Cash Management Federal Program Name Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria According to the 2 CFR 200.305(b) non-federal entities must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Also, CRRSAA HEERF II and ARP HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Institutional Aid Portion, (a)(2), and (a)(3) funds should be disbursed within 3 calendar days of the drawdown from G5. Condition During our examination, we found the following instances on which the Institution did not disbursed funds in an expedite matter: Fund Instances Average of days late 84.425F 106 7 84.425L 5 31 Cause The delay in disbursements responds to several situations: remote work, lack of banking or information from suppliers, multiplicity of tasks under the responsibility of the Administration and Operations Director, which affected the dates of sending the payments. Effect As a result of this condition, the USDE may issue warnings and/or impose penalties to the Institution. Questioned Cost None Context During our examination, we noted one hundred six (106) instances from one hundred thirty-six (136) of the HEERF Institutional portion and five (5) instances from five (5) from Minority, on which the Institution did not disbursed funds within 3 calendar days of the drawdown from G5. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation The management of the Institution should reinforce its cash management procedures and internal controls to ensure the disbursement of funds in the required time frame after the drawdowns from G5. Views of Responsible Officials of the Auditee and Planned Corrective Actions The management of the Institution agrees with this finding. Please refer to the corrective action plan on pages 22-26.
Cash Management Federal Program Name Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria According to the 2 CFR 200.305(b) non-federal entities must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. Also, CRRSAA HEERF II and ARP HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Institutional Aid Portion, (a)(2), and (a)(3) funds should be disbursed within 3 calendar days of the drawdown from G5. Condition During our examination, we found the following instances on which the Institution did not disbursed funds in an expedite matter: Fund Instances Average of days late 84.425F 106 7 84.425L 5 31 Cause The delay in disbursements responds to several situations: remote work, lack of banking or information from suppliers, multiplicity of tasks under the responsibility of the Administration and Operations Director, which affected the dates of sending the payments. Effect As a result of this condition, the USDE may issue warnings and/or impose penalties to the Institution. Questioned Cost None Context During our examination, we noted one hundred six (106) instances from one hundred thirty-six (136) of the HEERF Institutional portion and five (5) instances from five (5) from Minority, on which the Institution did not disbursed funds within 3 calendar days of the drawdown from G5. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation The management of the Institution should reinforce its cash management procedures and internal controls to ensure the disbursement of funds in the required time frame after the drawdowns from G5. Views of Responsible Officials of the Auditee and Planned Corrective Actions The management of the Institution agrees with this finding. Please refer to the corrective action plan on pages 22-26.
FA 2022-003 Improve Controls over Cash Management Compliance Requirement: Cash Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: 84.010 –Title I Grants to Local Educational Agencies Federal Award Numbers: SO10A200010 (Year: 2021), S010A210010-21A (Year: 2022) Questioned Costs: None Identified Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 – 84.425D – Elementary and Secondary School Emergency Relief Fund COVID-19 – 84.425W – American Rescue Plan Elementary and Secondary School Emergency Relief Fund – Homeless Children and Youth Federal Award Numbers: S425D210012 (Year: 2021), S425W210011 (Year: 2021) Questioned Costs: None Identified Repeat of Prior Year Findings: FA 2021-001, FA 2020-001, FA 2019-001, FA 2018-001, FA 2017-002, FA 2016-001, FA 2015-002, FA 2014-003 Description: The School District made cash drawdowns in excess of immediate cash needs for the Title I Grants to Local Educational Agencies and Elementary and Secondary School Emergency Relief Fund programs. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Background Information: The School District may request Title I Grants to Local Educational Agencies (Title I) and Elementary and Secondary School Emergency Relief (ESSER) Fund program funds from the Georgia Department of Education (GaDOE) once per month. GaDOE requires the School District to submit DE-0147 – Requests for Reimbursement of Monthly Cash Disbursements through the Grants Accounting Online Reporting System to receive program funds. When a DE-0147 request is submitted and approved, the funds are typically disbursed to the School District through an electronic payment process the next week. The School District submitted DE-0147 requests to receive a total of $390,112 in Title I funds and a total of $498,996 in ESSER funds from GaDOE during the fiscal year under review. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance Section 200.305(b) state that “For non-Federal entities other than states, payment methods must minimize the time elapsing between the transfer of funds… the pass-through entity and the disbursement by the non-Federal entity.” In addition, the Uniform Guidance Section 200.302(b)(6) requires the entity to develop written cash management procedures. Further, as noted in the Uniform Guidance Section 200.511, management is responsible for implementing reported corrective action to findings from previous audits. Condition: A review of all cash drawdowns and disbursements related to the Title I and ESSER programs was performed to determine if any excessive cash balances were maintained during the fiscal year under review. Cash balances in excess of program materiality were maintained for the Title I program for 365 days and the ESSER program for 121 days. Additionally, it was noted that the School District did not have appropriate internal controls in place over the cash drawdown process. Cause: In discussing this issue with the School District, they indicated that the lack of review of federal grants resulted in excess cash drawdown requests. Effect: The School District was not in compliance with the Uniform Guidance and GaDOE guidance. In addition, the School District could potentially accrue an interest liability that would be owed back to the federal government. Furthermore, when the School District cannot meet the requirement to minimize the time elapsing between the transfer of funds and disbursement of those funds, provisions included in the Uniform Guidance allow GaDOE to change the method by which the School District is transferred funds and delay the School District’s receipt of these funds. This may include a requirement by GaDOE to submit invoices prior to being reimbursed for program expenditures. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Recommendation: The School District should establish procedures to accurately forecast the cash needs of the Title I and ESSER programs and minimize the time elapsing between the transfer of funds from GaDOE and the disbursement of such funds by the School District. In addition, these procedures should be documented in writing in accordance with the Uniform Guidance Section 200.302(b)(6). Furthermore, management should develop and implement a monitoring process to ensure that these procedures are followed. Views of Responsible Officials: We concur with this finding.
FA 2022-003 Improve Controls over Cash Management Compliance Requirement: Cash Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: 84.010 –Title I Grants to Local Educational Agencies Federal Award Numbers: SO10A200010 (Year: 2021), S010A210010-21A (Year: 2022) Questioned Costs: None Identified Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 – 84.425D – Elementary and Secondary School Emergency Relief Fund COVID-19 – 84.425W – American Rescue Plan Elementary and Secondary School Emergency Relief Fund – Homeless Children and Youth Federal Award Numbers: S425D210012 (Year: 2021), S425W210011 (Year: 2021) Questioned Costs: None Identified Repeat of Prior Year Findings: FA 2021-001, FA 2020-001, FA 2019-001, FA 2018-001, FA 2017-002, FA 2016-001, FA 2015-002, FA 2014-003 Description: The School District made cash drawdowns in excess of immediate cash needs for the Title I Grants to Local Educational Agencies and Elementary and Secondary School Emergency Relief Fund programs. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Background Information: The School District may request Title I Grants to Local Educational Agencies (Title I) and Elementary and Secondary School Emergency Relief (ESSER) Fund program funds from the Georgia Department of Education (GaDOE) once per month. GaDOE requires the School District to submit DE-0147 – Requests for Reimbursement of Monthly Cash Disbursements through the Grants Accounting Online Reporting System to receive program funds. When a DE-0147 request is submitted and approved, the funds are typically disbursed to the School District through an electronic payment process the next week. The School District submitted DE-0147 requests to receive a total of $390,112 in Title I funds and a total of $498,996 in ESSER funds from GaDOE during the fiscal year under review. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance Section 200.305(b) state that “For non-Federal entities other than states, payment methods must minimize the time elapsing between the transfer of funds… the pass-through entity and the disbursement by the non-Federal entity.” In addition, the Uniform Guidance Section 200.302(b)(6) requires the entity to develop written cash management procedures. Further, as noted in the Uniform Guidance Section 200.511, management is responsible for implementing reported corrective action to findings from previous audits. Condition: A review of all cash drawdowns and disbursements related to the Title I and ESSER programs was performed to determine if any excessive cash balances were maintained during the fiscal year under review. Cash balances in excess of program materiality were maintained for the Title I program for 365 days and the ESSER program for 121 days. Additionally, it was noted that the School District did not have appropriate internal controls in place over the cash drawdown process. Cause: In discussing this issue with the School District, they indicated that the lack of review of federal grants resulted in excess cash drawdown requests. Effect: The School District was not in compliance with the Uniform Guidance and GaDOE guidance. In addition, the School District could potentially accrue an interest liability that would be owed back to the federal government. Furthermore, when the School District cannot meet the requirement to minimize the time elapsing between the transfer of funds and disbursement of those funds, provisions included in the Uniform Guidance allow GaDOE to change the method by which the School District is transferred funds and delay the School District’s receipt of these funds. This may include a requirement by GaDOE to submit invoices prior to being reimbursed for program expenditures. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Recommendation: The School District should establish procedures to accurately forecast the cash needs of the Title I and ESSER programs and minimize the time elapsing between the transfer of funds from GaDOE and the disbursement of such funds by the School District. In addition, these procedures should be documented in writing in accordance with the Uniform Guidance Section 200.302(b)(6). Furthermore, management should develop and implement a monitoring process to ensure that these procedures are followed. Views of Responsible Officials: We concur with this finding.
