Finding 1240848 (2024-013)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2024
Accepted
2026-10-21
Audit: 415176
Organization: State of Kosrae (FM)

AI Summary

  • Core Issue: The State could not provide adequate documentation for $221,521 of a federal cash drawdown, failing to demonstrate that it reimbursed eligible expenditures.
  • Impacted Requirements: The State did not comply with 2 CFR 200.302 and 200.305, which require maintaining records of federal fund usage and timely reimbursement requests.
  • Recommended Follow-up: The State should enhance cash-management procedures, ensure proper documentation for drawdowns, and regularly monitor cash needs to prevent future issues.

Finding Text

Finding 2024-013 Federal Agency: U.S. Department of Health and Human Services Assistance Listing: 93.224 - Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) Federal Award No.: Various Area: Cash Management Questioned Costs: $221,521 Criteria: Under 2 CFR 200.302(b)(3), (6), and (7), a non-federal entity must maintain records that identify the source and application of federal funds, establish effective control over and accountability for all funds, and support compliance with federal requirements through written procedures. In addition, 2 CFR 200.305(b) requires the non-federal entity to minimize the time between the transfer of federal funds and their disbursement and, when reimbursement is used, to request payment only after costs have been incurred. Accordingly, each drawdown should be supported by contemporaneous expenditure records and a reconciliation demonstrating the amount of eligible, unreimbursed program expenditures. Condition: 1. For 1 of 2 cash-management transactions tested, the State could not provide documentation supporting the calculation or amount of a $435,026 federal cash drawdown requested on June 5, 2024, under award 4 H8FCS41736-01-03 (the award). Specifically, the documentation provided for JV240324 did not include a contemporaneous expenditure report or reconciliation identifying (a) eligible award expenditures incurred through the drawdown date, (b) amounts previously reimbursed, and (c) the remaining unreimbursed expenditures available to support the drawdown. Our review of other available documentation disclosed the following: • On August 24, 2022, and April 27, 2023, the State drew down $110,269 and $74,899, respectively, totaling $185,168. Available documentation indicated that these drawdowns reimbursed expenditures incurred from program inception through March 31, 2023. • For the period from October 1, 2022, through August 31, 2024, available records identified approximately $745,597 of federal expenditures charged to the award. • On June 12, 2023, September 26, 2023, and June 5, 2024, the State drew down $148,366, $198,558, and $435,026, respectively, totaling $781,950. Based on the available records, the State had $560,429 of potentially eligible unreimbursed expenditures after the April 27, 2023, drawdown ($745,597 of reported expenditures less $185,168 of prior documented drawdowns). However, the subsequent drawdowns totaled $781,950. Therefore, the available documentation did not support $221,521 of the June 5, 2024, drawdown ($781,950 less $560,429). We question $221,521 because the State did not demonstrate that this portion of the drawdown reimbursed eligible, unreimbursed award expenditures. 2. In addition, the State did not consistently implement its established procedures for monitoring program cash needs and making drawdowns on a regular schedule. During fiscal year 2024, the State made only two drawdowns: one requested on June 5, 2024, and received on June 7, 2024, and another requested on August 2, 2024, and received on August 6, 2024.Cause: The State did not consistently enforce its cash-management procedures and did not maintain a complete, contemporaneous audit trail supporting each drawdown. Specifically, responsibility for preparing, reviewing, and retaining expenditure reports and cumulative reimbursement reconciliations was not effectively implemented. Effect: The State could not demonstrate that $221,521 of the June 5, 2024, drawdown was supported by eligible, unreimbursed award expenditures. As a result, federal funds may have been drawn in excess of immediate program needs, and the unsupported amount is questioned. Recommendation: The State should: 1. Strengthen and enforce its cash-management procedures. For each drawdown, the State should prepare, review, and retain a reconciliation that identifies cumulative eligible expenditures, prior reimbursements, adjustments or reconciling items, and the resulting balance of unreimbursed expenditures by federal award. The reconciliation and supporting expenditure reports should be reviewed and approved before the drawdown request is submitted. 2. Monitor program cash needs and submit reimbursement requests on a regular, timely schedule consistent with its written procedures. Management should review the $221,521 questioned amount and provide additional support to the federal awarding agency if available. Identification as a Repeat Finding: 2023-008 Views of Responsible Officials: The State's response and corrective action plan addressing this finding are included in the accompanying corrective action plan.

