GRASSROOTS CRISIS INTERVENTION CENTER, INC.Non-Profit

Finding 2020-001 Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: Howard County Health Department Program Title: Opioid STR CFDA Number: 93.788 Federal Award Period: September 30, 2019 through June 30, 2020 Compliance Requirement: Cash Management Type of Finding: Material Noncompliance and Material Weakness Criteria: In accordance with 2 CFR part 200.305 (Payment), the non-federal entity may be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures to minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement by the non-federal entity, and maintains a financial management system that meets the standards for fund control and accountability. Furthermore, the non-federal entity must maintain the advance payments in an interest-bearing account. 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. 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. Condition: During the year ended June 30, 2020, management did not review draw-downs to ensure that amounts requested minimize the time elapsing between the transfer of funds from pass-through entity and program disbursements. The advances received during the year were based on budgeted quarterly amounts and were not supported by documentation of the cash requirement needs resulting in material refunds of federal awards for the periods ending September 29, 2019 and June 30, 2020. This also led to material amounts of unused funds on hand/liability during the period September 30, 2019 through June 30, 2020. Questioned Costs: None identified. Cause: The Organization did not have adequate written procedures or internal controls in place regarding the compliance requirements specified in 2 CFR part 200.305. Effect: The Organization has not complied with the specific requirements over cash management as described in the Uniform Guidance. Recommendations: We recommend the Organization maintain adequate written procedures and internal controls in place as well as prepare a spreadsheet to document the anticipated immediate cash needs to avoid requesting excess advances during the award period. Views of Responsible Official and Planned Corrective Action: Management agrees with the auditor?s findings and recommendations. Starting in fiscal year 2021, the Organization is getting reimbursed for the actual expenditures for the program instead of receiving advances from the pass-through agency.