FA 2022-003 Improve Controls over Cash Management Compliance Requirement: Cash Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: 84.010 –Title I Grants to Local Educational Agencies Federal Award Numbers: SO10A200010 (Year: 2021), S010A210010-21A (Year: 2022) Questioned Costs: None Identified Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 – 84.425D – Elementary and Secondary School Emergency Relief Fund COVID-19 – 84.425W – American Rescue Plan Elementary and Secondary School Emergency Relief Fund – Homeless Children and Youth Federal Award Numbers: S425D210012 (Year: 2021), S425W210011 (Year: 2021) Questioned Costs: None Identified Repeat of Prior Year Findings: FA 2021-001, FA 2020-001, FA 2019-001, FA 2018-001, FA 2017-002, FA 2016-001, FA 2015-002, FA 2014-003 Description: The School District made cash drawdowns in excess of immediate cash needs for the Title I Grants to Local Educational Agencies and Elementary and Secondary School Emergency Relief Fund programs. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Background Information: The School District may request Title I Grants to Local Educational Agencies (Title I) and Elementary and Secondary School Emergency Relief (ESSER) Fund program funds from the Georgia Department of Education (GaDOE) once per month. GaDOE requires the School District to submit DE-0147 – Requests for Reimbursement of Monthly Cash Disbursements through the Grants Accounting Online Reporting System to receive program funds. When a DE-0147 request is submitted and approved, the funds are typically disbursed to the School District through an electronic payment process the next week. The School District submitted DE-0147 requests to receive a total of $390,112 in Title I funds and a total of $498,996 in ESSER funds from GaDOE during the fiscal year under review. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance Section 200.305(b) state that “For non-Federal entities other than states, payment methods must minimize the time elapsing between the transfer of funds… the pass-through entity and the disbursement by the non-Federal entity.” In addition, the Uniform Guidance Section 200.302(b)(6) requires the entity to develop written cash management procedures. Further, as noted in the Uniform Guidance Section 200.511, management is responsible for implementing reported corrective action to findings from previous audits. Condition: A review of all cash drawdowns and disbursements related to the Title I and ESSER programs was performed to determine if any excessive cash balances were maintained during the fiscal year under review. Cash balances in excess of program materiality were maintained for the Title I program for 365 days and the ESSER program for 121 days. Additionally, it was noted that the School District did not have appropriate internal controls in place over the cash drawdown process. Cause: In discussing this issue with the School District, they indicated that the lack of review of federal grants resulted in excess cash drawdown requests. Effect: The School District was not in compliance with the Uniform Guidance and GaDOE guidance. In addition, the School District could potentially accrue an interest liability that would be owed back to the federal government. Furthermore, when the School District cannot meet the requirement to minimize the time elapsing between the transfer of funds and disbursement of those funds, provisions included in the Uniform Guidance allow GaDOE to change the method by which the School District is transferred funds and delay the School District’s receipt of these funds. This may include a requirement by GaDOE to submit invoices prior to being reimbursed for program expenditures. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Recommendation: The School District should establish procedures to accurately forecast the cash needs of the Title I and ESSER programs and minimize the time elapsing between the transfer of funds from GaDOE and the disbursement of such funds by the School District. In addition, these procedures should be documented in writing in accordance with the Uniform Guidance Section 200.302(b)(6). Furthermore, management should develop and implement a monitoring process to ensure that these procedures are followed. Views of Responsible Officials: We concur with this finding.
FA 2022-003 Improve Controls over Cash Management Compliance Requirement: Cash Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: 84.010 –Title I Grants to Local Educational Agencies Federal Award Numbers: SO10A200010 (Year: 2021), S010A210010-21A (Year: 2022) Questioned Costs: None Identified Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 – 84.425D – Elementary and Secondary School Emergency Relief Fund COVID-19 – 84.425W – American Rescue Plan Elementary and Secondary School Emergency Relief Fund – Homeless Children and Youth Federal Award Numbers: S425D210012 (Year: 2021), S425W210011 (Year: 2021) Questioned Costs: None Identified Repeat of Prior Year Findings: FA 2021-001, FA 2020-001, FA 2019-001, FA 2018-001, FA 2017-002, FA 2016-001, FA 2015-002, FA 2014-003 Description: The School District made cash drawdowns in excess of immediate cash needs for the Title I Grants to Local Educational Agencies and Elementary and Secondary School Emergency Relief Fund programs. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Background Information: The School District may request Title I Grants to Local Educational Agencies (Title I) and Elementary and Secondary School Emergency Relief (ESSER) Fund program funds from the Georgia Department of Education (GaDOE) once per month. GaDOE requires the School District to submit DE-0147 – Requests for Reimbursement of Monthly Cash Disbursements through the Grants Accounting Online Reporting System to receive program funds. When a DE-0147 request is submitted and approved, the funds are typically disbursed to the School District through an electronic payment process the next week. The School District submitted DE-0147 requests to receive a total of $390,112 in Title I funds and a total of $498,996 in ESSER funds from GaDOE during the fiscal year under review. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance Section 200.305(b) state that “For non-Federal entities other than states, payment methods must minimize the time elapsing between the transfer of funds… the pass-through entity and the disbursement by the non-Federal entity.” In addition, the Uniform Guidance Section 200.302(b)(6) requires the entity to develop written cash management procedures. Further, as noted in the Uniform Guidance Section 200.511, management is responsible for implementing reported corrective action to findings from previous audits. Condition: A review of all cash drawdowns and disbursements related to the Title I and ESSER programs was performed to determine if any excessive cash balances were maintained during the fiscal year under review. Cash balances in excess of program materiality were maintained for the Title I program for 365 days and the ESSER program for 121 days. Additionally, it was noted that the School District did not have appropriate internal controls in place over the cash drawdown process. Cause: In discussing this issue with the School District, they indicated that the lack of review of federal grants resulted in excess cash drawdown requests. Effect: The School District was not in compliance with the Uniform Guidance and GaDOE guidance. In addition, the School District could potentially accrue an interest liability that would be owed back to the federal government. Furthermore, when the School District cannot meet the requirement to minimize the time elapsing between the transfer of funds and disbursement of those funds, provisions included in the Uniform Guidance allow GaDOE to change the method by which the School District is transferred funds and delay the School District’s receipt of these funds. This may include a requirement by GaDOE to submit invoices prior to being reimbursed for program expenditures. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Recommendation: The School District should establish procedures to accurately forecast the cash needs of the Title I and ESSER programs and minimize the time elapsing between the transfer of funds from GaDOE and the disbursement of such funds by the School District. In addition, these procedures should be documented in writing in accordance with the Uniform Guidance Section 200.302(b)(6). Furthermore, management should develop and implement a monitoring process to ensure that these procedures are followed. Views of Responsible Officials: We concur with this finding.
