Finding Text
Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR 200.305(b)). Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR 200.1). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the US Treasury and disbursement by the nonfederal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR 200.305(b)(1)). The reimbursement payment method is the preferred payment method if (a) the non-federal entity cannot meet the requirements in 2 CFR 200.305(b)(1) for advance payment, (b) the federal awarding agency sets a specific condition for use of the reimbursement or (c) if requested by the non-federal entity (2 CFR 200.305(b)(3) and 200.208). The reimbursement payment method also may be used on a federal award for construction or for other construction activity as specified in 2 CFR 200.305(b)(3). To the extent available, the non-federal entity must disburse funds available from program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries, and interest earned on such funds before requesting additional federal cash draws (2 CFR 200.305(b)(5)). Except for interest exempt under the Indian Self-Determination and Education Assistance Act (25 USC 5301 et seq.), interest earned by non-federal entities other than states on advances of federal funds is required to be remitted annually to the US Department of Health and Human Services, Payment Management System, P.O. Box 6021, Rockville, MD 20852. Up to $500 per year may be kept for administrative expenses (2 CFR 200.305(b)(9)). During testing of federal compliance, we noted the City drew federal funds for expenses paid by another funding source. This resulted in the City accumulating a federal cash balance of $2,260,553. The City inquired with the grantor about the cash balance and was instructed to pay the next few project invoices with the cash balance until fully expended. Further, we noted that two of the five remaining draws in 2025 were held by the City in excess of five days. Estimated interest earned in 2025 on the balance of federal grants held is $27,658. Estimated interest in 2024 on the balance of federal grants held is $14,811. Finally, we noted the City does not have a federal cash management policy. The City should implement additional procedures to ensure they minimize the time elapsing between the transfer of funds from the US Treasury and disbursement by the City. Further, the City should adopt a written policy regarding cash management of federal funds.