Finding 1236505 (2025-002)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2025
Accepted
2026-09-24
Audit: 412036
Organization: GULF OF ALASKA KEEPER (AK)

AI Summary

  • Core Issue: The Organization drew down $3.7 million in Federal funds significantly exceeding immediate cash needs, violating cash management regulations.
  • Impacted Requirements: Federal regulations require cash draws to align closely with actual expenditures, limiting advances to necessary amounts.
  • Recommended Follow-Up: Strengthen cash management controls, document cash needs before draws, and review excess funds with the awarding agency to address compliance issues.

Finding Text

Finding 2025-002 Noncompliance over Cash Management Material Weakness/ Material Noncompliance Criteria: Federal regulations require recipients and subrecipients to maintain appropriate cash management procedures over Federal awards. Under 2 CFR § 200.305(b), advance payments of Federal funds must be limited to the minimum amounts needed and timed to coincide with the organization’s actual, immediate cash requirements. The timing and amount of Federal cash draws should be as close as administratively feasible to the organization’s actual disbursements for allowable program costs. Condition and Context: During our testing of the Organization’s compliance with cash management requirements, we noted that in January 2025, the Board approved the withdrawal of substantially all remaining funds available under the Federal award. Management indicated that the decision was made due to concerns that Federal funding for the grant could be terminated or otherwise become unavailable. At the time of the drawdown, the Organization had incurred approximately $63,000 of program expenditures. As a result, approximately $3.7 million of Federal funds were drawn in excess of expenditures incurred and the Organization’s immediate cash needs. Accordingly, the funds were drawn substantially in advance of the related program expenditures. We considered this matter to represent material noncompliance with the cash management requirements applicable to the Federal award. Cause: The Organization elected to draw substantially all available grant funds due to concerns regarding the potential premature termination or loss of Federal funding. Additionally, the Organization did not have adequate controls in place to ensure that Federal cash draws were limited to amounts necessary to meet immediate program cash requirements. Effect: The Organization maintained a significant amount of Federal funds in excess of its immediate cash needs, resulting in material noncompliance with Federal cash management requirements and the terms and conditions of the Federal award. The excess draw also exposes the Organization to potential repayment requirements and obligations related to interest earned on Federal funds. Under 2 CFR § 200.305, Federal advance payments generally must be maintained in interest-bearing accounts when applicable, and interest earned in excess of $500 per year must be remitted to the Federal government. Questioned Costs: None noted. Repeat Finding: This is not a repeat finding. Recommendation: Management should strengthen its internal controls over Federal cash management and establish written procedures requiring Federal cash draws to be based on actual, immediate cash needs. Prior to each draw, management should document the expenditures incurred and anticipated near-term disbursements supporting the amount requested. Cash draw requests should be reviewed and approved by appropriate personnel and periodically reconciled to actual program expenditures. Management should also review the excess Federal funds on hand and coordinate with the awarding agency or pass-through entity, as appropriate, to determine whether amounts should be returned and whether any interest earned is required to be remitted. Although management indicated that verbal approval was received, written documentation should be obtained and retained to support the organization’s treatment and use of the interest earned. Management Response: Management concurs with this finding. See Corrective Action Plan.

Corrective Action Plan

Finding 2025-002: Noncompliance over Cash Management Name of Contact: Chris Pallister, Executive Director Corrective Action: Federal cash drawdowns will be based on cash needs not to exceed 30 days. In collaboration with the Exec Director, Controller will prepare a report of anticipated cash disbursements for each month, along with projected ending grant funds on hand. The report will be submitted to the Exec Director or Treasurer for review and to request written approval for the drawdown. Such approval shall be obtained prior to requesting the drawdown. Cash draw requests will be reconciled to actual program expenditures on a quarterly basis. Proposed Completion Date: October 1, 2026.

Categories

Cash Management Subrecipient Monitoring

Other Findings in this Audit

  • 1236504 2025-001
    Material Weakness Repeat
  • 1236506 2025-003
    Material Weakness Repeat
  • 1236507 2025-004
    Material Weakness Repeat
  • 1236508 2025-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
11.999 MARINE DEBRIS PROGRAM $1.67M