Finding Reference Number: SA 2022-005 Cash Management – Drawdown of Grant Funds In Advance of Disbursement AL Number: 14.218 Assistance Listing Title: CDBG - Entitlement Grants Cluster – Community Development Block Grants/Entitlement Grants COVID-19 - Community Development Block Grants/Entitlement Grants-CV Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-14-MC-06-0037, B-15-MC-06-0037, B-16-MC-06-0037, B-17-MC-06-0037, B-18-MC-06-0037, B-19-MC-06-0037, B-20-MC-06-0037, B-20-MW-06-0037, B-21-MC-06-0037 Criteria: Under 2 CFR 200.305, a CDBG grantee is prohibited from drawing funds down from its line of credit in advance of cash needs, and must minimize the time elapsing between the transfer of funds from its line of credit, and the disbursement of the funds. Advance payment must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the grantee or subrecipient carrying out an eligible activity. The general rule is that CDBG funds must be used within three business days they are drawn down. Condition: We selected thirteen disbursements related to projects, subgrants and administrative expenditures and noted one disbursement on September 30, 2021 was included in a reimbursement request on September 9, 2021 and payment was received from HUD on September 13, 2021, which is seventeen days prior to payment to the vendor. Effect: Drawing down funds in advance and not disbursing the funds in three days or less does not minimize the time elapsing between receipt of funds and expenditures and is not in compliance with the cash management provisions of 2 CFR 200.305 and the CDBG program. Cause: We understand the disbursement was requested prior to payment due to staff oversight. Recommendation: The City should not draw down funds until expenditures have been paid in cash and in the event drawdowns occur prior to disbursement, ensure that the time elapsing between the draw down and the expenditure is minimized. In addition, the City should determine whether the interest earned on the grant funds advanced needs to be returned to the grantor. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.
Finding Reference Number: SA 2022-005 Cash Management – Drawdown of Grant Funds In Advance of Disbursement AL Number: 14.218 Assistance Listing Title: CDBG - Entitlement Grants Cluster – Community Development Block Grants/Entitlement Grants COVID-19 - Community Development Block Grants/Entitlement Grants-CV Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-14-MC-06-0037, B-15-MC-06-0037, B-16-MC-06-0037, B-17-MC-06-0037, B-18-MC-06-0037, B-19-MC-06-0037, B-20-MC-06-0037, B-20-MW-06-0037, B-21-MC-06-0037 Criteria: Under 2 CFR 200.305, a CDBG grantee is prohibited from drawing funds down from its line of credit in advance of cash needs, and must minimize the time elapsing between the transfer of funds from its line of credit, and the disbursement of the funds. Advance payment must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the grantee or subrecipient carrying out an eligible activity. The general rule is that CDBG funds must be used within three business days they are drawn down. Condition: We selected thirteen disbursements related to projects, subgrants and administrative expenditures and noted one disbursement on September 30, 2021 was included in a reimbursement request on September 9, 2021 and payment was received from HUD on September 13, 2021, which is seventeen days prior to payment to the vendor. Effect: Drawing down funds in advance and not disbursing the funds in three days or less does not minimize the time elapsing between receipt of funds and expenditures and is not in compliance with the cash management provisions of 2 CFR 200.305 and the CDBG program. Cause: We understand the disbursement was requested prior to payment due to staff oversight. Recommendation: The City should not draw down funds until expenditures have been paid in cash and in the event drawdowns occur prior to disbursement, ensure that the time elapsing between the draw down and the expenditure is minimized. In addition, the City should determine whether the interest earned on the grant funds advanced needs to be returned to the grantor. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.
2022-005 - Internal Control Over Compliance and Compliance – Cash Management Program- U.S. Department of Energy, Environmental Monitoring/Cleanup, Cultural and Resource Management Emergency Response Research, Outreach, Technical Analysis ALN: 81.214, Award #: DE-EM0005173, Award Year: 04/23/2018 – 06/30/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR Section 200.305(b)(3), for non-Federal entities funded under the reimbursement method, reimbursement requests should be supported by documentation to verify that the entity paid for the costs for which reimbursement was requested prior to the date of the reimbursement request. Condition – During our cash management testing for major program ALN 81.214, we noted the following: • For three (3) out of four (4) samples selected for testing, NGA Center was unable to provide documentation showing review and approval of the cash drawdown requests. • For one (1) out of four (4) sample selected for testing, NGA Center was unable to provide the supporting calculation of the cash drawdown request. • In addition, expenditures reflected in the cash drawdown requests were not reconciled with the general ledger. For the first three quarters of fiscal year 2022, the compensated absences and fringe benefits were included in the cash drawdown requests, however, NGA Center did not record the transactions in the general ledger during those quarters. Also, certain contractual services recorded in the general ledger during the last quarter of fiscal year 2022 were excluded on the cash drawdown request. During our cash management testing for major program ALN 93.421, we noted the following: • For two (2) out of two (2) samples selected for testing, NGA Center was unable to provide documentation showing review and approval of the cash drawdown requests. • For one (1) out of two (2) samples selected for testing, NGA Center was unable to provide the supporting calculation of the cash drawdown request. • In addition, expenditures reflected in the cash drawdown requests are not reconciled with the general ledger. During the first half of fiscal year 2022, compensated absences and fringe benefits were included in the cash drawdown request, however, NGA Center did not record the transactions in the general ledger during that period. Also, certain contractual services recorded in the general ledger during the last three quarters were excluded on the cash drawdown requests. Questioned Costs – Not determinable. Context – This is a condition identified per review of NGA Center’s compliance with the provisions of the grant agreements and general compliance principles. Cause – NGA Center did not appear to exercise due diligence in requesting Federal funds consistent with the grant agreements and its actual cash needs. Effect – NGA Center is not in compliance with the stated provisions. The opportunity to use the money for other immediate cash needs is unnecessarily delayed when funds are not requested timely. Repeat Finding – This is not a repeat finding. Recommendation - We recommend that NGA Center comply with the provisions of the grant agreements and request Federal funds consistent with the grant agreement funding techniques and clearance patterns for these programs. Views of Responsible Officials – NGA Center agrees with the finding and recommendations of this finding set forth within and has developed a corrective action plan to address the lapse in the prescribed internal controls.
