repeat Finding: N/A, first year for this finding. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Organization Response: Management agrees with this finding.
Criteria: Per 2 CFR section 200.305(b)(5), the entity is required to pay for the costs before the date of the reimbursement request. Condition: The Organization was unable to provide adequate audit support for reimbursement requests during the fiscal year under audit. Cause: The Organization did not have adequate internal controls to ensure documentation was maintained to support reimbursement requests. Effect: The lack of internal controls surrounding the cash management compliance requirement could lead to potential funding issues in the future. Questioned Costs: None. Repeat Finding: N/A, first year for this finding. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Organization Response: Management agrees with this finding.
FINDING 2022-005: CRIME VICTIM ASSISTANCE (16.575) ? CASH MANAGEMENT ? REIMBURSEMENT REQUESTS AND SUPPORTING DOCUMENTATION FINDING TYPE: Federal Awards ? Material Weakness/Noncompliance CRITERIA: 2 CFR section 200.305(b)(3) states that a non-Federal entity must incur costs prior to the date of the reimbursement request when the reimbursement method is used. Supporting documentation must be maintained. CONDITION: The auditor noted, while testing a sample of reimbursement requests for Crime Victim Assistance for compliance and adherence to internal controls, that several reimbursement requests in excess of materiality were requested in advance of any expenses being incurred. The auditor noted, in particular, several large final drawdowns for a grant with a period ending on 9/30/21. The amounts requested were based off budgeted and estimated amounts. It was difficult for the auditor to determine that eligible costs were incurred before the close of the grant period. CAUSE: Turnover at the accounting position and override of controls lead to accidental and non-compliant reimbursement requests. EFFECT: Safenet, Inc. was not in compliance with cash management compliance requirements and internal controls were not functioning in a manner that would ensure proper reimbursement requests. Excess funds could have potentially been drawn and not expended. QUESTIONED COST: Undetermined RECOMMENDATION: Management should ensure internal controls are designed in a manner that ensures reimbursement requests are based off expenses that have been incurred prior to the date of the reimbursement request. Requests should be reviewed by someone other than the preparer and should agree to supporting documentation. VIEWS OF RESPONSIBLE OFFICIALS: Management agrees with the finding.
2022-001 Activities Allowed or Unallowed and Allowable Costs/Cost Principles / Types of Services Allowed or Disallowed, Cash Management, and Reporting U.S. Department of Health and Human Services: Passed through State of New Jersey, Department of Health: COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (SARS-COV-2 Hospital Testing) Federal Grant Number and Years: PHLP21CHT017 (7/1/2021 ? 6/30/2022) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Findings: None Criteria: Activities Allowed or Unallowed and Allowable Costs/Cost Principles / Types of Services Allowed or Disallowed - Except where otherwise authorized by statute, costs must be adequately documented in order to be allowable under Federal awards (2 CFR Section 200.404). Cash Management - Except where otherwise authorized by statute, when non-federal entities are funded under the reimbursement method, costs must be adequately documented as paid prior to the date of the reimbursement request (2 CFR section 200.305(b)(3)) Reporting - In accordance with the grant agreement and the reporting requirements for State of New Jersey Department of Health (NJDOH), direct grants and pass-through funds are fulfilled utilizing a Report of Expenditures (ROE). ROEs are prepared and submitted quarterly in order to allow for relevant and reliable information to be provided to the Federal government or State of New Jersey for reimbursement and tracking purposes. The ROEs are the source documents for the grantee to prepare a schedule of expenditures of Federal awards (SEFA) for the period covered by the grantee?s financial statements in accordance with 2 CFR 200.502, Basis for determining Federal awards expended, for the SEFA. Additionally, in accordance with Federal requirements, a non-Federal entity shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context: On a quarterly basis, University Hospital (the Hospital) prepares and reports to New Jersey Department of Health the program expenditures for Federal funding amounts on the ROE, which are then used to prepare the annual SEFA at the end of the fiscal year. The Hospital?s expenditures per the ROE were greater than the expenditures that were supported by the general ledger and accounting records, therefore, the Hospital submitted the ROE and claim towards the grant for reimbursement above the amount allowed by $405,971, due to a double counting of previously reimbursed costs. Further, the Hospital?s indirect costs charged were greater than the allowable amount by $3,514. The original amount reported on the SEFA by the Hospital and charged to the State was $3,142,428. The Hospital has adjusted the SEFA to account for allowable costs, which is $2,732,943. The Hospital?s policies and procedures to ensure compliance with the above compliance requirements did not include certain internal controls that were designed properly and operating effectively to ensure that the Hospital has adequate supporting accounting records for allowable costs claimed and reported on the ROE and SEFA. Cause: Management's review of the ROE did not identify the double counting of previously reimbursed costs, therefore, the review was not performed at the appropriate level of precision in accordance with its design. Effect: The Hospital overcharged the grant by $409,485. Questioned Costs: $409,485 Recommendation: We recommend that the Hospital strengthen its procedures to ensure that the quarterly ROEs include the correct amount of allowable expenditures based upon the general ledger and accounting records and reflected on the SEFA and that the review of the ROE is properly performed prior to submission for reimbursement.
