Finding 38057 (2022-002)

-
Requirement
C
Questioned Costs
-
Year
2022
Accepted
2023-07-16

AI Summary

  • Core Issue: The Alliance did not pass federal funds to subrecipients within the required 30 days after receiving them.
  • Impacted Requirements: This violates cash management rules outlined in 2 CFR section 200.305(b), which require timely disbursement of funds.
  • Recommended Follow-Up: Enhance policies and procedures for subrecipient payments and implement regular checks and training to ensure compliance.

Finding Text

Program Information: Temporary Assistance for Needy Families (ALN #93.558) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management- Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the nonfederal 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)). As defined in 48 CFR section 52.216 7(b)(1), with relation to supplies and services purchased for use on the contract, ?ordinary course of business? would be in accordance with the terms and conditions of a subcontract or invoice, and ordinarily within 30 days of the request to the federal government for reimbursement. Views of Responsible Officials and Planned Corrective Actions: To stay updated on incoming funds, management will proactively check the Virginia Portal each week to determine if any payments have been made. Management will initiate cross-training sessions for additional staff members to ensure that Club payments can be processed in the absence of the current staff. Management will implement calendar reminders to ensure that payments are promptly presented for processing within five days of receiving the deposit notification. Condition: Certain instances during the year were identified in which federal funds were not passed to subrecipients within 30 days of the funds being transferred to the Alliance from the US Treasury or pass-through entity. Cause: Administrative oversight with respect to Cash Management compliance requirements. Effect or Potential Effect: The Alliance was not in compliance Cash Management compliance requirements. Questioned Costs: None. Context: For 3 of 18 subrecipient payments selected for testing, the Alliance failed to properly disburse funds received from the Department of Health and Human Services to local clubs within the required 30 calendar days. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the Alliance enhance its policies and procedures over subrecipient payments to ensure such payments are in accordance with federal regulations.

Corrective Action Plan

Individual Responsible for Corrective Action Plan: Romero Brown, Virginia Alliance Director Corrective Action: Weekly Monitoring: Management will proactively check the Virginia Portal each week to determine if any payments have been made. This will allow us to stay updated on incoming funds. Cross Training: Management will initiate cross-training sessions for additional staff members to ensure that Club payments can be processed even in the absence of the current staff. This step will enhance our operational resilience. Calendar Prompts: Management will implement calendar reminders to ensure that payments are promptly presented for processing within five days of receiving the deposit notification. This measure will help us adhere to the required disbursement timeframe. By implementing these actions, we aim to mitigate delays in the disbursement process and establish a more efficient workflow. Anticipated Completion Date: June 30, 2023

Categories

Subrecipient Monitoring Cash Management Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
93.558 Temporary Assistance for Needy Families $1.67M