Finding 1241173 (2025-001)

Material Weakness Repeat Finding
Requirement
C
Questioned Costs
-
Year
2025
Accepted
2026-10-25
Audit: 415251
Auditor: APRIO LLP

AI Summary

  • Core Issue: CRMHS' internal controls failed to ensure federal draw requests were properly reviewed and reconciled, leading to premature fund draws.
  • Impacted Requirements: Compliance with 2 CFR Part 200.305, which mandates minimizing the time between federal fund transfers and their disbursement for program needs.
  • Recommended Follow-Up: Management should enhance cash management controls and ensure thorough reconciliation of federal draw requests with expenditure records before submission.

Finding Text

Condition: CRMHS’ internal controls were not functioning as designed to ensure that federal draw requests were reviewed and reconciled to underlying allowable expenditures for the above program, resulting in CRMHS drawing down federal funds in advance of immediate cash needs. This finding is a repeat of finding 2024-002. Criteria: Under 2 CFR Part 200.305, non-federal entities must minimize the time elapsing between the transfer of funds from the U.S. Treasury and the disbursement of those funds for program purposes. Funds should only be drawn down as needed for immediate cash requirements. Cause: CRMHS made a draw prior to the year ended June 30, 2025 in excess of what was needed for immediate cash needs. Effect: Holding excess federal funds for extended periods can result in non-compliance with federal regulations and could potentially increase the risk of mismanagement or misuse of funds. Questioned Costs: During testing of cash draws under Assistance Listing 93.696, we noted CRMHS requested reimbursement of $193,046 in advance of incurring allowable costs. At June 30, 2025, this amount remained unspent and was properly recorded as part of refundable advances in the consolidated financial statements. This excess draw was subsequently expended for allowable program expenses. Accordingly, no questioned costs were identified. Recommendation: We recommend management review the current controls over cash management procedures and ensure a proper reconciliation of all federal draw requests to supporting expenditure records prior to submission of the draw request.

Corrective Action Plan

CRMHS management concurs with the finding. During the fiscal year ended June 30, 2025, CRMHS did not consistently operate internal controls over federal cash management as designed. Specifically, a federal draw was processed in excess of immediate cash needs and was not fully reconciled to supporting allowable expenditures prior to submission. This resulted in federal funds being drawn in advance of program disbursement requirements. Management acknowledges that this practice does not comply with 2 CFR §200.305, which requires non-federal entities to minimize the time between drawdown of federal funds and their disbursement for program purposes. While the funds were ultimately expended on allowable program costs, the timing of the draw created a compliance exception and reflects a material weakness in internal control over compliance. Management takes this matter seriously and has implemented corrective measures to strengthen cash management oversight and reconciliation procedures. Such actions include: CRMHS has completed a full reconciliation of all drawdowns under Assistance Listing 93.696 to supporting allowable expenditures through June 30, 2025. • Any excess cash balances identified were evaluated and adjusted to ensure compliance with federal cash management requirements. • Pre-Draw Reconciliation Requirement—No draw request may be submitted without documented reconciliation to recorded allowable expenditures. • Segregation of Duties and Review—the draw request and documented reconciliation will be reviewed and signed off on by a second qualified member of the accounting team. • Monthly Grant Cash Monitoring—CRMHS will compare cumulative drawdowns to cumulative allowable expenditures to identify and resolve any excess cash position.

Categories

Cash Management Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

Programs in Audit

ALN Program Name Expenditures
93.696 CERTIFIED COMMUNITY BEHAVIORAL HEALTH CLINIC EXPANSION GRANTS $873,442
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $517,192
93.493 CONGRESSIONAL DIRECTIVES $66,175
93.778 GRANTS TO STATES FOR MEDICAID $48,946