Finding No. 2022-003 Cash Management Federal Program Research and Development Cluster ALNs ALN 93.396, 93.279, 93.846 Federal Agencies Department of Health and Human Services Federal Award Years July 1, 2021 to June 30, 2022 Criteria or Requirement Per 2 CFR section 200.305(b)(3), non-federal entities that are funded under the reimbursement method are required to pay for the costs for which reimbursement was requested prior to the date of the reimbursement request. Condition and Context For 3 of the 40 samples tested, taxes were properly accrued as allowable costs but were drawn prior to payment by the University. While these costs are deemed allowable, they were not paid for prior to seeking reimbursement from the federal agency. The taxes drawn prior to payment totaled $4,035 out of a total of $784,941 tested in the sample of 40. Cause and Potential Effect The control to ensure that all costs were paid for prior to seeking reimbursement was not operating effectively to identify instances of noncompliance related to the applicable taxes. Questioned Cost The known unallowable costs identified in our sample items totaled $4,035. Management?s analysis identified a total of $51,803. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation We recommend that the University strengthen its processes and controls within the procurement office to ensure that all costs are paid prior to seeking reimbursement. View of Responsible Officials Management of the University takes no exception to this reported finding and has subsequently paid the applicable taxes and related interest. We have implemented the remedial actions as outlined in our Corrective Action Plan.
Finding No. 2022-003 Cash Management Federal Program Research and Development Cluster ALNs ALN 93.396, 93.279, 93.846 Federal Agencies Department of Health and Human Services Federal Award Years July 1, 2021 to June 30, 2022 Criteria or Requirement Per 2 CFR section 200.305(b)(3), non-federal entities that are funded under the reimbursement method are required to pay for the costs for which reimbursement was requested prior to the date of the reimbursement request. Condition and Context For 3 of the 40 samples tested, taxes were properly accrued as allowable costs but were drawn prior to payment by the University. While these costs are deemed allowable, they were not paid for prior to seeking reimbursement from the federal agency. The taxes drawn prior to payment totaled $4,035 out of a total of $784,941 tested in the sample of 40. Cause and Potential Effect The control to ensure that all costs were paid for prior to seeking reimbursement was not operating effectively to identify instances of noncompliance related to the applicable taxes. Questioned Cost The known unallowable costs identified in our sample items totaled $4,035. Management?s analysis identified a total of $51,803. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation We recommend that the University strengthen its processes and controls within the procurement office to ensure that all costs are paid prior to seeking reimbursement. View of Responsible Officials Management of the University takes no exception to this reported finding and has subsequently paid the applicable taxes and related interest. We have implemented the remedial actions as outlined in our Corrective Action Plan.
Finding No. 2022-003 Cash Management Federal Program Research and Development Cluster ALNs ALN 93.396, 93.279, 93.846 Federal Agencies Department of Health and Human Services Federal Award Years July 1, 2021 to June 30, 2022 Criteria or Requirement Per 2 CFR section 200.305(b)(3), non-federal entities that are funded under the reimbursement method are required to pay for the costs for which reimbursement was requested prior to the date of the reimbursement request. Condition and Context For 3 of the 40 samples tested, taxes were properly accrued as allowable costs but were drawn prior to payment by the University. While these costs are deemed allowable, they were not paid for prior to seeking reimbursement from the federal agency. The taxes drawn prior to payment totaled $4,035 out of a total of $784,941 tested in the sample of 40. Cause and Potential Effect The control to ensure that all costs were paid for prior to seeking reimbursement was not operating effectively to identify instances of noncompliance related to the applicable taxes. Questioned Cost The known unallowable costs identified in our sample items totaled $4,035. Management?s analysis identified a total of $51,803. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation We recommend that the University strengthen its processes and controls within the procurement office to ensure that all costs are paid prior to seeking reimbursement. View of Responsible Officials Management of the University takes no exception to this reported finding and has subsequently paid the applicable taxes and related interest. We have implemented the remedial actions as outlined in our Corrective Action Plan.
