Finding 28619 (2022-002)

Criteria and Condition: The Organization is required to properly retain and store documentation surrounding grant reimbursements. The Organization should have strong policies and internal controls in place to ensure reimbursement requests are in line with 2 CFR 200.305(b)(3). Cause: This was caused by inadequate policies and weakened internal controls. Effect: The lack of adequate documentation may result in the Organization being non-compliant with 2 CFR 200.305(b)(3). Not having strong policies in place and weakened internal controls could result in questioned costs. Questioned Costs: There are no questioned costs as a result of this finding. Perspective Information: The finding is a systemic program and was identified in all cases of the testing sample. The sample was a statistically valid sample. Recommendation: We recommend the Organization implement policies and procedures that outline the process for requesting reimbursement in line with 2 CFR 200.305(b)(3). Pursuant to 2 CFR 200.305(b)(3), program costs must be paid by non-federal entity funds before submitting a payment request. Uniform Guidance states that a non-federal entity must distribute funds for program purposes before requesting payment from the federal awarding agency or pass through entity. We recommend the Organization ensure proper documentation is retained to serve as proof for a reimbursement request. Views of Responsible Officials: The Organization agrees with the finding and will adhere to the planned corrective action.