Finding Text
FINDING 2023-002
Program Information: Substance Abuse and Mental Health Services Projects (ALN #93.243)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): C. Cash Management – When the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR 200.305(b)(3).
M. Subrecipient Monitoring - Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved (2 CFR 200.332(d).
Condition: The Organization mistakenly disbursed grant funds to an incorrect local club in fiscal year 2022, resulting in untimely payment of pass-through funds to the correct local club and insufficient subrecipient monitoring over subawards.
Cause: Administrative oversight with respect to subrecipient monitoring and cash management.
Effect or Potential Effect: The Organization did not ensure the incorrect local club used the subaward for authorized purposes. The Organization did not make timely payment of pass-through funds within 30 days to the correct club.
Questioned Costs: Below reportable threshold.
Context: The Organization mistakenly disbursed grant funds to an incorrect local club in fiscal year 2022. This club did not incur expenditures in the period of reimbursement, indicating insufficient subrecipient monitoring over subawards. As the Organization did not disburse the funds to the correct club until February 2024, they did not make appropriate payment within 30 calendar days after receipt of the billing as required at 2 CFR 300.305(b)(3).
Identification as a Repeat Finding: No similar findings noted in the prior year.
Recommendation: We recommend that the Organization enhance its procedures and internal controls with respect to monitoring over subrecipient activities and reimbursement payments.
Views of Responsible Officials and Planned Corrective Actions: The Organization will enhance its procedures and internal controls with respect to monitoring subrecipient activities, and reimbursement payments, by working with the State of Montana grantor to ensure local clubs are using subawards for authorized purposes.