Finding Text
Finding No.: 2023-002 Federal Agency: U.S. Department of Commerce AL Program: 11.482 Coral Reef Preservation Program Federal Award Nos.: NA20NOS4820198 Area: Cash Management Questioned Costs: $248,189 Criteria: 2 CFR 200.305(b) requires payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient. Advance payments to a recipient or subrecipient must be limited to the minimum amounts needed and be timed with actual, immediate cash requirements of the recipient or subrecipient in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the recipient or subrecipient for direct program or project costs and the proportionate share of any allowable indirect costs. The recipient or subrecipient must make timely payments to contractors in accordance with the contract provisions. 2 CFR 200.305(b)(1) requires that the recipient or subrecipient must maintain or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the recipient or subrecipient. Condition: Of thirteen (13) cash drawdowns totaling $759,083, eight (8) cash drawdowns totaling $592,568 were tested. For one (1) sample or (or 13% of drawdowns tested), the Trust did not demonstrate implementation of procedures to minimize the time elapsing between the transfer of funds from the federal agencies and disbursement of funds for program purposes Cause: The Trust does not maintain written procedures to ensure that time elapsing between the transfer of funds from the U.S. federal agency or pass-through entity and the disbursements of funds is minimized. Effect: The Trust is in noncompliance with applicable cash management requirements which resulted in questioned costs of $248,189. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: The Trust should establish written procedures to minimize the number of days elapsing between transfer of funds from U.S. federal agency or pass-through entity and disbursements of funds. Views of Responsible Officials: Management agrees with the finding. See separate Corrective Action Plan