Finding Text
Federal Program: Assistance Listing #93.590 - Community-based Child Abuse Prevention Grant
Program
Assistance Listing #93.912 - Rural Communities Opioid Response Program
Criteria: Non-federal entities must minimize the time elapsing between the transfer of funds from
the US Treasury or pass-through entity and disbursement by the non-federal entity for direct
program or project costs and the proportionate share of allowable indirect costs, whether the
payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or
payment by other means (2 CFR section 200.305(b)).
Condition: Illuminate Colorado has established a policy to time Federal drawdown requests to
ensure that Federal cash on hand is sufficient to be disbursed to third party vendors within 10
days of receipt.
2 out of 49 program disbursements to external vendors were made 79 to 90 days after receipt of
funds for Community-based Child Abuse Prevention Grant program.
32 out of 46 program disbursements to external vendors were made 14 to 186 days after receipt
of funds for Rural Communities Opioid Response program.
Questioned Costs: None.
Cause and Effect: Illuminate Colorado experienced cashflow issues during 2023 resulting in
usage of program receipts for other programs. In addition, vendors utilized for direct Federal
assistance programs were not identified and prioritized for federal drawdown receipts. As a result,
Illuminate Colorado did not minimize the time elapsing between the drawdown and transfer of
funds from the US Treasury and disbursement by the non-federal entity for direct program or
project costs.
Recommendation: Since Illuminate Colorado is a direct recipient of federal program funds, we
recommend Illuminate Colorado identify and pay external vendors participating in this program
within 10 days of receipt of program funds in accordance with its financial policies and procedures.
In addition, non-program cash flow should be increased to allow enough working capital to
disburse program funds to external vendors utilized for this program. Management’s Response: Illuminate Colorado has improved invoicing procedures to ensure
timely submission of invoices across the board to minimize time elapsed between submission of
invoices to funders and reimbursement of those invoices. In addition, Illuminate Colorado has
been seeking increased working capital via a larger line of credit or other sources to address cash
flow issues. Finally, Illuminate Colorado is in process of developing a Standard Operating
Procedure to ensure consistent identification of vendors utilized for direct Federal assistance
programs in order to prioritize payment of those vendors with federal drawdown receipts.