2022-005 - Internal Control Over Compliance and Compliance – Cash Management Program- U.S. Department of Energy, Environmental Monitoring/Cleanup, Cultural and Resource Management Emergency Response Research, Outreach, Technical Analysis ALN: 81.214, Award #: DE-EM0005173, Award Year: 04/23/2018 – 06/30/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR Section 200.305(b)(3), for non-Federal entities funded under the reimbursement method, reimbursement requests should be supported by documentation to verify that the entity paid for the costs for which reimbursement was requested prior to the date of the reimbursement request. Condition – During our cash management testing for major program ALN 81.214, we noted the following: • For three (3) out of four (4) samples selected for testing, NGA Center was unable to provide documentation showing review and approval of the cash drawdown requests. • For one (1) out of four (4) sample selected for testing, NGA Center was unable to provide the supporting calculation of the cash drawdown request. • In addition, expenditures reflected in the cash drawdown requests were not reconciled with the general ledger. For the first three quarters of fiscal year 2022, the compensated absences and fringe benefits were included in the cash drawdown requests, however, NGA Center did not record the transactions in the general ledger during those quarters. Also, certain contractual services recorded in the general ledger during the last quarter of fiscal year 2022 were excluded on the cash drawdown request. During our cash management testing for major program ALN 93.421, we noted the following: • For two (2) out of two (2) samples selected for testing, NGA Center was unable to provide documentation showing review and approval of the cash drawdown requests. • For one (1) out of two (2) samples selected for testing, NGA Center was unable to provide the supporting calculation of the cash drawdown request. • In addition, expenditures reflected in the cash drawdown requests are not reconciled with the general ledger. During the first half of fiscal year 2022, compensated absences and fringe benefits were included in the cash drawdown request, however, NGA Center did not record the transactions in the general ledger during that period. Also, certain contractual services recorded in the general ledger during the last three quarters were excluded on the cash drawdown requests. Questioned Costs – Not determinable. Context – This is a condition identified per review of NGA Center’s compliance with the provisions of the grant agreements and general compliance principles. Cause – NGA Center did not appear to exercise due diligence in requesting Federal funds consistent with the grant agreements and its actual cash needs. Effect – NGA Center is not in compliance with the stated provisions. The opportunity to use the money for other immediate cash needs is unnecessarily delayed when funds are not requested timely. Repeat Finding – This is not a repeat finding. Recommendation - We recommend that NGA Center comply with the provisions of the grant agreements and request Federal funds consistent with the grant agreement funding techniques and clearance patterns for these programs. Views of Responsible Officials – NGA Center agrees with the finding and recommendations of this finding set forth within and has developed a corrective action plan to address the lapse in the prescribed internal controls.
2022-005 - Internal Control Over Compliance and Compliance – Cash Management Program- U.S. Department of Energy, Environmental Monitoring/Cleanup, Cultural and Resource Management Emergency Response Research, Outreach, Technical Analysis ALN: 81.214, Award #: DE-EM0005173, Award Year: 04/23/2018 – 06/30/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR Section 200.305(b)(3), for non-Federal entities funded under the reimbursement method, reimbursement requests should be supported by documentation to verify that the entity paid for the costs for which reimbursement was requested prior to the date of the reimbursement request. Condition – During our cash management testing for major program ALN 81.214, we noted the following: • For three (3) out of four (4) samples selected for testing, NGA Center was unable to provide documentation showing review and approval of the cash drawdown requests. • For one (1) out of four (4) sample selected for testing, NGA Center was unable to provide the supporting calculation of the cash drawdown request. • In addition, expenditures reflected in the cash drawdown requests were not reconciled with the general ledger. For the first three quarters of fiscal year 2022, the compensated absences and fringe benefits were included in the cash drawdown requests, however, NGA Center did not record the transactions in the general ledger during those quarters. Also, certain contractual services recorded in the general ledger during the last quarter of fiscal year 2022 were excluded on the cash drawdown request. During our cash management testing for major program ALN 93.421, we noted the following: • For two (2) out of two (2) samples selected for testing, NGA Center was unable to provide documentation showing review and approval of the cash drawdown requests. • For one (1) out of two (2) samples selected for testing, NGA Center was unable to provide the supporting calculation of the cash drawdown request. • In addition, expenditures reflected in the cash drawdown requests are not reconciled with the general ledger. During the first half of fiscal year 2022, compensated absences and fringe benefits were included in the cash drawdown request, however, NGA Center did not record the transactions in the general ledger during that period. Also, certain contractual services recorded in the general ledger during the last three quarters were excluded on the cash drawdown requests. Questioned Costs – Not determinable. Context – This is a condition identified per review of NGA Center’s compliance with the provisions of the grant agreements and general compliance principles. Cause – NGA Center did not appear to exercise due diligence in requesting Federal funds consistent with the grant agreements and its actual cash needs. Effect – NGA Center is not in compliance with the stated provisions. The opportunity to use the money for other immediate cash needs is unnecessarily delayed when funds are not requested timely. Repeat Finding – This is not a repeat finding. Recommendation - We recommend that NGA Center comply with the provisions of the grant agreements and request Federal funds consistent with the grant agreement funding techniques and clearance patterns for these programs. Views of Responsible Officials – NGA Center agrees with the finding and recommendations of this finding set forth within and has developed a corrective action plan to address the lapse in the prescribed internal controls.
2022-005 - Internal Control Over Compliance and Compliance – Cash Management Program- U.S. Department of Energy, Environmental Monitoring/Cleanup, Cultural and Resource Management Emergency Response Research, Outreach, Technical Analysis ALN: 81.214, Award #: DE-EM0005173, Award Year: 04/23/2018 – 06/30/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR Section 200.305(b)(3), for non-Federal entities funded under the reimbursement method, reimbursement requests should be supported by documentation to verify that the entity paid for the costs for which reimbursement was requested prior to the date of the reimbursement request. Condition – During our cash management testing for major program ALN 81.214, we noted the following: • For three (3) out of four (4) samples selected for testing, NGA Center was unable to provide documentation showing review and approval of the cash drawdown requests. • For one (1) out of four (4) sample selected for testing, NGA Center was unable to provide the supporting calculation of the cash drawdown request. • In addition, expenditures reflected in the cash drawdown requests were not reconciled with the general ledger. For the first three quarters of fiscal year 2022, the compensated absences and fringe benefits were included in the cash drawdown requests, however, NGA Center did not record the transactions in the general ledger during those quarters. Also, certain contractual services recorded in the general ledger during the last quarter of fiscal year 2022 were excluded on the cash drawdown request. During our cash management testing for major program ALN 93.421, we noted the following: • For two (2) out of two (2) samples selected for testing, NGA Center was unable to provide documentation showing review and approval of the cash drawdown requests. • For one (1) out of two (2) samples selected for testing, NGA Center was unable to provide the supporting calculation of the cash drawdown request. • In addition, expenditures reflected in the cash drawdown requests are not reconciled with the general ledger. During the first half of fiscal year 2022, compensated absences and fringe benefits were included in the cash drawdown request, however, NGA Center did not record the transactions in the general ledger during that period. Also, certain contractual services recorded in the general ledger during the last three quarters were excluded on the cash drawdown requests. Questioned Costs – Not determinable. Context – This is a condition identified per review of NGA Center’s compliance with the provisions of the grant agreements and general compliance principles. Cause – NGA Center did not appear to exercise due diligence in requesting Federal funds consistent with the grant agreements and its actual cash needs. Effect – NGA Center is not in compliance with the stated provisions. The opportunity to use the money for other immediate cash needs is unnecessarily delayed when funds are not requested timely. Repeat Finding – This is not a repeat finding. Recommendation - We recommend that NGA Center comply with the provisions of the grant agreements and request Federal funds consistent with the grant agreement funding techniques and clearance patterns for these programs. Views of Responsible Officials – NGA Center agrees with the finding and recommendations of this finding set forth within and has developed a corrective action plan to address the lapse in the prescribed internal controls.