Finding 2022-020 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness and Noncompliance over Cash Management Repeat Finding: Yes Condition: For 1 out of 1 selection, we were unable to agree the drawdown amount to the general ledger to ensure funds were being expended prior to requesting the reimbursement. Criteria: In accordance with 2 CFR 200.303: Internal Control, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR 200.305, if unearned revenue balances are identified, balances must be consistent with the requirement to minimize the time between drawing and disbursing Federal funds. If advance payments are identified, verify that the non-Federal entity minimized the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-Federal entity. Under the reimbursement method, ascertain if the entity paid for the costs for which reimbursement was requested prior to the date of the reimbursement request. When a program receives program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries, or interest earned on such funds; ascertain if these funds were disbursed before requesting additional Federal cash draws. Review records to determine if interest in excess of $500 per year was earned on Federal cash draws. If so, determine if it was remitted annually to the Department of Health and Human Services, Payment Management System. According to AM 413-60, Grant Documentation, Grant Manager/Program Manager/Director Conducts ongoing monitoring and control of all reimbursement receipts and deposits until grant ends; as well as all program and sub-recipient (when applicable) documentation, to include: (1) program documentation; (2) timesheets; (3) deliverables; (4) activities; (5) vendor payments; (6) program data/charts/numbers; and (7) financial and compliance report. According to AM 413-61, Grant Management Financial Reporting, Grant Manager/Program Manager/Director maintains all documentation, either electronic or hard copy, for all Federally funded grants for the term of the grant for a minimum of seven years for review and audit by the granting agency or its designee. Finding 2022-020 (continued) Cause: The agency did not reconcile information presented in the expenditure report to the underlying records. Finance and the agency use different parameters for generating reports and there was no documentation of the reconciling differences. Effect: Expenditures reported to the Federal government could be inaccurate. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with reporting requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor?s Conclusion: Finding remains as stated.
Finding 2022-020 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness and Noncompliance over Cash Management Repeat Finding: Yes Condition: For 1 out of 1 selection, we were unable to agree the drawdown amount to the general ledger to ensure funds were being expended prior to requesting the reimbursement. Criteria: In accordance with 2 CFR 200.303: Internal Control, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR 200.305, if unearned revenue balances are identified, balances must be consistent with the requirement to minimize the time between drawing and disbursing Federal funds. If advance payments are identified, verify that the non-Federal entity minimized the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-Federal entity. Under the reimbursement method, ascertain if the entity paid for the costs for which reimbursement was requested prior to the date of the reimbursement request. When a program receives program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries, or interest earned on such funds; ascertain if these funds were disbursed before requesting additional Federal cash draws. Review records to determine if interest in excess of $500 per year was earned on Federal cash draws. If so, determine if it was remitted annually to the Department of Health and Human Services, Payment Management System. According to AM 413-60, Grant Documentation, Grant Manager/Program Manager/Director Conducts ongoing monitoring and control of all reimbursement receipts and deposits until grant ends; as well as all program and sub-recipient (when applicable) documentation, to include: (1) program documentation; (2) timesheets; (3) deliverables; (4) activities; (5) vendor payments; (6) program data/charts/numbers; and (7) financial and compliance report. According to AM 413-61, Grant Management Financial Reporting, Grant Manager/Program Manager/Director maintains all documentation, either electronic or hard copy, for all Federally funded grants for the term of the grant for a minimum of seven years for review and audit by the granting agency or its designee. Finding 2022-020 (continued) Cause: The agency did not reconcile information presented in the expenditure report to the underlying records. Finance and the agency use different parameters for generating reports and there was no documentation of the reconciling differences. Effect: Expenditures reported to the Federal government could be inaccurate. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with reporting requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor?s Conclusion: Finding remains as stated.
