Finding 575166 (2024-002)

Criteria - Title 2 CFR 200.305 of the Uniform Guidance requires that program costs be paid with recipient or subrecipient funds before requesting reimbursement from the federal government or pass-through entity. When awards provide for advance payments, recipients must follow procedures to minimize the time between drawdown of funds from the U.S. Treasury and expenditure of funds by the recipient or subrecipient. Condition - During the audit for the year ended September 30, 2024, we noted three instances of reimbursements requested from the pass-through entity for expenditures that were not paid prior to the request. The School subsequently made payments to the vendors in August 2025. Cause - Funds were requested to reimburse for School expenditures that were not paid to vendors. Questioned costs - $7,180. Effect - The School did not minimize the time between the drawdown of funds and the disbursement of funds to the vendors. Recommendation - We recommend that the School should implement adequate policies and procedures to ensure requests for drawdowns are reimbursements of program expenditures and, when the drawdown is an advance payment, the time period between the drawdown of funds and the use of the funds is minimized. Management response - See corrective action plan provided by the Head of School.