Finding 1166676 (2025-001)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2025
Accepted
2025-12-28

AI Summary

  • Core Issue: Delays in payments to subrecipients exceeded the 30-day requirement after billing, indicating a significant deficiency in compliance.
  • Impacted Requirements: Violations of 2 CFR 200.305 regarding timely disbursement of federal funds to nonfederal entities.
  • Recommended Follow-up: Review and improve procedures to ensure compliance with federal payment timelines; consider requesting advances from the State to facilitate timely reimbursements.

Finding Text

Assistance Listing, Federal Agency, and Program Name - 93.566, U.S. Department of Health and Human Services, Refugee and Entrant Assistance State/Replacement Designee Administered Programs Federal Award Identification Number and Year- FCSAK00843 2025 Pass- through Entity - Illinois Department of Human Services Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - Yes 2024-001 Criteria - In accordance with 2 CFR 200.305 2(b), for nonfederal entities other than states, payment methods 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 nonfederal entity whether the payment is made by electronic funds transfers or issuance or redemption of checks, warrants, or payments by other means. In accordance with 2 CFR 200.305(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 billing unless the request is believed to be improper. Condition - Controls in place did not minimize the time elapsing between the transfer receipt of billing from the subrecipient and disbursement of federal dollars to the subrecipient in accordance with the guidance above. Questioned Costs - None. If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - Not applicable as there are no questioned costs. Identification of How Questioned Costs Were Computed - Not applicable as there are no questioned costs. Context - Of the three transactions tested, two of the subrecipients were not paid within 30 days of receipt of billing. Cause and Effect - Policies, procedures, and related internal controls did not ensure compliance with federal payment requirements under Uniform Guidance. Recommendation - We recommend the Federation review its procedures and controls to ensure disbursement of funds to its subrecipients is consistent with applicable laws and regulations. Views of Responsible Officials and Corrective Action Plan - As a pass-through recipient, the Federation relies on the timeliness of the State for reimbursement. In all transactions tested, the Federation reimbursed the subrecipients within 30 days of receipt of funds from the State. As a pass-through entity, the Federation understands the requirement to reimburse subrecipients within 30 calendar days after receipt of a billing. However, Federation does not have the financial means to advance cash to subrecipients before funds are collected from the State. Therefore, Federation has requested an advance from the State of Illinois in order to comply with the 30 day requirement.

Corrective Action Plan

Condition: Controls in place did not minimize the time elapsing between the transfer receipt of billing from the subrecipient and disbursement of federal dollars to the subrecipient in accordance with the guidance above. Planned Corrective Action: Federation typically receives vouchers from 15 subrecipient organizations approximately ten to fifteen days after the end of each month. The number of vouchers per agency depends on the number of programs they provide. Staff reviews the vouchers for allowability and accuracy and submits them to the Illinois Department of Human Services (IDHS) within 24 days of month end. During fiscal year 2025, the IDHS remitted payment to Federation anywhere from 20 to 82 days after the month end. Upon receipt of the cash, Federation typically pays subrecipient organizations within two to three business days. In the instances identified by the auditors, the IDHS remitted payment over 30 days after Federation submitted the vouchers for reimbursement. Federation’s longstanding policy has always been to reimburse each subrecipient agency after it has received payment from the IDHS. Prior to fiscal year 2024, the IDHS usually provided payment within 15 days of receipt of our voucher and therefore Federation was able to comply with the 30-day requirement. However, reimbursement delays from IDHS began to occur in fiscal year 2024 and continued throughout fiscal year 2025, resulting in the findings describe herein. IDHS made two advance payments to Federation during fiscal 2025, but the amounts provided were not adequate to fund all payments within the 30 day time period. To ensure compliance with the 30-day reimbursement requirement, Federation will again request advances from the IDHS. Kyu Kim, Director of Finance and Contract Compliance, Refugee Services will be responsible for the oversight of the reimbursement payments. Contact person responsible for corrective action: Kyu Kim Anticipated Completion Date: July 2026

Categories

Subrecipient Monitoring Cash Management Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS $919,478
97.008 NON-PROFIT SECURITY PROGRAM $144,768