Finding Text
2024-008 Cash Management
Program Information
Federal Organization U.S Department of Health and Human Services
Assistance Listing
Numbers
93.224 & 93.527 Health Center Program Cluster
Award Numbers H80CS00513, H8FCS41684, H8GC48547, H8LCS51197
Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness
Title 2 CFR 200.305 requires that organizations “must minimize the time elapsing
between the transfer of funds from the United States Treasury or the pass-through
entity and the disbursement by the non-federal entity whether the payment is made by
electronic funds transfer, or issuance or redemption of checks, warrants, or payment
by other means.”
Condition Cash draws were made without support of approved documentation. Supporting
documentation for other draws included invoices for expenditures that were dated
several months after the draw was made.
This finding appears to be a systemic problem
Cause The Organization’s internal controls over cash management and PMS draws does not
include procedures for non-payroll expenditures. As a result, draws were made
without supporting documentation. In addition, the Organization did not always
maintain documentation of the payroll calculations supporting draws, as required by
company policy.
Effect The Organization may not have minimized the timing between draws from the PMS
and the related payments for expenditures incurred as required.
Questioned Costs Indeterminable.
Context Out of thirteen draws tested, the Organization was not able to provide supporting
documentation for one draw and support for two additional draws included expenses
that were not incurred within a reasonable time after the draw.
Recommendation We recommend the Organization implement controls requiring all draws from the
Payment Management System (PMS) to be based on detailed reports of expenditures
claimed for reimbursement and retain this documentation along with the supporting
invoices and payroll reports supporting the expenditures. In addition, we recommend
that the listing of expenditures be reviewed by qualified personnel to ensure that the
expenditures claimed are allowable and cash payments for the expenditures are made
before the date of the draw or within a reasonable time after the draw.
Views of responsible
officials and planned
corrective action
Management is in agreement with this finding and will take corrective action as
outlined below.