Finding Text
Criteria: Under 2 CFR § 200.305(b) of the Uniform Guidance, advance payments to a non-federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-federal entity in carrying out the purpose of the approved program. Under 2 CFR § 200.302(b)(6), the entity must maintain written procedures to implement these payment requirements. Additionally, 2 CFR § 200.346 provides that any federal funds paid in excess of the amount the entity is entitled to under the award constitute a debt to the federal government, and 2 CFR § 200.344 requires the entity to promptly refund any balance of unobligated cash advanced that it is not authorized to retain. Condition: During our testing of cash management for the Part C Capacity Development award, we noted that the Institution requested an advance of $15,000 from the federal awarding agency for the purchase of equipment. The equipment was ultimately acquired at a cost lower than the amount requested. As a result, the $15,000 advanced remained undisbursed as of December 31, 2025. At the time of our audit, the Institution had not returned the excess funds to the federal awarding agency. Effect: The Institution held federal cash in excess of its immediate needs, which is not in compliance with the cash management requirements of the Uniform Guidance. The undisbursed balance represents a liability to the federal government and may generate interest that must be remitted. Failure to return these funds could result in the federal agency disallowing costs or requiring repayment, imposing other remedies for noncompliance under 2 CFR § 200.339, potentially jeopardizing future funding Cause: The Institution does not have adequate policies and procedures to monitor federal cash advances against actual expenditures, nor to identify and return excess advanced funds on a timely basis. In addition, there was no review process to reconcile drawdowns to the actual cost of the items purchased once the transaction was completed. Recommendations: We recommend that the Institution take the following actions: 1. Return of Excess Funds: Promptly return the undisbursed $15,000 to HRSA through the Payment Management System (PMS) in accordance with the agency’s refund procedures, and determine whether any interest earned on the advance must be remitted under 2 CFR § 200.305(b)(9). 2. Drawdown Procedures: Develop and implement written cash management procedures to ensure that advance requests are limited to immediate cash needs and are supported by current quotes, purchase orders or invoices. 3. Reconciliation and Review: Establish a periodic reconciliation, at least monthly, of federal drawdowns against actual disbursements for each award, so that any excess cash is identified and either applied to allowable costs within the required time frame or returned to the awarding agency. 4. Monitoring and Oversight: Assign responsibility for monitoring federal cash balances to a designated officer, with review by senior management, to ensure timely compliance.