Finding Text
Condition: During testing of grant reimbursements, we noted NCHE received reimbursement for program costs before it paid for those costs. Criteria: In accordance with 2 CFR 200.305(b)(3), program costs must be paid by non-federal entity funds before submitting a reimbursement request. Cause of Condition: NCHE does not have adequate polices in place to ensure program costs have been paid before a reimbursement request is submitted. Effect: The lack of adequate policies may result in noncompliance with federal program cash management requirements. Recommendation: We recommend NCHE implement policies and procedures that outline the process for requesting reimbursement in line with 2 CFR 200.305(b)(3). 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. Management Response: Management accepts the finding and recommendation.