Finding Text
Internal Controls over Compliance and Other Matters C. Cash Management – Lack of Documented Procedures Related to Advance Payments U.S. ENVIRONMENTAL PROTECTION AGENCY Geographic Programs - Great Lakes Restoration Initiative – Assistance Listing No. 66.469 Criteria: The federal sub-award grant agreement number 208171 for the EPA Perch Lake Habitat Restoration Project from the State of Minnesota requires Minnesota Land Trust to comply with all federal requirements imposed on the awarded funds, which includes Title 2 U.S. Code of Federal Regulation (CFR) section 200.305. In accordance with 2 CFR section 200.305, a non-federal entity must maintain written procedures that minimize the time elapsing between the transfer of funds and disbursement. Condition: Minnesota Land Trust does not have documented procedures over advance payments that incorporate all the requirements of 2 CFR section 200.305. Cause: Internal controls were not in place to ensure Minnesota Land Trust was aware of the compliance requirements per 2 CFR 200.305 for advance payments. Questioned Costs: None. Effect: Minnesota Land Trust is not in compliance with 2 CFR section 200.305. Context: The federal sub-award grant agreement number 208171 allows for Minnesota Land Trust to request advance payments. Minnesota Land Trust requested and received advance payments related to this project during fiscal year 2023. Recommendation: We recommend that Minnesota Land Trust adopt a written advance payment policy which includes all requirements of 2 CFR section 200.305. Views of Responsible Officials: Minnesota Land Trust agrees with the finding and will adopt a documented advance payment policy consistent with the standards of 2 CFR section 200.305 to use for advance payment requests under federal awards or sub-awards.