2022-005 - Internal Control Over Compliance and Compliance – Cash Management Program- U.S. Department of Energy, Environmental Monitoring/Cleanup, Cultural and Resource Management Emergency Response Research, Outreach, Technical Analysis ALN: 81.214, Award #: DE-EM0005173, Award Year: 04/23/2018 – 06/30/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR Section 200.305(b)(3), for non-Federal entities funded under the reimbursement method, reimbursement requests should be supported by documentation to verify that the entity paid for the costs for which reimbursement was requested prior to the date of the reimbursement request. Condition – During our cash management testing for major program ALN 81.214, we noted the following: • For three (3) out of four (4) samples selected for testing, NGA Center was unable to provide documentation showing review and approval of the cash drawdown requests. • For one (1) out of four (4) sample selected for testing, NGA Center was unable to provide the supporting calculation of the cash drawdown request. • In addition, expenditures reflected in the cash drawdown requests were not reconciled with the general ledger. For the first three quarters of fiscal year 2022, the compensated absences and fringe benefits were included in the cash drawdown requests, however, NGA Center did not record the transactions in the general ledger during those quarters. Also, certain contractual services recorded in the general ledger during the last quarter of fiscal year 2022 were excluded on the cash drawdown request. During our cash management testing for major program ALN 93.421, we noted the following: • For two (2) out of two (2) samples selected for testing, NGA Center was unable to provide documentation showing review and approval of the cash drawdown requests. • For one (1) out of two (2) samples selected for testing, NGA Center was unable to provide the supporting calculation of the cash drawdown request. • In addition, expenditures reflected in the cash drawdown requests are not reconciled with the general ledger. During the first half of fiscal year 2022, compensated absences and fringe benefits were included in the cash drawdown request, however, NGA Center did not record the transactions in the general ledger during that period. Also, certain contractual services recorded in the general ledger during the last three quarters were excluded on the cash drawdown requests. Questioned Costs – Not determinable. Context – This is a condition identified per review of NGA Center’s compliance with the provisions of the grant agreements and general compliance principles. Cause – NGA Center did not appear to exercise due diligence in requesting Federal funds consistent with the grant agreements and its actual cash needs. Effect – NGA Center is not in compliance with the stated provisions. The opportunity to use the money for other immediate cash needs is unnecessarily delayed when funds are not requested timely. Repeat Finding – This is not a repeat finding. Recommendation - We recommend that NGA Center comply with the provisions of the grant agreements and request Federal funds consistent with the grant agreement funding techniques and clearance patterns for these programs. Views of Responsible Officials – NGA Center agrees with the finding and recommendations of this finding set forth within and has developed a corrective action plan to address the lapse in the prescribed internal controls.
2022-005 - Internal Control Over Compliance and Compliance – Cash Management Program- U.S. Department of Energy, Environmental Monitoring/Cleanup, Cultural and Resource Management Emergency Response Research, Outreach, Technical Analysis ALN: 81.214, Award #: DE-EM0005173, Award Year: 04/23/2018 – 06/30/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR Section 200.305(b)(3), for non-Federal entities funded under the reimbursement method, reimbursement requests should be supported by documentation to verify that the entity paid for the costs for which reimbursement was requested prior to the date of the reimbursement request. Condition – During our cash management testing for major program ALN 81.214, we noted the following: • For three (3) out of four (4) samples selected for testing, NGA Center was unable to provide documentation showing review and approval of the cash drawdown requests. • For one (1) out of four (4) sample selected for testing, NGA Center was unable to provide the supporting calculation of the cash drawdown request. • In addition, expenditures reflected in the cash drawdown requests were not reconciled with the general ledger. For the first three quarters of fiscal year 2022, the compensated absences and fringe benefits were included in the cash drawdown requests, however, NGA Center did not record the transactions in the general ledger during those quarters. Also, certain contractual services recorded in the general ledger during the last quarter of fiscal year 2022 were excluded on the cash drawdown request. During our cash management testing for major program ALN 93.421, we noted the following: • For two (2) out of two (2) samples selected for testing, NGA Center was unable to provide documentation showing review and approval of the cash drawdown requests. • For one (1) out of two (2) samples selected for testing, NGA Center was unable to provide the supporting calculation of the cash drawdown request. • In addition, expenditures reflected in the cash drawdown requests are not reconciled with the general ledger. During the first half of fiscal year 2022, compensated absences and fringe benefits were included in the cash drawdown request, however, NGA Center did not record the transactions in the general ledger during that period. Also, certain contractual services recorded in the general ledger during the last three quarters were excluded on the cash drawdown requests. Questioned Costs – Not determinable. Context – This is a condition identified per review of NGA Center’s compliance with the provisions of the grant agreements and general compliance principles. Cause – NGA Center did not appear to exercise due diligence in requesting Federal funds consistent with the grant agreements and its actual cash needs. Effect – NGA Center is not in compliance with the stated provisions. The opportunity to use the money for other immediate cash needs is unnecessarily delayed when funds are not requested timely. Repeat Finding – This is not a repeat finding. Recommendation - We recommend that NGA Center comply with the provisions of the grant agreements and request Federal funds consistent with the grant agreement funding techniques and clearance patterns for these programs. Views of Responsible Officials – NGA Center agrees with the finding and recommendations of this finding set forth within and has developed a corrective action plan to address the lapse in the prescribed internal controls.
2022-005 - Internal Control Over Compliance and Compliance – Cash Management Program- U.S. Department of Energy, Environmental Monitoring/Cleanup, Cultural and Resource Management Emergency Response Research, Outreach, Technical Analysis ALN: 81.214, Award #: DE-EM0005173, Award Year: 04/23/2018 – 06/30/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR Section 200.305(b)(3), for non-Federal entities funded under the reimbursement method, reimbursement requests should be supported by documentation to verify that the entity paid for the costs for which reimbursement was requested prior to the date of the reimbursement request. Condition – During our cash management testing for major program ALN 81.214, we noted the following: • For three (3) out of four (4) samples selected for testing, NGA Center was unable to provide documentation showing review and approval of the cash drawdown requests. • For one (1) out of four (4) sample selected for testing, NGA Center was unable to provide the supporting calculation of the cash drawdown request. • In addition, expenditures reflected in the cash drawdown requests were not reconciled with the general ledger. For the first three quarters of fiscal year 2022, the compensated absences and fringe benefits were included in the cash drawdown requests, however, NGA Center did not record the transactions in the general ledger during those quarters. Also, certain contractual services recorded in the general ledger during the last quarter of fiscal year 2022 were excluded on the cash drawdown request. During our cash management testing for major program ALN 93.421, we noted the following: • For two (2) out of two (2) samples selected for testing, NGA Center was unable to provide documentation showing review and approval of the cash drawdown requests. • For one (1) out of two (2) samples selected for testing, NGA Center was unable to provide the supporting calculation of the cash drawdown request. • In addition, expenditures reflected in the cash drawdown requests are not reconciled with the general ledger. During the first half of fiscal year 2022, compensated absences and fringe benefits were included in the cash drawdown request, however, NGA Center did not record the transactions in the general ledger during that period. Also, certain contractual services recorded in the general ledger during the last three quarters were excluded on the cash drawdown requests. Questioned Costs – Not determinable. Context – This is a condition identified per review of NGA Center’s compliance with the provisions of the grant agreements and general compliance principles. Cause – NGA Center did not appear to exercise due diligence in requesting Federal funds consistent with the grant agreements and its actual cash needs. Effect – NGA Center is not in compliance with the stated provisions. The opportunity to use the money for other immediate cash needs is unnecessarily delayed when funds are not requested timely. Repeat Finding – This is not a repeat finding. Recommendation - We recommend that NGA Center comply with the provisions of the grant agreements and request Federal funds consistent with the grant agreement funding techniques and clearance patterns for these programs. Views of Responsible Officials – NGA Center agrees with the finding and recommendations of this finding set forth within and has developed a corrective action plan to address the lapse in the prescribed internal controls.
