Finding 522136 (2024-001)

Significant Deficiency
Requirement
C
Questioned Costs
-
Year
2024
Accepted
2025-02-05

AI Summary

  • Core Issue: Delays in disbursing federal funds to subrecipients, violating federal payment requirements.
  • Impacted Requirements: Noncompliance with 2 CFR 200.305 regarding timely payments within 30 days of billing.
  • Recommended Follow-up: Review and improve procedures to ensure compliance with payment timelines and collaborate with the State for timely reimbursements.

Finding Text

Assistance Listing, Federal Agency, and Program Name - 93.566, U.S. Department of Health and Human Services, Refugee and Entrant Assistance State/ Replacement Designee Administered Programs Federal Award Identification Number and Year - FCSAK00843 2024 Pass-through Entity - Illinois Department of Human Services Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - No Criteria - In accordance with 2 CFR 200.305 2(b), for nonfederal entities other than states, payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass through entity and the disbursement by the nonfederal entity whether the payment is made by electronic funds transfers or issuance or redemption of checks, warrants, or payments by other means. In accordance with 2 CFR 200.305(3), when the reimbursement method is used, the federal awarding agency or pass through entity must make payment within 30 calendar days after receipt of billing, unless it is believed the request to be improper. Condition - Controls in place did not minimize the time elapsing between the transfer receipt of billing from the subrecipient and disbursement of federal dollars to the subrecipient in accordance with the guidance above. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable as there are no questioned costs. Context - Of the four transactions tested, none of the subrecipients were paid within 30 days of receipt of billing. Cause and Effect - Policies, procedures, and related internal internal controls did not ensure compliance with federal payment requirements under Uniform Guidance. Recommendation - We recommend the Federation review its procedures and controls to ensure disbursement of funds to its subrecipients is consistent with applicable laws and regulations. Views of Responsible Officials and Corrective Action Plan - As a pass through recipient, the Federation relies on the timeliness of the State for reimbursement. In all transactions tested, the Federation reimbursed the subrecipients within 30 days of receipt of funds from the State. However, as a pass through entity the Federation understands the requirement to reimburse subrecipients within 30 calendar days after receipt of a billing. The Federation will work with the State to address the time elapsed.

Corrective Action Plan

Identifying Number: 2024-001 Condition: Controls in place did not minimize the time elapsing between the transfer receipt of billing from the subrecipient and disbursement of federal dollars to the subrecipient in accordance with the guidance above. Corrective Actions Taken or Planned: Federation typically receives vouchers from 14 subrecipient organizations approximately ten days after the end of each month. The number of vouchers per agency depends on the number of programs they provide. Staff reviews the vouchers for allowability and accuracy and submits them to the Illinois Department of Human Services (IDHS) within 24 days of month end. During fiscal year 2024, the IDHS remitted payment to Federation anywhere from 48 to 124 days after the month end. Upon receipt of the cash, Federation pays subrecipient organizations within thirty days. In the instances identified by the auditors, the IDHS remitted payment over 30 days after Federation submitted the vouchers for reimbursement. Federation’s longstanding policy has always been to reimburse each subrecipient agency after it has received payment from the IDHS. Prior to fiscal year 2024, the IDHS usually provided payment within 15 days of receipt of our voucher and therefore Federation was able to comply with the 30-day requirement. However, reimbursement delays from IDHS occurred during fiscal year 2024 resulting in the findings describe herein. To ensure compliance with the 30-day reimbursement requirement, Federation will formally request an advance from the IDHS. Kyu Kim, Director of Finance and Contract Compliance, Refugee Services will be responsible for the oversight of the reimbursement payments and will ensure the Federation adheres to the 30 day requirement going forward. Responsible Person: Kyu Kim Anticipated Completion Date: July 2025

Categories

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Cash Management Significant Deficiency

Other Findings in this Audit

  • 1098578 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $820,132