Finding 1174868 (2024-001)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2024
Accepted
2026-02-22

AI Summary

  • Core Issue: ICMEC drew down $233,494 in Federal funds too early, using them for other programs instead of immediate needs.
  • Impacted Requirements: This violates 2 CFR 200.305, which requires funds to be drawn only as needed and disbursed within three business days.
  • Recommended Follow-Up: ICMEC should create procedures to align drawdown requests with actual cash needs and ensure timely disbursement of Federal funds.

Finding Text

Section III - Federal Award Findings and Questioned Costs (2 CFR 200.516(a)) Finding 2024-001: Cash Management (Material Weakness) Federal Programs: ALN 19.019 Criteria: According to 2 CFR 200.305, recipients must draw Federal funds only in amounts necessary to meet immediate cash needs for program expenditures. Funds should be disbursed as soon as possible, generally within three business days of receipt. Condition: During our testing of cash management compliance, we noted that ICMEC drew down a total of $233,494 on Federal funds in advance of need. The remaining funds were used for other ICMEC programmatic work. Cause: ICMEC did not have adequate procedures to align Federal drawdown requests with immediate program disbursement requirements. Drawdowns were based on budgeted monthly cash needs rather than actual expenditures. Effect or Potential Effect: Drawing funds in advance of need results in excess Federal cash being held by ICMEC, which is not permitted under Federal regulations. This increases the risk of misuse of Federal funds and may result in ICMEC owing interest to the Federal Government. Questioned Costs: $233,494 Context: Our audit procedures consisted of testwork completed on individual cash receipts and draw downs requests and evaluating the refundable advance analysis prepared by ICMEC as of December 31, 2024. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend ICMEC establish and implement procedures to ensure drawdown requests are limited to actual, immediate cash needs, with monitoring to confirm that Federal funds are disbursed within three business days of receipt.

Corrective Action Plan

View of Responsible Officials: ICMEC discovered an error during FY2024 that resulted in overdraws for their Federal awards as well as drawing expenses from one award that should have been drawn under a different award. After meeting with the funder, ICMEC began to reduce its draws to reduce the overdraw balance. Additionally, ICMEC has received a modification and extension to one of its grants that allows for retroactive indirect and salary costs. As of 8/31/25, the net balance of all JTIP grants combined is close to zero. We are working to correct the individual balances.

Categories

Cash Management

Other Findings in this Audit

  • 1174869 2024-002
    Material Weakness Repeat
  • 1174870 2024-003
    Material Weakness Repeat
  • 1174871 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
19.019 INTERNATIONAL PROGRAMS TO COMBAT HUMAN TRAFFICKING $904,896
19.023 OVERSEAS SCHOOLS PROGRAM $147,123