2022-005 - Internal Control Over Compliance and Compliance – Cash Management Program- U.S. Department of Energy, Environmental Monitoring/Cleanup, Cultural and Resource Management Emergency Response Research, Outreach, Technical Analysis ALN: 81.214, Award #: DE-EM0005173, Award Year: 04/23/2018 – 06/30/2023 Program- U.S. Department of Health and Human Services, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health ALN: 93.421, Award #: Various, Award Year: 08/01/2018 – 07/31/2023 Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR Section 200.305(b)(3), for non-Federal entities funded under the reimbursement method, reimbursement requests should be supported by documentation to verify that the entity paid for the costs for which reimbursement was requested prior to the date of the reimbursement request. Condition – During our cash management testing for major program ALN 81.214, we noted the following: • For three (3) out of four (4) samples selected for testing, NGA Center was unable to provide documentation showing review and approval of the cash drawdown requests. • For one (1) out of four (4) sample selected for testing, NGA Center was unable to provide the supporting calculation of the cash drawdown request. • In addition, expenditures reflected in the cash drawdown requests were not reconciled with the general ledger. For the first three quarters of fiscal year 2022, the compensated absences and fringe benefits were included in the cash drawdown requests, however, NGA Center did not record the transactions in the general ledger during those quarters. Also, certain contractual services recorded in the general ledger during the last quarter of fiscal year 2022 were excluded on the cash drawdown request. During our cash management testing for major program ALN 93.421, we noted the following: • For two (2) out of two (2) samples selected for testing, NGA Center was unable to provide documentation showing review and approval of the cash drawdown requests. • For one (1) out of two (2) samples selected for testing, NGA Center was unable to provide the supporting calculation of the cash drawdown request. • In addition, expenditures reflected in the cash drawdown requests are not reconciled with the general ledger. During the first half of fiscal year 2022, compensated absences and fringe benefits were included in the cash drawdown request, however, NGA Center did not record the transactions in the general ledger during that period. Also, certain contractual services recorded in the general ledger during the last three quarters were excluded on the cash drawdown requests. Questioned Costs – Not determinable. Context – This is a condition identified per review of NGA Center’s compliance with the provisions of the grant agreements and general compliance principles. Cause – NGA Center did not appear to exercise due diligence in requesting Federal funds consistent with the grant agreements and its actual cash needs. Effect – NGA Center is not in compliance with the stated provisions. The opportunity to use the money for other immediate cash needs is unnecessarily delayed when funds are not requested timely. Repeat Finding – This is not a repeat finding. Recommendation - We recommend that NGA Center comply with the provisions of the grant agreements and request Federal funds consistent with the grant agreement funding techniques and clearance patterns for these programs. Views of Responsible Officials – NGA Center agrees with the finding and recommendations of this finding set forth within and has developed a corrective action plan to address the lapse in the prescribed internal controls.
Assistance Listing Number(s): 93.959 Name of Federal Program or Cluster: Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing Number(s): 93.788 Name of Federal Program or Cluster: State Targeted Response to the Opioid Crisis Grants Name of Federal Agency: Department of Health and Human Services Criteria or Specific Requirement: Non-Federal entities must minimize the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-Federal entity for direct program or project costs and the proportionate share of allowable indirect costs (2 CFR section 200.305(b)). Condition and Context: The balance of refundable advances was not reconciled during the fiscal period, which should have informed the process for matching funding with expenses and the calculation of amounts requested to draw for contract expenses. Cause: Routines and habits lapsed during the changes in operations, staffing and management. Changes in key management positions has reduced the institutional knowledge and experience in this area. Effect or Potential Effect: Grant funding for reimbursement of expenses are not supported in the contract period and funds might be required to be returned to grantors. Repeat Finding: No Recommendation: For each contract, ARC must reconcile refundable advances routinely and in coordination with the recognition and allocation of allowable costs and to inform the determination of draw request amounts. While this did not occur during the year ended June 30, 2022, steps have been taken to reconcile all accounts subsequent to the report date. Views of Responsible Officials: A formalized and monitored process was implemented to reconcile refundable advances routinely and in coordination with the recognition and allocation of allowable costs effective August of 2023.
Assistance Listing Number(s): 93.959 Name of Federal Program or Cluster: Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing Number(s): 93.788 Name of Federal Program or Cluster: State Targeted Response to the Opioid Crisis Grants Name of Federal Agency: Department of Health and Human Services Criteria or Specific Requirement: Non-Federal entities must minimize the time elapsing between the transfer of funds from the U.S. Treasury or pass-through entity and disbursement by the non-Federal entity for direct program or project costs and the proportionate share of allowable indirect costs (2 CFR section 200.305(b)). Condition and Context: The balance of refundable advances was not reconciled during the fiscal period, which should have informed the process for matching funding with expenses and the calculation of amounts requested to draw for contract expenses. Cause: Routines and habits lapsed during the changes in operations, staffing and management. Changes in key management positions has reduced the institutional knowledge and experience in this area. Effect or Potential Effect: Grant funding for reimbursement of expenses are not supported in the contract period and funds might be required to be returned to grantors. Repeat Finding: No Recommendation: For each contract, ARC must reconcile refundable advances routinely and in coordination with the recognition and allocation of allowable costs and to inform the determination of draw request amounts. While this did not occur during the year ended June 30, 2022, steps have been taken to reconcile all accounts subsequent to the report date. Views of Responsible Officials: A formalized and monitored process was implemented to reconcile refundable advances routinely and in coordination with the recognition and allocation of allowable costs effective August of 2023.
Assistance Listings number and name: 84.425F COVID-19 Education Stabilization Fund—Institutional Portion Award number and year: P425F200677, May 4, 2020 through June 30, 2023 Federal agency: U.S. Department of Education Compliance requirements: Allowable costs/cost principles and cash management Questioned costs: $10,217,259 Condition—Contrary to federal guidance and regulations and Northern Arizona University’s (University) federal indirect cost agreement, for fiscal years 2020 through 2022, the University incorrectly calculated its federal indirect costs by applying its indirect cost rate to capital expenditures and lost revenues and requested and received reimbursement for direct program expenditures it did not incur. Effect—The University overcharged $10,217,259 of unallowed costs to its HEERF program’s institutional portion for fiscal years 2020 through 2022, resulting in less monies available to spend on allowable program costs for addressing institutional needs, such as defraying costs associated with COVID-19 (including lost revenue and payroll). These unallowed costs included $2,473,496 in indirect costs related to capital expenditures, $7,449,036 in indirect costs related to lost revenues, and $294,727 for direct expenditures it did not incur and that comprised 8.5 percent of the University’s portion of the program’s total federal award expenditures for fiscal years 2020 through 2022. The University returned these unallowed costs to the U.S. Department of Education (ED) on August 18, 2023. Cause—The University did not properly train the individual administering the program or require secondary reviews of indirect-cost calculations and reimbursement requests. Specifically, despite the requirements in its federal indirect cost rate agreement and ED’s guidance, the University’s administration reported that the individual performing the indirect-cost calculation was not properly trained on calculating indirect costs and therefore, did not realize that the indirect cost rate should not have been applied to capital expenditures and lost revenues. Also, the University did not follow written policy and have a second employee who was knowledgeable about the program review and approve the indirect-cost calculation for accuracy. Similarly, a second employee did not review reimbursement requests or reconcile program expenditures to its financial accounting system, and the University’s policy lacked such requirements. Criteria—Federal guidance and regulations require the University to follow its federal indirect cost agreement to apply and calculate indirect costs allocated to federal programs at the specific percentages for specific costs that comprise the program’s base expenditures.1 The University’s federal indirect cost agreement and ED’s guidance does not allow the University to apply an indirect cost rate to its capital expenditures and estimated amount of lost revenue.2 In addition, University policy requires an independent review and approval of all transactions recorded in its accounting system, including indirect-cost calculations, to ensure that they are appropriate, accurate, and comply with applicable laws and regulations (Northern Arizona University Comptroller Manual, CMP 603). Further, federal regulation requires the University to use the reimbursement method to administer the program, whereby the Office is reimbursed with federal program monies only after it spends its own monies for authorized program purposes and requests reimbursement from the federal grantor (2 CFR §200.305[b][3]). Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The University should: 1. Correctly calculate federal indirect costs by: a. Training employees responsible for calculating federal program indirect costs to properly apply the award’s indirect cost rate to only allowable program expenditures as outlined in the indirect cost agreement and grant awards. b. Following written policy for reviewing federal program transactions, including ensuring indirect-cost calculations are properly reviewed and approved. 2. Ensure only federal program costs incurred are requested for reimbursement by improving its written policy to require a second employee to reconcile program expenditures recorded on its financial accounting system to the reimbursement request before approving the request to be submitted to the federal grantor. The University’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 U.S. Department of Education. (2021). Higher Education Emergency Relief Fund III—Frequently Asked Questions, Question 43. Retrieved 5/19/2023 from https://www2.ed.gov/about/offices/list/ope/arpfaq.pdf. U.S. Office of Management and Budget. (2021). Appendix III to 2 CFR Part 200—Indirect (F&A) Costs Identification and Assignment, and Rate Determinations for Institutions of Higher Education. Retrieved 5/19/2023 from https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/appendix-Appendix%20III%20to%20Part%20200. 2 Executive Office of the President, Office of Management and Budget. 2 CFR Part 200, Appendix XI Compliance Supplement, page 4-84.425-ESF-38. (2002). Retrieved 5/19/2023 from https://www.whitehouse.gov/wp-content/uploads/2022/05/2022-Compliance-Supplement_PDF_Rev_05.11.22.pdf.
