Finding Text
Program Information: COVID-19 Elementary and Secondary School Emergency Relief Fund (84.425U)
Criteria or Specific Requirement (Including Statutory, Regulatory
or Other Citation): C. Cash Management - In accordance with 2 CFR 200.305(b)(1), non-Federal entities must utilize payment methods that minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity; the non-Federal entity must make timely payment to contractors in accordance with the contract provisions.
Condition: For 12 of 38 transfers of Federal funds for selected testing, the subsequent pass through disbursement to the subrecipients exceeded 30 days.
Cause: The Organization does not have sufficient controls in place to ensure that pass through disbursements are made within 30 days of receipt of federal funds.
Effect or Potential Effect: The Organization was not in compliance with cash management requirements.
Questioned Costs: None.
Context: The Organization received federal funds to pass through to subrecipients, however the pass throughs occurred greater than 30 days after the Organization’s receipt of the federal funds. The Organization did ultimately pass the funds through to the subrecipients.
Identification as a Repeat Finding: No similar findings were identified in the prior year.
Recommendation: We recommend the Organization enhance its procedures and internal controls to ensure that time between receipt of federal funds and payment to its local clubs is minimized.
Views of Responsible Officials and Planned Corrective Actions: The Alliance will enhance its procedures and internal controls around cash management to ensure that time between receipt of federal funds and payment to its local clubs is minimized. The Alliance will also request notification of funding from the agency.