Finding 1236213 (2025-002)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2025
Accepted
2026-09-23

AI Summary

  • Core Issue: NICJR failed to minimize the time between drawing down federal funds and making related payments, violating 2 CFR 200.305(b).
  • Impacted Requirements: Cash management requirements were not met, as NICJR did not have formal policies to ensure timely disbursements.
  • Recommended Follow-Up: NICJR should develop and implement a cash management policy to align with federal requirements and improve fund disbursement timing.

Finding Text

Criteria – 2 CFR 200.305(b) requires recipients and subrecipients other than States, to minimize the time elapsing between the transfer of funds from the Federal agency or pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made byelectronic funds transfer or by other means. Condition – NICJR did not minimize the time elapsed between the drawdown of funds and payment of related expenditures in accordance with 2 CFR 200.305(b). Context – NICJR did not pay expenses prior to requesting a transfer of funds from the federal agency, did not minimize the time elapsed between payment and request of funds, and did not calculate interest earned on any advanced payments. Cause – NICJR does not have formal policies and procedures in place to minimize the time elapsing between transfer of funds and related disbursements. Effect – The federal agency paid down funds to NICJR before costs were paid. NICJR has not met the Cash Management requirements of 2 CFR 200.305(b). Questioned costs – None Repeat Finding – This is not a repeat finding. Recommendation – We recommend NICJR enhance policies and procedures to minimize the time elapsed between payment and request of funds. Management’s response - NICJR’s drawdowns were due to extraordinary circumstances. There was an unprecedented action taken by the federal government in announcing the pending cancellation of more than $800 million grants to thousands of non-profit organizations around the country. During the significant uncertainty surrounding the changing funding environment, as well as our commitment to our subgrantee organizations, NICJR continued submitting reimbursement requests while awaiting additional guidance. NICJR will create a cash management policy to minimize the time elapsed between payment and request of funds to meet requirements of 2 CFR 200.305(b).

Corrective Action Plan

Views of Responsible Officials and Corrective Action Plan: Management acknowledges and concurs with this finding and is developing formal policies and procedures related to cash management compliance requirements. NICJR’s drawdowns were due to extraordinary circumstances. There was an unprecedented action taken by the federal government in announcing the pending cancellation of more than $800 million grants to thousands of non-profit organizations around the country. During the significant uncertainty surrounding the changing funding environment as well as our commitment to our subgrantee organizations, NICJR continued submitting reimbursement requests while awaiting additional guidance. NICJR will create a cash management policy to minimize the time elapsed between payment and request of funds to meet requirements of 2 CFR 200.305(b). Name of Responsible Person: Leah Wilson, Chief of Staff Implementation Date: July 1, 2026

Categories

Cash Management Subrecipient Monitoring

Other Findings in this Audit

  • 1236211 2025-002
    Material Weakness Repeat
  • 1236212 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
16.827 JUSTICE REINVESTMENT INITIATIVE $270,039
16.540 JUVENILE JUSTICE AND DELINQUENCY PREVENTION $232,367
16.839 STOP SCHOOL VIOLENCE $113,967
16.548 DELINQUENCY PREVENTION PROGRAM $41,165
16.045 COMMUNITY-BASED VIOLENCE INTERVENTION AND PREVENTION INITIATIVE $40,297