Corrective Action Plan

Pohnpei has agreed to the findings and is committed to implementing the recommendations. Ongoing Director of Treasury and Administration Sihna N. Lawrence sihna.lawrence@pohnpeidota.fm

Categories

Cash Management

Other Findings in this Audit

  • 1240821 2024-002
    Material Weakness Repeat
  • 1240822 2024-004
    Material Weakness Repeat
  • 1240823 2024-007
    Material Weakness Repeat
  • 1240824 2024-008
    Material Weakness Repeat
  • 1240825 2024-002
    Material Weakness Repeat
  • 1240826 2024-003
    Material Weakness Repeat
  • 1240827 2024-005
    Material Weakness Repeat
  • 1240828 2024-007
    Material Weakness Repeat
  • 1240829 2024-008
    Material Weakness Repeat
  • 1240830 2024-008
    Material Weakness Repeat
  • 1240831 2024-002
    Material Weakness Repeat
  • 1240832 2024-004
    Material Weakness Repeat
  • 1240833 2024-005
    Material Weakness Repeat
  • 1240834 2024-007
    Material Weakness Repeat
  • 1240835 2024-008
    Material Weakness Repeat
  • 1240836 2024-007
    Material Weakness Repeat
  • 1240837 2024-008
    Material Weakness Repeat
  • 1240838 2024-002
    Material Weakness Repeat
  • 1240839 2024-008
    Material Weakness Repeat
  • 1240840 2024-008
    Material Weakness Repeat
  • 1240841 2024-006
    Material Weakness Repeat
  • 1240842 2024-008
    Material Weakness Repeat
  • 1240843 2024-002
    Material Weakness Repeat
  • 1240844 2024-009
    Material Weakness Repeat
  • 1240845 2024-010
    Material Weakness Repeat
  • 1240846 2024-011
    Material Weakness Repeat
  • 1240847 2024-012
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.027 SPECIAL EDUCATION GRANTS TO STATES $951,629
93.224 HEALTH CENTER PROGRAM $364,188
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $238,919
93.116 PROJECT GRANTS AND COOPERATIVE AGREEMENTS FOR TUBERCULOSIS CONTROL PROGRAMS $181,165
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $114,816
10.675 URBAN AND COMMUNITY FORESTRY PROGRAM $105,924
15.875 ECONOMIC, SOCIAL, AND POLITICAL DEVELOPMENT OF THE TERRITORIES $98,721
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $95,032
15.904 HISTORIC PRESERVATION FUND GRANTS-IN-AID $80,497
93.217 FAMILY PLANNING SERVICES $39,296
93.898 CANCER PREVENTION AND CONTROL PROGRAMS FOR STATE, TERRITORIAL AND TRIBAL ORGANIZATIONS $36,788
93.092 AFFORDABLE CARE ACT (ACA) PERSONAL RESPONSIBILITY EDUCATION PROGRAM $31,376
93.110 SPECIAL PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $21,837
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $20,553
93.377 PREVENTION AND CONTROL OF CHRONIC DISEASE AND ASSOCIATED RISK FACTORS IN THE U.S. AFFILIATED PACIFIC ISLANDS, U.S. VIRGIN ISLANDS, AND P. R. $16,670
93.251 EARLY HEARING DETECTION AND INTERVENTION $9,312
93.788 OPIOID STR $1,026
93.104 COMPREHENSIVE COMMUNITY MENTAL HEALTH SERVICES FOR CHILDREN WITH SERIOUS EMOTIONAL DISTURBANCES (SED) $508
93.354 PUBLIC HEALTH EMERGENCY RESPONSE: COOPERATIVE AGREEMENT FOR EMERGENCY RESPONSE: PUBLIC HEALTH CRISIS RESPONSE $324