Finding Text
Finding: Improper cash draws- expenses drawn without regard to expenses incurred. Criteria: Cash Management Per the Office of Management and Budget Compliance Supplement (2 CFR Part 200, Appendix XI), cash management is a relevant compliance requirement for the Unaccompanied Children Program cluster. Per the Notice of Award for all three Unaccompanied Children Funds may be drawn either as a reimbursement, or to accommodate your immediate cash needs. Funds drawn from PMS must not be held in excess of three (3) working days. Drawdown payment requests from PMS must be made consistent with 45 CFR 75.305 – Payment: “(b) …For non-Federal entities other than states, payments 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 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, Context, and Cause: As discussed above, the Organization was making cash draws from the PMS system without regard to timing of actual allowable expenditures. During our audit, we noted several instances of cash draws in excess of identified expenditures for the period. Result: Amounts identified as unallowable costs per the compliance guidance have been included in the contract liability as disclosed in Note 12. See the Summary of Unallowable Costs and Questioned Costs tables for detail on page 56. Recommendation: The auditors recommend the Organization re-implement internal controls to track allowable expenditures and reconcile qualifying costs with cash draws.