Finding 1229722 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-09-14
Audit: 410915
Organization: Intertribal Agriculture Council (MS)

AI Summary

  • Core Issue: The Organization failed to manage advance federal payments properly, not placing them in required interest-bearing accounts.
  • Impacted Requirements: Non-compliance with 2 CFR §200.305(b) regarding cash management and interest remittance led to questioned costs of $2,733.
  • Recommended Follow-Up: Implement policies for depositing funds in insured accounts, track interest earned, and provide staff training to ensure compliance.

Finding Text

Criteria: According to 2 CFR §200.305(b), when a non-federal entity receives advance payments of federal funds, recipients must minimize the time elapsed between the transfer of funds from the federal awarding agency and disbursement for program purposes. Further, advance payments 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. Unless certain exceptions apply, the entity must deposit those funds in interest-bearing accounts and must remit any interest earned on advances in excess of $500 per year to the federal agency. Condition: During our audit of the Organization’s federal awards, management identified deficiencies in the grantee’s cash management procedures related to advance payments received from federal awarding agencies. Specifically, the grantee did not segregate advance payments into an insured interest-bearing account required as required by the Uniform Guidance. Questioned Costs: $2,733 in interest in excess of $500 Cause: The Organization did not have adequate policies and procedures or internal controls in place to ensure compliance with the cash management requirements related to advance payments. Effect: Interest that should have been earned on federal advance payments may not have been earned, calculated, or remitted to the grantor in excess of $500. Recommendation: We recommend that the Organization implement policies and procedures to ensure that all advance payments are deposited into insured, interest-bearing accounts as required. The Organization should also establish controls to track interest earned on these accounts and remit amounts due to the federal awarding agencies in a timely manner. Training should be provided to staff responsible for cash management to ensure ongoing compliance with federal requirements. Repeat finding: This is a repeat of the prior year finding 2024-001. Views of Responsible Officials: Management agrees with the finding and procedures have been implemented to address the related issues.

Corrective Action Plan

Effect: The federal awarding agency did not receive interest that could have been earned on the advances. There was no loss from uninsured funds or from lack of segregating funds into separate accounts. Recommendation: The auditor recommends that the Organization implement policies and procedures to ensure that all advance payments are deposited into separate, insured, interest-bearing accounts as required. The grantee should also establish controls to track interest earned on these accounts and remit amounts due to the federal awarding agencies in a timely manner. Training should be provided to staff responsible for cash management to ensure ongoing compliance with federal requirements. 1. Explanation of Disagreement with Audit Findings: There is no disagreement with the audit findings. 2. Action Planned in Response to Finding: The Organization has implemented procedures to deposit the advance funds into separate, insured, interest-bearing accounts as required. The Organization has also established controls to track interest earned on the accounts and credit the interest back to the grant. 3. Official Responsible for Ensuring CAP: Kari Jo Lawrence, Chief Executive Officer and Jernon Kelly, Chief Financial Officer are responsible for ensuring corrective action of this deficiency. 4. Planned Completion Date for CAP: December 31, 2026.

Categories

Cash Management

Other Findings in this Audit

  • 1229721 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.186 REGIONAL FOOD BUSINESS CENTERS $2.35M
10.968 INCREASING LAND, CAPITAL, AND MARKET ACCESS PROGRAM $1.04M
10.184 PANDEMIC RELIEF ACTIVITIES: MEAT AND POULTRY PROCESSING CAPACITY - TECHNICAL ASSISTANCE GRANTS $652,522
10.601 MARKET ACCESS PROGRAM $478,506
10.147 OUTREACH EDUCATION AND TECHNICAL ASSISTANCE $337,664
10.234 AMERICAN RESCUE PLAN TECHNICAL ASSISTANCE INVESTMENT PROGRAM $293,719
10.046 Building Resiliency $291,746
10.069 CONSERVATION RESERVE PROGRAM $241,682
10.U01 Intertribal Agriculture Council American Indian Foods Program Domestic Market FFY 2023 $190,569
10.531 STATE AGENCY: FARM TO SCHOOL PROGRAM TRAINING AND CURRICULA $150,955
10.937 PARTNERSHIPS FOR CLIMATE-SMART COMMODITIES $65,871
10.902 SOIL AND WATER CONSERVATION $17,565
10.048 TRIBAL AGRICULTURE TECHNICAL ASSISTANCE $15,400
15.681 COOPERATIVE AGRICULTURE $609