Finding 1217914 (2025-001)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2025
Accepted
2026-06-18
Audit: 404036
Organization: Generations United, Inc. (DC)

AI Summary

  • Core Issue: The Organization lacks a formal internal review and approval process for cash drawdowns, risking non-compliance with federal requirements.
  • Impacted Requirements: This deficiency violates 2 CFR §200.303, which mandates effective internal controls for managing federal awards.
  • Recommended Follow-Up: Establish a formal review and approval process for all drawdowns to ensure accuracy and compliance before reimbursement requests are submitted.

Finding Text

Finding: 2025-001 Cash Management (Significant Deficiency) Federal Agency: Department of Health and Human Services Federal Program: National Technical Assistance Center on Kinship and Grandfamilies (2025) Assistance Listing Number: 93.048 Criteria: According to 2 CFR §200.303, Recipients and subrecipients must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Organization did not have an internal review and approval process in place over draw downs. Cause: The Organization did not maintain an adequate review and approval process over each drawdown to ensure amounts requested, including indirect cost reimbursements, were accurate, properly supported, and in compliance with Federal grant requirements. Effect or Potential Effect: The Organization may request reimbursement for costs in excess of the allowable amount or for unallowable costs, if drawdowns are not properly reviewed and approved with appropriate oversight. Information on the Federal Program: 93.048 Questioned Costs: None noted, as this is an administrative requirement and there were no instances noted of noncompliance. Context: During our audit, we noted that none of the nine drawdown samples tested were reviewed and approved. The sample is representative of the population. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend the Organization implement a formal review and approval process for all drawdowns to ensure amounts requested are accurate, properly supported, and reviewed prior to submission for reimbursement.

Corrective Action Plan

Views of Responsible Officials: Management acknowledges that a formal internal review and approval process over Federal drawdowns was not in place during the audit period, particularly for the more frequent drawdowns that moved from monthly to weekly. The change in drawdown practices, including performing draws on a more frequent basis, was implemented in response to managing cash flow and external risks.Management notes that oversight was performed on a periodic basis, specifically each quarter end. Starting in May 2026, one financial party will calculate the Federal pull amount using actual costs and a 10% indirect rate, the Executive Director will review and sign off, and the Director of Grandfamilies & Kinship Support Network will initiate pulling funds from the Federal system.

Categories

Cash Management Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Programs in Audit

ALN Program Name Expenditures
93.048 SPECIAL PROGRAMS FOR THE AGING, TITLE IV, AND TITLE II, DISCRETIONARY PROJECTS $2.31M
93.052 NATIONAL FAMILY CAREGIVER SUPPORT, TITLE III, PART E $66,590