Finding 1086215 (2023-006)

Significant Deficiency
Requirement
C
Questioned Costs
-
Year
2023
Accepted
2024-11-22
Audit: 329488
Organization: People Trust (AR)

AI Summary

  • Core Issue: Management failed to keep advanced federal funds in an interest-bearing account as required by federal guidelines.
  • Impacted Requirements: Non-compliance with 2 CFR Part-200, Subpart-D-200.305(b)(11) regarding cash management for federal awards.
  • Recommended Follow-Up: Establish procedures to ensure federal advances are placed in interest-bearing accounts and track any interest earned, with oversight from knowledgeable personnel.

Finding Text

Federal Agency: U.S. Department of Treasury Federal Program: CDFI Equitable Recovery Program (ERP) Assistance Listing Numbers: 21.033 Federal Award Identification Number and Year: 22ERP061482 – 2023 Award Period: January 1, 2023 – December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Compliance - Other Matter Criteria or Specific Requirement: Under 2 CFR Part-200, Subpart-D-200.305(b)(11), the non-Federal entity must maintain advance payments of Federal awards in interest-bearing accounts, unless the following apply: (i) The non-Federal entity receives less than $250,000 in Federal awards per year. (ii) The best reasonably available interest-bearing account would not be expected to earn interest in excess of $500 per year on Federal cash balances. (iii) The depository would require an average or minimum balance so high that it would not be feasible within the expected Federal and non-Federal cash resources. (iv) A foreign government or banking system prohibits or precludes interest-bearing accounts. Condition: Management did not maintain its advanced payment in an interest-bearing account nor met the exceptions criteria outlined above. Questioned Costs: None Context: The Organization received $3 million of advanced funds in 2023 and utilized approximately $1.8 million in the same year. As a result, the Organization should have placed the remaining portion of the advanced payment into an interest-bearing account and track the interest earned on the account. Additionally, any interest earned in excess of $500 should then be reported and remitted back to the federal agency in accordance with program requirements. Cause: Management was not aware of the uniform guidance requirements around cash management, specifically related to maintaining advanced federal funds in interest-bearing accounts. Effect: Cash management procedures were not properly followed in accordance with the uniform guidance and program requirements. Repeat Finding: No Recommendation: Management should develop a procedure to track its federal award advances to ensure those funds are placed in interest-bearing accounts, when applicable, and any interest earnings on those funds are separately tracked, reported and remitted in accordance with the program requirements. A documented review of this activity should be performed by a knowledge individual who is aware of the program requirements prior to reporting or remitting payment back to the federal agency. Views of Responsible Officials: There is no disagreement with the audit finding.

Categories

Cash Management

Other Findings in this Audit

  • 509771 2023-004
    Material Weakness
  • 509772 2023-005
    Significant Deficiency
  • 509773 2023-006
    Significant Deficiency
  • 1086213 2023-004
    Material Weakness
  • 1086214 2023-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.033 Cdfi Equitable Recovery Plan (erp) $1.81M
21.020 Community Development Financial Institutions Program $325,000
14.231 Emergency Solutions Grant Program $110,146
14.267 Continuum of Care Program $72,256