Finding 2024-004 – Cash Collateralization (Repeat Finding 2023-003)
Condition:
During our review of the Coalition’s cash, it was noted that as of September 30, 2024, they have.
not collateralized cash balances more than the amounts insured by the Federal Despot
Insurance Corporation. Cash balances of $7,596,383 were uninsured at September 30, 2024.
Unearned revenue was reported at approximately $4,434,584 which includes advance payments of Federal Funds.
Corrective Action Plan – Finding 2024-004
Corrective Action:
In response to the finding regarding the lack of collateralization for cash balances exceeding the amounts insured by the Federal Deposit Insurance Corporation (FDIC), the Nebraska Urban Indian Health Coalition (NUIHC) acknowledges that corrective actions were initially delayed due to the illness and eventual retirement of the former CEO. However, under new leadership, these actions have since been fully implemented.
As of April 2025, NUIHC is in full compliance with the cash collateralization requirements outlined in 2 CFR §200.305(b)(7). A formal cash collateralization agreement has been executed with our financial institutions, ensuring that all cash balances—including advanced federal funds—are now either insured or properly collateralized.
In addition to entering into this agreement, the following measures are in the process to strengthen ongoing compliance:
1. Updated Cash Management Policies:
Policies are being reviewed and revised to reflect current federal requirements and internal procedures regarding custodial credit risk and cash handling practices.
2. Monitoring and Compliance Controls:
A monitoring system is in place to routinely review cash balances and coordinate with our financial institution to ensure all funds remain protected.
3. Staff Training:
Targeted training was provided to financial and accounting staff to ensure continued understanding of cash collateralization requirements and the importance of ongoing compliance.
Implementation Summary:
• Cash Collateralization Agreement: Completed – April 2025
• Policy Revisions and Monitoring System: In process– July 2025
• Staff Training: Completed by – August 2025
Responsible Party: Chief Financial Officer, Carlett Gregory