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.