Finding 7614 (2022-003)

Material Weakness
Requirement
C
Questioned Costs
-
Year
2022
Accepted
2024-01-05
Audit: 9980
Auditor: Wipfli LLP

AI Summary

  • Core Issue: The Organization failed to timely remit payments to subrecipients after drawing down cash, leading to a material weakness in internal controls.
  • Impacted Requirements: Non-compliance with cash management regulations (2 CFR section 200.305(b)) due to delays in reviewing subrecipient expenditure documentation.
  • Recommended Follow-up: Implement procedures to manage the timing of subrecipient cash requests and disbursements effectively.

Finding Text

Description: Cash Management for Subrecipient Expenditures Repeat Finding: No Type of Finding: Material weakness in internal controls and material non-compliance with the cash management compliance requirement Questioned Costs: None Major Program: AL # 64.033, VA Supportive Services for Veteran Families Program, #20-OR-430 and #20-OR-430-C3. Condition: During the year ended June 30, 2022, the Organization regularly drew down cash from the Payment Management System (PMS) for subrecipient expenditures but did not remit the related payments to the subrecipients in a timely manner. Review of supporting documentation submitted by subrecipients for their expenditures did not occur prior to drawing down the cash from PMS for the related expenditures. 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 (2 CFR section 200.305(b)). Cause: The Organization did not ensure its service provider was properly managing subrecipient cash requests and disbursements throughout the year and was not consistently reviewing subrecipient expenditure requests in a timely manner. Effect: As a result of the matter identified in the condition paragraph, a material weakness in the Organization’s internal controls over compliance and a material non-compliance exist for the cash management compliance requirement. Recommendation: We recommend the Organization implements procedures to ensure it is properly managing the timing of subrecipient cash requests and disbursements to comply with the cash management requirement. View of responsible officials: Management agrees with the assessment and has committed to a corrective action plan.

Corrective Action Plan

Corrective Action: The lack of timeliness in payouts to SSVF subrecipients was largely due to the transition CAPO underwent in fiscal providers in 2022, and to a lack of sufficient internal staff to adequately manage the SSVF program’s growing fiscal requirements. The amount of SSVF funding CAPO passes through has increased significantly since 2021, and existing staffing was insufficient to assure timely tracking of draws and payments. Since moving to SMJ and hiring a Finance Manager, CAPO has improved the fiscal management of this grant considerably. CAPO is also hiring an Account Specialist to be assigned directly to SSVF invoicing and accounting needs. They will be charged to the VA grant and will work with the SSVF Program Manager and CAPO’s Finance Manager to process invoices, draw funds, and issue payments. Person Responsible: Janet Allanach, Rose Bradshaw, SSVF Program Manager; Shane Melton, Finance Manager. Timing for Implementation: Partially complete/In progress until December 31st, 2023, completion.

Categories

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Cash Management Material Weakness

Other Findings in this Audit

  • 7612 2022-001
    Significant Deficiency
  • 7613 2022-002
    Significant Deficiency
  • 584054 2022-001
    Significant Deficiency
  • 584055 2022-002
    Significant Deficiency
  • 584056 2022-003
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
64.033 Va Supportive Services for Veteran Families Program $2.46M
93.569 Community Services Block Grant $351,180
14.267 Continuum of Care Program $202,740
14.231 Emergency Solutions Grant Program $90,431