Assistance Listings number and name: 84.425F COVID-19 Education Stabilization Fund—Institutional Portion Award number and year: P425F200677, May 4, 2020 through June 30, 2023 Federal agency: U.S. Department of Education Compliance requirements: Allowable costs/cost principles and cash management Questioned costs: $10,217,259 Condition—Contrary to federal guidance and regulations and Northern Arizona University’s (University) federal indirect cost agreement, for fiscal years 2020 through 2022, the University incorrectly calculated its federal indirect costs by applying its indirect cost rate to capital expenditures and lost revenues and requested and received reimbursement for direct program expenditures it did not incur. Effect—The University overcharged $10,217,259 of unallowed costs to its HEERF program’s institutional portion for fiscal years 2020 through 2022, resulting in less monies available to spend on allowable program costs for addressing institutional needs, such as defraying costs associated with COVID-19 (including lost revenue and payroll). These unallowed costs included $2,473,496 in indirect costs related to capital expenditures, $7,449,036 in indirect costs related to lost revenues, and $294,727 for direct expenditures it did not incur and that comprised 8.5 percent of the University’s portion of the program’s total federal award expenditures for fiscal years 2020 through 2022. The University returned these unallowed costs to the U.S. Department of Education (ED) on August 18, 2023. Cause—The University did not properly train the individual administering the program or require secondary reviews of indirect-cost calculations and reimbursement requests. Specifically, despite the requirements in its federal indirect cost rate agreement and ED’s guidance, the University’s administration reported that the individual performing the indirect-cost calculation was not properly trained on calculating indirect costs and therefore, did not realize that the indirect cost rate should not have been applied to capital expenditures and lost revenues. Also, the University did not follow written policy and have a second employee who was knowledgeable about the program review and approve the indirect-cost calculation for accuracy. Similarly, a second employee did not review reimbursement requests or reconcile program expenditures to its financial accounting system, and the University’s policy lacked such requirements. Criteria—Federal guidance and regulations require the University to follow its federal indirect cost agreement to apply and calculate indirect costs allocated to federal programs at the specific percentages for specific costs that comprise the program’s base expenditures.1 The University’s federal indirect cost agreement and ED’s guidance does not allow the University to apply an indirect cost rate to its capital expenditures and estimated amount of lost revenue.2 In addition, University policy requires an independent review and approval of all transactions recorded in its accounting system, including indirect-cost calculations, to ensure that they are appropriate, accurate, and comply with applicable laws and regulations (Northern Arizona University Comptroller Manual, CMP 603). Further, federal regulation requires the University to use the reimbursement method to administer the program, whereby the Office is reimbursed with federal program monies only after it spends its own monies for authorized program purposes and requests reimbursement from the federal grantor (2 CFR §200.305[b][3]). Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The University should: 1. Correctly calculate federal indirect costs by: a. Training employees responsible for calculating federal program indirect costs to properly apply the award’s indirect cost rate to only allowable program expenditures as outlined in the indirect cost agreement and grant awards. b. Following written policy for reviewing federal program transactions, including ensuring indirect-cost calculations are properly reviewed and approved. 2. Ensure only federal program costs incurred are requested for reimbursement by improving its written policy to require a second employee to reconcile program expenditures recorded on its financial accounting system to the reimbursement request before approving the request to be submitted to the federal grantor. The University’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 U.S. Department of Education. (2021). Higher Education Emergency Relief Fund III—Frequently Asked Questions, Question 43. Retrieved 5/19/2023 from https://www2.ed.gov/about/offices/list/ope/arpfaq.pdf. U.S. Office of Management and Budget. (2021). Appendix III to 2 CFR Part 200—Indirect (F&A) Costs Identification and Assignment, and Rate Determinations for Institutions of Higher Education. Retrieved 5/19/2023 from https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/appendix-Appendix%20III%20to%20Part%20200. 2 Executive Office of the President, Office of Management and Budget. 2 CFR Part 200, Appendix XI Compliance Supplement, page 4-84.425-ESF-38. (2002). Retrieved 5/19/2023 from https://www.whitehouse.gov/wp-content/uploads/2022/05/2022-Compliance-Supplement_PDF_Rev_05.11.22.pdf.
Assistance Listings number and name: 84.425F COVID-19 Education Stabilization Fund—Institutional Portion Award number and year: P425F200677, May 4, 2020 through June 30, 2023 Federal agency: U.S. Department of Education Compliance requirements: Allowable costs/cost principles and cash management Questioned costs: $10,217,259 Condition—Contrary to federal guidance and regulations and Northern Arizona University’s (University) federal indirect cost agreement, for fiscal years 2020 through 2022, the University incorrectly calculated its federal indirect costs by applying its indirect cost rate to capital expenditures and lost revenues and requested and received reimbursement for direct program expenditures it did not incur. Effect—The University overcharged $10,217,259 of unallowed costs to its HEERF program’s institutional portion for fiscal years 2020 through 2022, resulting in less monies available to spend on allowable program costs for addressing institutional needs, such as defraying costs associated with COVID-19 (including lost revenue and payroll). These unallowed costs included $2,473,496 in indirect costs related to capital expenditures, $7,449,036 in indirect costs related to lost revenues, and $294,727 for direct expenditures it did not incur and that comprised 8.5 percent of the University’s portion of the program’s total federal award expenditures for fiscal years 2020 through 2022. The University returned these unallowed costs to the U.S. Department of Education (ED) on August 18, 2023. Cause—The University did not properly train the individual administering the program or require secondary reviews of indirect-cost calculations and reimbursement requests. Specifically, despite the requirements in its federal indirect cost rate agreement and ED’s guidance, the University’s administration reported that the individual performing the indirect-cost calculation was not properly trained on calculating indirect costs and therefore, did not realize that the indirect cost rate should not have been applied to capital expenditures and lost revenues. Also, the University did not follow written policy and have a second employee who was knowledgeable about the program review and approve the indirect-cost calculation for accuracy. Similarly, a second employee did not review reimbursement requests or reconcile program expenditures to its financial accounting system, and the University’s policy lacked such requirements. Criteria—Federal guidance and regulations require the University to follow its federal indirect cost agreement to apply and calculate indirect costs allocated to federal programs at the specific percentages for specific costs that comprise the program’s base expenditures.1 The University’s federal indirect cost agreement and ED’s guidance does not allow the University to apply an indirect cost rate to its capital expenditures and estimated amount of lost revenue.2 In addition, University policy requires an independent review and approval of all transactions recorded in its accounting system, including indirect-cost calculations, to ensure that they are appropriate, accurate, and comply with applicable laws and regulations (Northern Arizona University Comptroller Manual, CMP 603). Further, federal regulation requires the University to use the reimbursement method to administer the program, whereby the Office is reimbursed with federal program monies only after it spends its own monies for authorized program purposes and requests reimbursement from the federal grantor (2 CFR §200.305[b][3]). Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The University should: 1. Correctly calculate federal indirect costs by: a. Training employees responsible for calculating federal program indirect costs to properly apply the award’s indirect cost rate to only allowable program expenditures as outlined in the indirect cost agreement and grant awards. b. Following written policy for reviewing federal program transactions, including ensuring indirect-cost calculations are properly reviewed and approved. 2. Ensure only federal program costs incurred are requested for reimbursement by improving its written policy to require a second employee to reconcile program expenditures recorded on its financial accounting system to the reimbursement request before approving the request to be submitted to the federal grantor. The University’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 U.S. Department of Education. (2021). Higher Education Emergency Relief Fund III—Frequently Asked Questions, Question 43. Retrieved 5/19/2023 from https://www2.ed.gov/about/offices/list/ope/arpfaq.pdf. U.S. Office of Management and Budget. (2021). Appendix III to 2 CFR Part 200—Indirect (F&A) Costs Identification and Assignment, and Rate Determinations for Institutions of Higher Education. Retrieved 5/19/2023 from https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/appendix-Appendix%20III%20to%20Part%20200. 2 Executive Office of the President, Office of Management and Budget. 2 CFR Part 200, Appendix XI Compliance Supplement, page 4-84.425-ESF-38. (2002). Retrieved 5/19/2023 from https://www.whitehouse.gov/wp-content/uploads/2022/05/2022-Compliance-Supplement_PDF_Rev_05.11.22.pdf.
