Finding 1221661 (2025-002)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-06-30

AI Summary

  • Core Issue: The Coalition has not insured cash balances exceeding FDIC limits, leaving $510,432 uninsured as of September 30, 2025.
  • Impacted Requirements: This violates Uniform Guidance 2 CFR, Part §200.305(b)(7), which mandates that advance payments of Federal funds be deposited in insured accounts.
  • Recommended Follow-Up: The Coalition should consult with their bank about options like insured cash sweep services or certificate of deposit account registry services to ensure compliance.

Finding Text

Finding 2025-002 – Cash Collateralization (Repeat Finding 2024-004) Criteria: Uniform Guidance 2 CFR, Part §200.305(b)(7) requires advance payments of Federal funds to be deposited and maintained in insured accounts whenever possible. Condition: During our review of the Coalition’s cash, it was noted that as of September 30, 2025, they have not collateralized cash balances in excess of the amounts insured by the Federal Despot Insurance Corporation. Cash balances of $510,432 were uninsured at September 30, 2025. Unearned revenue was reported at $7,516,280 which includes advance payments of Federal funds. Questioned Costs: None. Cause: The Coalition has not entered into a cash collateralization agreement with their financial institution. Effect: The Coalition is not in compliance with Uniform Guidance 2 CFR, Part §200.305(b)(7) as not all cash balances received in advance from the funding agency were adequately insured or collateralized and were exposed to custodial credit risk in the event of a bank failure. Recommendation: We recommend the Coalition discuss with their financial institution about insured cash sweep services or certificate of deposit account registry services. Views of Responsible Officials: See the corrective action plan that accompanies the schedule of findings and questioned costs.

Corrective Action Plan

Finding Number: 2025-002 Finding Title: Cash Collateralization (Repeat Finding 2024-004) Planned Corrective Action: Management acknowledges the finding regarding cash collateralization. As of September 30, 2025, the Coalition's cash deposits were pledged and collateralized. After year-end, management became aware that two affiliated financial institutions participating in the deposit sweep program had inadvertently assigned the same certificate numbers during the nightly sweep process. Consequently, a portion of the Coalition's deposits may have been swept into the same financial institution, resulting in balances that may have temporarily exceeded applicable FDIC insurance limits. Although this condition resulted from the financial institutions' sweep process rather than the Coalition's cash management practices, management recognizes its responsibility to monitor deposit coverage and ensure compliance. To address this finding, the Coalition will implement the following corrective actions: 1. Meet with representatives from both participating banks to discuss the issue and formally notify them of the audit finding. 2. Request written confirmation that the nightly sweep process has been reviewed and modified to prevent deposits from being placed with the same institution through duplicate certificate assignments or other system errors. This may happen from time-to-time but IntraFi corrects those deposits and reallocates them, It will be reviewed weekly to make sure they did reallocate those funds. 3. Communication with certain representatives within the financial institution will be contacted by NUHIC and will need to request that dollars are required to be transferred to IntraFi to remain in compliance of your audit before 2:30pm everyday. 4. Obtain and review periodic reports from the financial institutions identifying the banks holding swept deposits and the amount of funds placed with each institution. 5. Establish a weekly review process to monitor cash balances, FDIC insurance coverage, and collateralization to identify any exceptions on a timely basis. 6. Maintain documentation of all reviews, bank communications, and corrective actions as part of the Coalition's internal control procedures. 7. If the financial institutions cannot provide adequate assurance that deposits will remain fully insured or properly collateralized, the Coalition will evaluate alternative cash management options, including other insured cash sweep providers or collateralized deposit arrangements. Management believes these corrective actions will strengthen oversight of the Coalition's cash management process and reduce the risk of future noncompliance with FDIC insurance requirements. Responsible Official: Carlett Gregory Anticipated Completion Date: December 31, 2026

Categories

Cash Management

Other Findings in this Audit

  • 1221660 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.U01 TITLE V, URBAN HEALTH SERVICES $414,292
93.237 SPECIAL DIABETES PROGRAM FOR INDIANS DIABETES PREVENTION AND TREATMENT PROJECTS $305,715
93.193 URBAN INDIAN HEALTH SERVICES $137,045
16.841 VOCA TRIBAL VICTIM SERVICES SET-ASIDE PROGRAM $116,920
93.800 ORGANIZED APPROACHES TO INCREASE COLORECTAL CANCER SCREENING $39,480
93.436 WELL-INTEGRATED SCREENING AND EVALUATION FOR WOMEN ACROSS THE NATION (WISEWOMAN) $3,750
93.898 CANCER PREVENTION AND CONTROL PROGRAMS FOR STATE, TERRITORIAL AND TRIBAL ORGANIZATIONS $3,750