Finding Text
2021-002 Overdrawing of federal funds Information on Federal Programs: Assistance Listing #: 93.421, 93.318, 93.185 Federal Agency: United States Department of Heath and Human Services Criteria: Cash management compliance requirements under Subpart B of 31 CFR Part 205 require that nonfederal entities minimize the time elapsing between the transfer of funds from the Payment Management System (PMS) or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. (2 CFR section 200.305(b)). Condition: There was an overdraw of funds of $200,000 where costs had not been incurred to support the draw, nor were all the funds spent prior within a reasonable time frame. Effect: There is a refundable advance on the books for $131,858 for funds that were drawn and unspent at year end. Cause: Due to changes in staffing around this time, a draw was made for part of the funds and then a second draw was made for the full amount of expenses, without accounting for the previously drawn funds. Recommendation: We recommend that the Organization ensure there controls in place for review and approval of all draws and a reconciliation be done at each draw to ensure that there are sufficient expenditures to support the draw. Any overdraws should be caught immediately and steps taken to remedy the draw or to expend the funds within a reasonable timeframe.