Description: Cash Management for Subrecipient Expenditures Repeat Finding: No Type of Finding: Material weakness in internal controls and material non-compliance with the cash management compliance requirement Questioned Costs: None Major Program: AL # 64.033, VA Supportive Services for Veteran Families Program, #20-OR-430 and #20-OR-430-C3. Condition: During the year ended June 30, 2022, the Organization regularly drew down cash from the Payment Management System (PMS) for subrecipient expenditures but did not remit the related payments to the subrecipients in a timely manner. Review of supporting documentation submitted by subrecipients for their expenditures did not occur prior to drawing down the cash from PMS for the related expenditures. Criteria: Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity (2 CFR section 200.305(b)). Cause: The Organization did not ensure its service provider was properly managing subrecipient cash requests and disbursements throughout the year and was not consistently reviewing subrecipient expenditure requests in a timely manner. Effect: As a result of the matter identified in the condition paragraph, a material weakness in the Organization’s internal controls over compliance and a material non-compliance exist for the cash management compliance requirement. Recommendation: We recommend the Organization implements procedures to ensure it is properly managing the timing of subrecipient cash requests and disbursements to comply with the cash management requirement. View of responsible officials: Management agrees with the assessment and has committed to a corrective action plan.
State Agency: Illinois Department of Revenue (IDOR) Federal Agency: U.S. Department of Treasury (Treasury) Program Name: COVID-19 – Homeowner Assistance Fund ALN and Program Expenditures: 21.026 ($209,795,189) Award Numbers: Various – See schedule of award numbers Federal Award Year: Various – See schedule of award numbers Questioned Costs: None Compliance Requirement: Cash Management Finding 2022-003: Failure to Monitor Subrecipient Cash Draws Type of Finding: Adverse opinion and material weaknessCondition Found: IDOR passed through most of the advance drawn funds to its subrecipient while reporting no activity had occurred for the COVID–19 – Homeowner Assistance Fund (HAF) program in the special report prepared during fiscal year 2022. The State designated IDOR as the State agency responsible for fiscal activities of the COVID-19 – HAF program. IDOR passed funding through to the Illinois Housing Development Authority (IHDA) (a component unit of the State) who works directly with program beneficiaries (eligible homeowners or subrecipients). During our audit procedures, we noted the State received $211,309,688 of COVID-19 – HAF program funding from the U.S. Treasury in January 2022. At the time of the January 2022 cash receipt, we noted IDOR had passed through $32,886,765 to IHDA. During our review of subrecipient payments (totaling $209,795,189) made to IHDA during the year ended June 30, 2022, we noted IHDA had only reported expenditures of $6,901,019 during the year ended June 30, 2022. Accordingly, IDOR had provided HAF program advances totaling $202,894,170 during the year ended June 30, 2022. IDOR did not have procedures in place to monitor whether IHDA had incurred or would be incurring program expenditures to minimize federal cash on hand. Additionally, the State prepared and submitted a one-time special report (Interim Report 1505-0269) that covered the reporting period beginning on the date of the COVID-19 – HAF program award (May 3, 2021) through January 31, 2022. The key line items in the special report included the following: • Number of unique Homeowners that received HAF assistance and subset(s) that are classified as Socially Disadvantaged and 100 percent Area Median Income (AMI) or less • Homeowners that received HAF assistance disaggregated by Program Design Element • Amount of assistance provided to Homeowners disaggregated by Program Design Element During our testing of the COVID-19 – HAF program special report, we noted the State did not report activity data for any of the key line items. Total subrecipient expenditures for the HAF program administered by the State were $209,795,189 during the year end June 30, 2022.Criteria or Requirement: Pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized as required by the applicable cash management requirements in the federal award to the recipient (2 CFR section 200.305(b)(1)). In addition, 2 CFR 200.303 requires non-federal entities receiving Federal awards to establish and maintain internal control designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include establishing procedures to minimize the time elapsing between the transfer of funds to subrecipients and the subrecipient’s actual cash outlay for program costs. Cause: The State’s relationship with IHDA is a multi-agency initiative. IDOR’s role has historically been statutorily limited to funding agent. This role does not include expenditure monitoring or reporting responsibilities. There was confusion in fiscal year 2022 regarding which state agency would perform these tasks for the COVID grant money awarded to IHDA. Possible Asserted Effect: Failure to monitor whether subrecipients minimize the time between the receipt of federal funds and expenditure for program purposes may result in advance funding in excess of immediate cash needs. Additionally, failure to properly report program activities in required special reports inhibits the U.S. Treasury from properly monitoring program activities and progress. Repeat Finding: A similar finding was not reported in a prior year audit. (Finding Code No. 2022-003) Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend IDOR implement procedures to monitor subrecipients to ensure funds are requested only for expenditures which have been incurred or will be incurred within a reasonable time period to minimize federal cash on hand. Additionally, the State should implement procedures to ensure the COVID-19 – HAF program special report completely and accurately describes required program activities. Views of IDOR Officials: The IHDA Act was updated to allow IDOR to disburse COVID money. However, the language for the tasks to be performed by the funding agent was left unchanged. This ambiguity along with the reporting IHDA does to other agencies contributed to confusion regarding which agency was responsible for the grant expenditure monitoring and reporting. IDOR pursued legislative clarification. This resulted in the decision to transition the funding agent role to DHS.
Condition: The Center?s written policies and procedures related to financial management do not meet the requirements of 2 CFR 200, Subpart D and Subpart E. Criteria: According to 2 CFR Section 200.302.b and 2 CFR Section 200.305 of the Uniform Guidance, the Center is required to have a written financial management policy. Cause: The Center was unaware of requirements regarding policies and procedures outlined in the Uniform Guidance. Effect: Written policies necessary for non-Federal entities receiving federal funds were not in place. Repeat Finding: No Questioned Costs: None reported Recommendation: We recommend that the Center update their written policies and procedures that meet the requirements of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Views of Responsible Officials and Planned Corrective Action: We concur with the auditor?s finding and will update the Center?s written policies and procedures for the Uniform Guidance requirements.
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.