2.) Finding 2020-002 Report Submission Delay
a. Program Information: 17.270 Reentry Employment Opportunities
b. Criteria: In accordance with 2 CFR 200.329, non-Federal entities must submit quarterly financial reports at the interval required by the Federal awarding agency or pass-through entity no later than the specified due date. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any quarterly financial report.
c. Condition: During our audit, we identified one quarterly financial report that was submitted to the Contracting Officer’s Representative (COR) after the stated due date.
Response:
Explanation: This delay was due to an unawareness of process limitations regarding the user application process for the Payment Management System (PMS), which is required for any new Finance Director. A formal application and access request form needs to be submitted along with documentation to support the request for access (including proof of identity, proof of employment, and role confirmation). These conditions, along with the 24-72 hour processing time required to get a user application approved by the PMS providers, led to our one-day-late submission of the required quarterly financial report.
Corrective Action: We have established a more proactive approach to managing reporting requirements and a protocol for timely submissions of reports. This includes:
- Mandatory PMS application processing as part of the early onboarding process for any new Finance Director.
- Early preparation of reports, scheduling reviews a month ahead of the submission deadline.
- Direct communication lines with the contract administrators and program directors.
- Standard procedures identified to request extensions in case of anticipated delays, specific to each contracting agency.
Future Measures: Regular training session for our team are planned to help staff stay informed about reporting requirements, procedures, and deadlines.
Contact person responsible for corrective action: John Domingo, Finance & IT Director
Compleion date: 07/01/2023