Finding Text
Criteria or Specific Requirements: In accordance with the terms and conditions of ALN 66.424 and ALN 66.446, reimbursement requests are required to be submitted by the 10th day of the month following the month in which expenditures were incurred. Effective internal controls should be designed and implemented to ensure reimbursement requests are prepared, reviewed, and submitted within the required timeframe. Condition: During testing of cash management compliance for ALN 66.424 and ALN 66.446, it was noted that the Organization did not have effective controls in place to ensure reimbursement requests subject to the agreement requirements were consistently submitted by the required deadline. Of 18 reimbursement requests tested that were required to be submitted by the 10th day of the following month, four reimbursement requests were submitted after the required deadline. Cause: The Organization had not established internal controls to ensure reimbursement requests were submitted in accordance with grant-specific reimbursement deadlines. Specifically, the Organization did not have procedures in place to monitor reimbursement due dates or ensure reimbursement requests were prepared and submitted by the required deadline. Effect: Failure to submit reimbursement requests within the required timeframe results in noncompliance with the cash management requirements established by the grant agreements. Untimely reimbursement requests may delay the receipt of federal funds and increase the risk that grant requirements are not met. Questioned Costs: Questioned costs were not identified. Perspective information: During testing of cash management compliance, 22 reimbursement requests were tested across multiple awards. Of the 22 reimbursement requests tested, 18 were subject to subrecipient agreement requirements requiring submission by the 10th day of the following month. Four of the 18 reimbursement requests subject to this requirement were submitted after the required deadline. Repeat Finding: None. Recommendations: We recommend that management establish and document procedures to ensure reimbursement requests are prepared, reviewed, and submitted by the required deadline. Such procedures should include maintaining a grant compliance calendar identifying submission due dates, assigning responsibility for preparation and review, implementing supervisory review prior to submission, and retaining documentation evidencing timely submission. Management should also periodically monitor compliance with reimbursement deadlines to ensure controls are operating effectively.