Finding 2022-021 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Material Weakness and Noncompliance over Cash Management Repeat Finding: Yes Condition: We were not able to agree the expenditure amount of expenditures per the drawdown request to the expenditure details per the general ledger. Criteria: In accordance with 2 CFR ?200.303, The Non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR 200.305, if unearned revenue balances are identified, balances must be consistent with the requirement to minimize the time between drawing and disbursing Federal funds. If advance payments are identified, verify that the non-Federal entity minimized the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-Federal entity. Under the reimbursement method, ascertain if the entity paid for the costs for which reimbursement was requested prior to the date of the reimbursement request. When a program receives program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries, or interest earned on such funds; ascertain if these funds were disbursed before requesting additional Federal cash draws. Review records to determine if interest in excess of $500 per year was earned on Federal cash draws. If so, determine if it was remitted annually to the Department of Health and Human Services, Payment Management System. According to AM 413-60, Grant Documentation, Grant Manager/Program Manager/Director Conducts ongoing monitoring and control of all reimbursement receipts and deposits until grant ends; as well as all program and sub-recipient (when applicable) documentation, to include: (1) program documentation; (2) timesheets; (3) deliverables; (4) activities; (5) vendor payments; (6) program data/charts/numbers; and (7) financial and compliance report. According to AM 413-61, Grant Management Financial Reporting, Grant Manager/Program Manager/Director maintains all documentation, either electronic or hard copy, for all Federally funded grants for the term of the grant for a minimum of seven years for review and audit by the granting agency or its designee. Finding 2022-021 (continued) Cause: The agency did not reconcile information presented in the expenditure report to the underlying records. Finance and the agency use different parameters for generating reports and there was no documentation of the reconciling differences. Effect: The City may not be in compliance with the cash management requirements in accordance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with cash management requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor?s Conclusion: Finding remains as stated.
Finding 2022-021 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Material Weakness and Noncompliance over Cash Management Repeat Finding: Yes Condition: We were not able to agree the expenditure amount of expenditures per the drawdown request to the expenditure details per the general ledger. Criteria: In accordance with 2 CFR ?200.303, The Non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR 200.305, if unearned revenue balances are identified, balances must be consistent with the requirement to minimize the time between drawing and disbursing Federal funds. If advance payments are identified, verify that the non-Federal entity minimized the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-Federal entity. Under the reimbursement method, ascertain if the entity paid for the costs for which reimbursement was requested prior to the date of the reimbursement request. When a program receives program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries, or interest earned on such funds; ascertain if these funds were disbursed before requesting additional Federal cash draws. Review records to determine if interest in excess of $500 per year was earned on Federal cash draws. If so, determine if it was remitted annually to the Department of Health and Human Services, Payment Management System. According to AM 413-60, Grant Documentation, Grant Manager/Program Manager/Director Conducts ongoing monitoring and control of all reimbursement receipts and deposits until grant ends; as well as all program and sub-recipient (when applicable) documentation, to include: (1) program documentation; (2) timesheets; (3) deliverables; (4) activities; (5) vendor payments; (6) program data/charts/numbers; and (7) financial and compliance report. According to AM 413-61, Grant Management Financial Reporting, Grant Manager/Program Manager/Director maintains all documentation, either electronic or hard copy, for all Federally funded grants for the term of the grant for a minimum of seven years for review and audit by the granting agency or its designee. Finding 2022-021 (continued) Cause: The agency did not reconcile information presented in the expenditure report to the underlying records. Finance and the agency use different parameters for generating reports and there was no documentation of the reconciling differences. Effect: The City may not be in compliance with the cash management requirements in accordance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with cash management requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor?s Conclusion: Finding remains as stated.
Finding 2022-021 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Material Weakness and Noncompliance over Cash Management Repeat Finding: Yes Condition: We were not able to agree the expenditure amount of expenditures per the drawdown request to the expenditure details per the general ledger. Criteria: In accordance with 2 CFR ?200.303, The Non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR 200.305, if unearned revenue balances are identified, balances must be consistent with the requirement to minimize the time between drawing and disbursing Federal funds. If advance payments are identified, verify that the non-Federal entity minimized the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-Federal entity. Under the reimbursement method, ascertain if the entity paid for the costs for which reimbursement was requested prior to the date of the reimbursement request. When a program receives program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries, or interest earned on such funds; ascertain if these funds were disbursed before requesting additional Federal cash draws. Review records to determine if interest in excess of $500 per year was earned on Federal cash draws. If so, determine if it was remitted annually to the Department of Health and Human Services, Payment Management System. According to AM 413-60, Grant Documentation, Grant Manager/Program Manager/Director Conducts ongoing monitoring and control of all reimbursement receipts and deposits until grant ends; as well as all program and sub-recipient (when applicable) documentation, to include: (1) program documentation; (2) timesheets; (3) deliverables; (4) activities; (5) vendor payments; (6) program data/charts/numbers; and (7) financial and compliance report. According to AM 413-61, Grant Management Financial Reporting, Grant Manager/Program Manager/Director maintains all documentation, either electronic or hard copy, for all Federally funded grants for the term of the grant for a minimum of seven years for review and audit by the granting agency or its designee. Finding 2022-021 (continued) Cause: The agency did not reconcile information presented in the expenditure report to the underlying records. Finance and the agency use different parameters for generating reports and there was no documentation of the reconciling differences. Effect: The City may not be in compliance with the cash management requirements in accordance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with cash management requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor?s Conclusion: Finding remains as stated.