Finding 1223140 (2025-007)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2025
Accepted
2026-07-08
Audit: 406665
Organization: Puerto Rico Ports Authority (PR)
Auditor: GALINDEZ LLC

AI Summary

  • Core Issue: There are inadequate controls to ensure timely disbursement of funds received from the pass-through entity, leading to unused capital advances.
  • Impacted Requirements: Compliance with CFR Part 200.305, which mandates minimizing the time between fund transfer and disbursement.
  • Recommended Follow-Up: Establish procedures to ensure timely disbursement of funds and avoid returning unused funds to the pass-through entity.

Finding Text

Finding No: 2025-007 – Lack of controls over minimizing the time elapsing between the transfer of funds from the pass-through entity and the disbursement of funds by the Authority . CFR Part 200 Subpart D Subsection 200.305 states the following: For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. See § 200.302(b)(6). Except as noted in this part, the Federal agency must require recipients to use only OMB-approved, government-wide information collections to request payment. The recipient or subrecipient must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the recipient or subrecipient, and financial management systems that meet the standards for fund control and accountability as established in this part. Advance payments to a recipient or subrecipient must be limited to the minimum amounts needed and be timed with actual, immediate cash requirements of the recipient or subrecipient in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the recipient or subrecipient for direct program or project costs and the proportionate share of any allowable indirect costs. The recipient or subrecipient must make timely payments to contractors in accordance with the contract provisions. Whenever possible, advance payment requests by the recipient or subrecipient must be consolidated to cover anticipated cash needs for all Federal awards received by the recipient from the awarding Federal agency or pass-through entity. During our audit procedures, we identified that most capital advances received during fiscal years 2025 and 2024 from FEMA were still unused on June 30, 2025, with no procedures to minimize the time elapsing between funds received and disbursed. In addition the Authority had to returned unused funds to the pass through entity since they remained unused for more than a year.

Corrective Action Plan

The Puerto Rico Ports Authority (PRPA) acknowledges the audit finding regarding the unused capital advances as of June 30, 2025. It is important to clarify that these funds were received under the Working Capital Advance (WCA) Program, an initiative led by COR3 to expedite the implementation of FEMA-funded recovery projects. The WCA Program provides subrecipients, such as PRPA, with a 25% upfront advance of the total project cost to address initial project expenses and mitigate delays due to cash flow constraints. The WCA advance is disbursed by PRPA upon completion of contracted deliverables by vendors or suppliers, particularly during the design and early implementation phases of projects. As of the audit date, most of PRPA’s FEMA projects under the WCA were still in the design phase, and the disbursements made thus far correspond to completed design services. The remaining balance of WCA funds will be disbursed as vendors fulfill the contractual milestones tied to architectural and engineering (A&E) and construction services. The apparent delay between fund receipt and disbursement reflects the timing of deliverable completion rather than a lack of project activity. PRPA continues to monitor the progress of A&E and construction services to ensure timely disbursement aligned with actual project progress. To strengthen the oversight of WCA funds and ensure timely utilization, PRPA management is implementing enhanced administrative controls. These include the development and formal adoption of internal procedures aimed at improving the handling, identification, and classification of FEMArelated funds. These measures will support be􀄴er alignment between fund disbursement and project execution timelines and demonstrate PRPA’s commitment to the prudent and compliant management of federal funds.

Categories

Subrecipient Monitoring Cash Management

Other Findings in this Audit

  • 1223134 2025-004
    Material Weakness Repeat
  • 1223135 2025-005
    Material Weakness Repeat
  • 1223136 2025-005
    Material Weakness Repeat
  • 1223137 2025-006
    Material Weakness Repeat
  • 1223138 2025-005
    Material Weakness Repeat
  • 1223139 2025-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
20.106 AIRPORT IMPROVEMENT PROGRAM, INFRASTRUCTURE INVESTMENT AND JOBS ACT PROGRAMS, AND COVID-19 AIRPORTS PROGRAMS $41.57M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $6.00M
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $4.42M
20.500 FEDERAL TRANSIT CAPITAL INVESTMENT GRANTS $899,871
97.039 HAZARD MITIGATION GRANT $825,137