Finding 1215017 (2024-007)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2024
Accepted
2026-05-19

AI Summary

  • Core Issue: Cash draws were made without considering actual expenses incurred, leading to improper fund management.
  • Impacted Requirements: This violates cash management guidelines set by the Office of Management and Budget and 45 CFR 75.305.
  • Recommended Follow-Up: Re-establish internal controls to ensure tracking of allowable expenditures and reconcile them with cash draws.

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.

Corrective Action Plan

Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of these asserted findings in conjunction with Findings 2024-005 and 006 to ensure any perceived deficiencies are addressed to the satisfaction of Cayuga Centers’ primary federal funder. With respect to the drawdown process generally, Cayuga Centers has established a review protocol requiring that draws include only qualified expenditures incurred or expected within three business days. All draw requests require dual approval from both finance and program staff. A centralized draw request log is being maintained, including supporting documentation and reconciliation records. With respect to Finding 2024-008, Cayuga Centers does not entirely agree with the auditors’ assertion that accrued vacation expense was improperly included in draw requests. Under certain circumstances, costs of paid time off may be treated as incurred based on PTO earned, rather than PTO-paid. See 2 C.F.R. § 200.431(b). Cayuga Centers will further evaluate this asserted finding with the grants management advisors described above. To the extent there may be any compliance discrepancy, Cayuga Centers will take further appropriate action.

Categories

Cash Management Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1214969 2024-003
    Material Weakness Repeat
  • 1214970 2024-004
    Material Weakness Repeat
  • 1214971 2024-005
    Material Weakness Repeat
  • 1214972 2024-006
    Material Weakness Repeat
  • 1214973 2024-007
    Material Weakness Repeat
  • 1214974 2024-008
    Material Weakness Repeat
  • 1214975 2024-009
    Material Weakness Repeat
  • 1214976 2024-010
    Material Weakness Repeat
  • 1214977 2024-011
    Material Weakness Repeat
  • 1214978 2024-012
    Material Weakness Repeat
  • 1214979 2024-013
    Material Weakness Repeat
  • 1214980 2024-003
    Material Weakness Repeat
  • 1214981 2024-004
    Material Weakness Repeat
  • 1214982 2024-005
    Material Weakness Repeat
  • 1214983 2024-006
    Material Weakness Repeat
  • 1214984 2024-007
    Material Weakness Repeat
  • 1214985 2024-008
    Material Weakness Repeat
  • 1214986 2024-009
    Material Weakness Repeat
  • 1214987 2024-010
    Material Weakness Repeat
  • 1214988 2024-011
    Material Weakness Repeat
  • 1214989 2024-012
    Material Weakness Repeat
  • 1214990 2024-013
    Material Weakness Repeat
  • 1214991 2024-003
    Material Weakness Repeat
  • 1214992 2024-004
    Material Weakness Repeat
  • 1214993 2024-005
    Material Weakness Repeat
  • 1214994 2024-006
    Material Weakness Repeat
  • 1214995 2024-007
    Material Weakness Repeat
  • 1214996 2024-008
    Material Weakness Repeat
  • 1214997 2024-009
    Material Weakness Repeat
  • 1214998 2024-010
    Material Weakness Repeat
  • 1214999 2024-011
    Material Weakness Repeat
  • 1215000 2024-012
    Material Weakness Repeat
  • 1215001 2024-013
    Material Weakness Repeat
  • 1215002 2024-003
    Material Weakness Repeat
  • 1215003 2024-004
    Material Weakness Repeat
  • 1215004 2024-005
    Material Weakness Repeat
  • 1215005 2024-006
    Material Weakness Repeat
  • 1215006 2024-007
    Material Weakness Repeat
  • 1215007 2024-008
    Material Weakness Repeat
  • 1215008 2024-009
    Material Weakness Repeat
  • 1215009 2024-010
    Material Weakness Repeat
  • 1215010 2024-011
    Material Weakness Repeat
  • 1215011 2024-012
    Material Weakness Repeat
  • 1215012 2024-013
    Material Weakness Repeat
  • 1215013 2024-003
    Material Weakness Repeat
  • 1215014 2024-004
    Material Weakness Repeat
  • 1215015 2024-005
    Material Weakness Repeat
  • 1215016 2024-006
    Material Weakness Repeat
  • 1215018 2024-008
    Material Weakness Repeat
  • 1215019 2024-009
    Material Weakness Repeat
  • 1215020 2024-010
    Material Weakness Repeat
  • 1215021 2024-011
    Material Weakness Repeat
  • 1215022 2024-012
    Material Weakness Repeat
  • 1215023 2024-013
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.676 UNACCOMPANIED ALIEN CHILDREN PROGRAM $5.28M
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $260,463