Finding Text
Finding 2022-002 ? Cash Management ? Pass-through Entities Identification of the federal program U.S. Department of Defense U.S. Department of Health and Human Services Research and Development Cluster All Assistance Listing Nos. with amounts provided to subrecipients ? 12.420, 93.242, 93.279, 93.351, 93.855, and 93.866 Federal Award Numbers Grant Period 5R01AI123047-05 8/15/2017-7/31/2022 1R56AG073316-01 9/01/2021-8/31/2023 W81XWH1910496 5/01/2020-10/31/2023 1R01MH130193-01 4/05/2022-2/28/2023 7R01MH116844-04 7/01/2020-1/31/2022 R01MH116844-05 2/01/2022-1/31/2024 5R01DA052845-03 7/01/2022-6/30/2023 5R01DA052845-02 7/01/2021-6/30/2022 2P51OD011133-23 5/01/2021-4/30/2022 2P51OD011133-18 5/01/2016-4/30/2017 5U42OD010442-21 2/01/2022-1/31/2023 5P51OD011133-24 5/01/2022-4/30/2023 5R21AI150445-02 2/01/2021-1/31/2024 5R01AI138587-05 5/01/2022-4/30/2023 5R01AI136831-04 8/01/2022-7/31/2023 5R01AI138587-04 5/01/2021-4/30/2022 5R01AI134245-05 2/01/2022-4/30/2023 1P30AI168439-01 3/10/2022-2/28/2023 5R01AI123047-05 8/01/2020-7/31/2022 7R01AI134245-05 9/01/2021-4/30/2022 5U34AG068482-03 6/01/2022-5/31/2022 U34AG068482 6/01/2021-5/31/2022 5P01AG051428-05 3/01/2020-2/28/2022 1R56AG073316-01 9/01/2021-8/31/2023 5R01AG065546-03 6/01/2022-5/31/2023 1R01AG065546-02 6/01/2021-5/31/2022 Criteria or specific requirement (including statutory, regulatory, or other citation) 2 CFR 200.303(a) requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR 200.305(b)(1) requires ?The non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part. Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non-Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions.? 2 CFR 200.305(b)(3) requires ?when the reimbursement method is used, the Federal agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper.? Condition Texas Biomed did not provide evidence of effectively designed internal controls to ensure subrecipients are paid by Texas Biomed within 30 days of requests for reimbursement received by Texas Biomed. Texas Biomed paid 2 of 23 subrecipients after 30 days of receipt of the request for reimbursement from the subrecipient, resulting in noncompliance with 2 CFR 200.305(b)(3). Cause Texas Biomed?s internal controls around payments to subrecipients were not precisely designed to ensure the issuance of payments to subrecipients occurs within 30 days of requests for reimbursement by the subrecipient. Effect or potential effect Texas Biomed did not comply with the cash management requirements of the Uniform Guidance to pay subrecipients within 30 days of their requests for reimbursement. Questioned costs None. Context For 2 of 23 subrecipient payments, Texas Biomed made payments to subrecipients at 50 and 41 days after receipt of the requests for reimbursement. These payments were not made in accordance with the 30-day requirement (5R01AI123047-05 and 1R56AG073316-01). For 1 additional subrecipient payment, we noted approval by the principal investigator of the subrecipient?s request for reimbursement was made after the payment was made to the subrecipient (5R01AI123047-05). Texas Biomed?s subrecipient expenditures totaled $2.0 million during the period, which represented 5.2% of Texas Biomed?s total research and development expenditures of $38.1 million. Identification as a repeat finding, if applicable This is not a repeat finding. Recommendation We recommend Texas Biomed design and implement internal controls with the required precision to ensure subrecipients are paid within 30 days of the receipt of requests for reimbursement from the subrecipient and approved by the principal investigator prior to paying the subrecipient. Views of responsible officials Texas Biomed will implement a more effective operating procedure for subrecipient invoice approval and timely payment that will include timeline expectations for the initial approval request to the applicable principal investigator upon receipt of invoices from the subrecipient, timeline for following-up with the principal investigator on approval requests, timeline and direction for seeking proxy approval if the principal investigator is unavailable or unable to provide a timely response, and timeline for entering the subrecipient invoice in Texas Biomed financial systems facilitating payment upon approval. Texas Biomed will implement corrective action on June 1, 2023.