Finding Text
2023-002 Internal Control over Compliance and Compliance with Cash Management
Information on the Federal Program(s):
United States Agency for International Development
Assistance Listing Number: 98.001
Assistance Listing Name: USAID Foreign Assistance for Programs Overseas
Pass-through Award(s):
Pass-through Entity Pass-through Award Number
Award Period
The American Bar Association 72068520LA0001 September 10, 2020 through March 31, 2023
FHI 360 PO22001322 March 15, 2022 through February 29, 2024
Education Development
Center, Inc. 72066822CA00002 October 1, 2022 through June 30, 2026
Freedom House 7200-AA-19-LA-00005 October 1, 2019 through April 30, 2023
Freedom House
720-68520-LA-00002
September 15, 2020 through
September 14, 2024
Freedom House 21-H4A004-01 April 1, 2021 through September 30, 2025
Freedom House 7200-AA-21-LA-00004 September 25, 2022 through August 31, 2023
Freedom House 7200-AA-21-LA-00004 July 6, 2023 through August 31, 2024
Freedom House
7200-AA-21-LA-00004
September 1, 2023 through
December 31, 2023
Management Systems International, Inc. 6122.01.18.005 July 24, 2018 through May 23, 2023
United States Department of Homeland Security
Assistance Listing Number: 97.132
Assistance Listing Name: Financial Assistance for Targeted Violence and Terrorism Prevention
Award Number:
Direct Award Number Award Period
EMW-2021-GR-00047-S01 October 1, 2021 through December 31, 2023
United States Department of State
Assistance Listing Number: 19.517
Assistance Listing Name: Overseas Refugee Assistance Programs for Africa
Pass-through Award(s):
Pass-through Entity Pass-through Award Number
Award Period
World Vision SPRMCO23CA0146-SFCG August 1, 2023 through July 30, 2024
World Vision SPRMCO22CA0158-SFCG August 1, 2022 through July 31, 2023
Criteria: In accordance with §200.305(b)(8), Federal Payment, advance payments must be deposited in interest bearing accounts unless one of the four exceptions apply. In accordance with §200.305(b)(9), Federal Payment, interest earned on amounts up to $500 per year may be retained by the non-Federal entity for administrative purposes. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS).
Condition: We noted the Organization does not maintain advance payments on Federal awards in interest-bearing accounts. The Organization has since prepared an estimated calculation of interest it would have earned if the advance payments were deposited in interest-bearing accounts. As the Organization estimated it could have earned approximately $22,186 of interest during the year ended December 31, 2023 on cash advances, the Organization estimates they owes the United States Government $21,686 of interest.
Questioned Costs: None.
Context: The nature of these findings is detailed in the condition section above.
Cause: The Organization’s internal controls established to ensure compliance with cash management regulations did not operate as designed to ensure controls address the regulation to calculate the interest earned on cash advances to remit to the U.S. Government at the end of the year.
Effect: Failure to have adequate controls in place to ensure cash advances are in interest-bearing accounts and processes to calculate the amount of interest earn resulted in the Organization not returning funding to the U.S. Government, as required.
Repeat Finding: This finding is not a repeat finding from prior year.
Recommendation: We recommend management ensure the compliance cash management policies that align to U.S. Government funding requirements related to interest on cash advances.
Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.