Finding 384404 (2023-002)

Material Weakness
Requirement
C
Questioned Costs
-
Year
2023
Accepted
2024-03-26
Audit: 297558
Organization: City of Cheboygan (MI)

AI Summary

  • Core Issue: The City is not paying contractors and vendors on time, often waiting over 30 days after receiving federal reimbursements.
  • Impacted Requirements: This noncompliance with the Federal Acquisition Regulation (FAR) and Uniform Guidance affects cash management practices.
  • Recommended Follow-Up: Develop a cash management policy to ensure timely payments to contractors and vendors within 30 days of reimbursement requests.

Finding Text

Cash Management Finding Type: Noncompliance and Material Weakness in Internal Control over Compliance. Programs: United States Environmental Protection Agency Capitalization Grants for Clean Water State Revolving Funds (ALN #66.458) and Capitalization Grants for Drinking Water State Revolving Funds (ALN #66.468) Criteria: For cost-reimbursement contracts under the Federal Acquisition Regulation (“FAR”), reimbursement payment is the predominant method of funding. Advance payments under FAR based contracts are rare. The FAR clause at 48 CFR section 52.216-7 applies to reimbursement payment. Paragraph (b)(1) of that clause requires that the non-Federal entity request reimbursement for (a) only allocable, allowable, and reasonable contract costs that have already been paid, or (b) if the non-Federal entity is not delinquent in paying costs of contract performance in the ordinary course of business, costs incurred, but not necessarily paid. 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. Condition/Finding: During our audit procedures over the City’s cash management procedures, we noted that the City paid contractors and vendors 30 days after receiving the Federal reimbursement on two of the five federal reimbursements, with vouchers totaling $212,541. The City does not have a process in place to ensure contractors and vendors are paid in a timely manner. Cause: The City does not have a cash management policy which led to them receiving and disbursing funds not in compliance with the Uniform Guidance. Effect: Contractors and vendors were not paid timely and federal funds were held for over thirty days prior to the disbursement of funds. Questioned Costs: No costs have been questioned as a result of this finding. Recommendation: The City should develop and implement a cash management policy and procedures and if reimbursements are requested prior to paying the contractors and vendors the contractors and vendors are paid within 30 days of the request.

Categories

Cash Management

Other Findings in this Audit

  • 384401 2023-001
    Material Weakness
  • 384402 2023-002
    Material Weakness
  • 384403 2023-001
    Material Weakness
  • 960843 2023-001
    Material Weakness
  • 960844 2023-002
    Material Weakness
  • 960845 2023-001
    Material Weakness
  • 960846 2023-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
66.458 Capitalization Grants for Clean Water State Revolving Funds $2.51M
66.468 Capitalization Grants for Drinking Water State Revolving Funds $2.51M
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $417,846
21.027 Coronavirus State and Local Fiscal Recovery Funds $408,308
10.760 Water and Waste Disposal Systems for Rural Communities $360,543
16.835 Body Worn Camera Policy and Implementation $5,747
90.404 2018 Hava Election Security Grants $1,268