Finding 1204664 (2025-001)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2025
Accepted
2026-03-30
Audit: 396440
Organization: Neomed Center, Inc. (PR)

AI Summary

  • Core Issue: NeoMed Center drew advance payments exceeding immediate cash needs, risking noncompliance with federal cash management rules.
  • Impacted Requirements: Advance payments must align with immediate cash needs and allowable costs within the approved performance period.
  • Recommended Follow-Up: Strengthen internal controls, revise policies for cash management, and train staff on compliance with federal requirements.

Finding Text

Criteria: The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) allow non-Federal entities to request advance payments, provided that the timing and amount of such advances are limited to the entity’s immediate cash needs and that funds are expended only for allowable costs incurred within the approved period of performance. Under cash management requirements, advance payments must be limited to the minimum amounts needed and timed to align with the actual, immediate cash requirements of the non-Federal entity (2 CFR §200.305(b)(1); 2025 OMB Compliance Supplement, Cash Management). Additionally, regarding the period of performance, federal awards may only be charged for obligations incurred during the approved period of performance stated in the Notice of Award, and costs incurred outside that period are considered unallowable unless specifically authorized by the federal awarding agency (2 CFR §200.309; 2025 OMB Compliance Supplement, Period of Performance). Condition: During the fiscal year ended June 30, 2025, NeoMed Center requested and received advance payments through the Payment Management System (PMS) under the Health Center Program (93.224). The advances included funds related to a grant budget period running from May 2025 through April 2026; however, management intended to use a portion of these funds to support operations in the subsequent fiscal year (July 1, 2025 through June 30, 2026). As of June 30, 2025, a portion of the advanced federal funds had not been expended for allowable costs incurred within the applicable period of performance. While advance payments are permitted under federal regulations, the timing of the drawdowns exceeded NeoMed Center Inc.’s immediate cash needs for allowable expenditures incurred during the approved period of performance. Effect: As a result of this condition, federal funds were drawn earlier than necessary relative to allowable expenditures as of and for the yar ended June 30, 2025 and were held to be expended and recorded as revenues in the next fiscal year ending June 30, 2026. This situation exposed NMCI to an increased risk of noncompliance with federal cash management and allowability requirements. Additionally, cash balances as of June 30, 2025, included federal funds that were not eligible to be recognized as expenditures as of that date. Cause: Management stated that the advance payments were requested as a preventive measure in response to uncertainty related to federal funding disruptions during calendar year 2025. However, lack of internal controls to ensure that advance drawdowns were limited only to immediate cash needs and aligned with the applicable grant period of performance permitted excess drawdown with no support. Recommendations: We recommend that the Institution implement the following corrective actions: 1. Strengthen internal controls over federal cash management and grant expenditure monitoring to ensure compliance with Uniform Guidance requirements. 2. Revise policies and procedures manuals and Implement procedures to ensure that advance drawdowns from the Payment Management System (PMS) are limited to the entity’s immediate cash needs. 3. Ensure that federal funds are drawn only for allowable expenditures expected to be incurred within the approved period of performance. 4. Provide training to relevant personnel on federal cash management requirements and the proper administration of advance payments.

Corrective Action Plan

Condition: During the fiscal year ended June 30, 2025, NeoMed Center, Inc. used the advance payment method through the HHS Payment Management System (PMS) to obtain federal funds. In certain instances, drawdowns were requested based on aggregated projections and liquidity needs before specific eligible expenses were fully identified and ready for immediate disbursement. Although the funds were later applied to eligible expenses incurred within the authorized award periods, the absence of a documented, expense-level linkage at the time of each drawdown created a temporary timing difference between cash receipt and expense recognition. Accordingly, funds that did not meet revenue recognition criteria at the end were recorded as Unearned Revenue. Consistent with U.S. GAAP and federal grant revenue recognition policies, the Unearned Revenue balance of approximately $1.8 million as of June 30, 2025, represents federal funds received in advance, for which revenue recognition was contingent on incurring future eligible expenses. This balance was analyzed, reconciled, and recognized as eligible expenses were incurred, as supported by reconciliations provided to the external auditors, and was appropriately disclosed in the notes to the financial statements for the years ended June 30, 2025, and 2024. Planned Corrective Action: To prevent recurrence, NeoMed Center, Inc. adopted and implemented “Federal Fund Drawdown via HHS Payment Management System (PMS)” (Policy No. NMCIP 46), approved by the Board of Directors and effective March 2026. The policy requires drawdowns to be based solely on immediate cash needs, supported by a documented short-term cash forecast, and prohibits requesting funds for expenses not yet incurred or not ready for immediate disbursement. Key internal controls include: • Mandatory preparation of a cash forecast by award prior to each drawdown. • Independent review and approval by the Finance Department prior to submission of drawdown requests in PMS. • Monthly reconciliations between PMS, bank accounts, and the general ledger. • Monitoring of the time elapsed between the receipt of funds and their disbursement, with a maximum internal standard of three (3) business days. • Documentation and formal approval of any exceptions. • Adoption of an internal benchmark of 8.33% per month (1/12 of the annual award) as a control parameter. • Clear definition of segregation of duties; and • Periodic reporting to Senior Management and the CEO. Management concludes that this matter resulted from cash-management timing and not from misuse of federal funds. Monitoring: Management will perform monthly monitoring of federal fund drawdowns beginning April 1st ,2026 to ensure they are limited to immediate cash needs and supported by documented short‑term cash forecasts. Drawdowns will be reconciled monthly to the general ledger, bank statements, and allowable expenditures incurred within the approved period of performance. Any timing variances or exceptions will be reviewed and documented. Monitoring results will be reviewed by senior management to ensure continued compliance with Uniform Guidance requirements. Responsible Official: Jose A. Guzman Machuca Time frame: This condition was identified on February 20, 2026, and is expected to be resolved by May 2026, upon the implementation of formal monitoring procedures and enhanced remittance controls.

Categories

Allowable Costs / Cost Principles Cash Management

Other Findings in this Audit

  • 1204665 2025-002
    Material Weakness Repeat
  • 1204666 2025-002
    Material Weakness Repeat
  • 1204667 2025-003
    Material Weakness Repeat
  • 1204668 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 HEALTH CENTER PROGRAM $6.96M
93.918 GRANTS TO PROVIDE OUTPATIENT EARLY INTERVENTION SERVICES WITH RESPECT TO HIV DISEASE $604,244
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $210,061