Finding Text
Criteria: Regulations require that the Organization 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, to comply with 2 CFR § 200.305(b). Condition: The 93.493 grant is a reimbursement type grant, subject to an approved preliminary expense budget, as the grant agreement does not specifically indicate that it is an advance-type grant. As such, all supported expenses should be recognized before applying for funding or expended within a “reasonable” period subsequent to receipt of funds. Effect: A portion of reimbursement funds were received prior to supporting expenditures being recognized, and funds were not subsequently expended within a “reasonable” period. Questioned Costs: No questioned costs were identified as a result of our procedures. Cause: The Organization applied for grant drawdowns based on projections and expended funds greater than 30 days beyond receipt, resulting in expenditures occurring prior to being identified as qualified expenditures. Recommendation: The Organization should review internal policies related to drawdowns to ensure that drawdowns occur in compliance with Uniform Guidance. Views of Responsible Officials: We agree with finding and will follow prescribed recommendation