Finding Text
2023-003 – Cash Management Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Number: 93.391Assistance Listing Name: Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Pass-through Awards under the Uniform Guidance Requirements: Criteria – CFR § 200.305 Federal payment. section (b) states that, " For Non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means.” Further, “The timing and amount of advance payments must be as close as 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,” and “To the extent available, the non-Federal entity must disburse funds available from program income (including repayments to a revolving fund), rebates, refunds, contract settlements, audit recoveries and interest earned on such funds before requesting additional cash payments. Condition – During our testing of payments received from the Ohio Department of Health, we noted that ODH funded $300,000 to the Organization, however, costs incurred through July 30, 2023 were approximately $195,000 per the SEFA. Management was unable to support the difference between total expenditures reported in the GMIS YTD June Report to the amounts reported in the SEFA, and therefore, it is unknown if the costs were incurred prior to requesting additional cash payments. Cause – United Way of Greater Cleveland does not have policies or procedures that address minimizing the time between receipt funds from the Ohio Department of Health and disbursement for programmatic expenses. Effect – United Way of Greater Cleveland is not in compliance with the provisions of CFR 200.305, in that, the Organization did not adhere to requirements to minimize the time elapsing between the transfer of funds and disbursement by the recipient, or that funds were disbursed prior to requesting additional cash payments. Questioned Costs – None Context – We sampled 7 cash receipts for the OHIZ program, noting a total of $300,000 received under the program as compared to expenditures of approximately $195,000, for which there were no policies or procedures to minimize the time elapsing between receipt and disbursement of such funds. Repeat Finding – This is not a repeat finding. Recommendation – We recommend that United Way of Greater Cleveland draft formal policies and procedures whereby federal funds received in advance of the expenditure are segregated and expended in a manner to minimize the time between date of receipt and date of disbursement. Views of Responsible Officials -