Finding number: 2022-003: Allowable Costs/Cost Principles, Period of Performance and
Subreceipient Monitoring, Research & Development Cluster
Criteria: Per Part 6 of the Compliance Supplement, controls need to be designed such that
they would prevent or detect potential noncompliance. Management should
implement control activities through policies.
Condition: ABS Institute does not have documented policies regarding the process and
controls in place surrounding the methodology utilized to allocate costs to grants.
ABS Institute does not have documented policies regarding the process and
controls in place surrounding documenting title, job description and pay rate for
employees.
ABS Institute does not have documented policies regarding the process and
controls in place surrounding the review and approval of credit card purchases
and any other purchases/payments made outside of bill.com system.
ABS Institute does not have documented policies regarding the process and
controls in place surrounding the review and approval of accrued expenses
included in the Schedule of Expenditures of Federal Awards.
ABS Institute does not have documented policies regarding the process and
controls in place surrounding subrecipient monitoring.
Cause: ABS Institute was recently formed, so documentation and implementation of
processes is still in process.
Effect or potential
effect:
Possibility of unallowable costs allocated to grants.
Possibility of grant funds drawn down without documentation to support costs
incurred.
Possibility of subrecipient expending federal funds for unallowable costs. Identification as a
repeat finding:
This is a repeat finding from the immediate previous audits, 2021-003 and 2020-
001.
Recommendation: We recommend that ABS Institute document policies regarding the process and
controls in place related to the areas as noted above.
Views of responsible
official:
ABS Institute is in the process of putting in place the appropriate documentation
with a proposed completion
Finding number: 2022-004: Allowable Costs/Cost Principles, Research & Development
Cluster
Criteria: Per Part 3 of the Compliance Supplement, charges to Federal awards for salaries
and wages must be based on records that accurately reflect the work performed.
These records must: (i) Be supported by a system of internal control which
provides reasonable assurance that the charges are accurate, allowable, and
properly allocated (ii) Be incorporated into the official records of the non-Federal
entity.
Condition: ABS Institute was unable to provide support documenting title, job description
and pay rate for multiple employees.
Cause: Documentation of title, job description and pay rate was not maintained.
Effect or potential
effect:
Possibility of unallowable costs allocated to grants.
Identification as a
repeat finding:
This is a repeat finding from the immediate previous audits, 2021-004 and 2020-
003.
Recommendation: We recommend that ABS Institute retain documentation to support employee’s
title, job description and pay rate.
Views of responsible
official:
ABS Institute has made the following changes in response to this finding:
In connection with pay increases that were completed in January 2023, we put in
place written documentation for each employee related to their title and pay rate.
In addition, all employees hired in 2022 and 2023 have an executed offer letter
Finding number: 2022-005: Allowable Costs/Cost Principles, Research & Development
Cluster
Criteria: Per Part 3 of the Compliance Supplement, for costs that are being allocated, costs
must be allocated uniformly across all programs.
Condition: ABS Institute utilizes cost allocation memorandums to allocate costs to the grant.
Several months of non-payroll costs were not allocated to programs in line with
ABS Institute's cost allocation memorandums. Cause: ABS Institute does not have a formal review process in place to ensure all
allocations are appropriately applied.
Effect or potential
effect:
Possibility of unallowable costs allocated to grants.
Identification as a
repeat finding:
This is a repeat finding from the immediate previous audit, 2021-005.
Recommendation: We recommend that ABS Institute implement a formal review policy to ensure
that non-payroll costs are allocated in line with cost allocation memorandums.
Views of responsible
official:
ABS Institute has made the following changes in response to this finding:
On a monthly basis, the allocations are provided to ABS Institute from our 3rd
party bookkeeper. The allocation process does not change from month-to-month.
On an adhoc basis, a review of the monthly allocations was completed in 2023.
Finding number: 2022-003: Allowable Costs/Cost Principles, Period of Performance and
Subreceipient Monitoring, Research & Development Cluster
Criteria: Per Part 6 of the Compliance Supplement, controls need to be designed such that
they would prevent or detect potential noncompliance. Management should
implement control activities through policies.
Condition: ABS Institute does not have documented policies regarding the process and
controls in place surrounding the methodology utilized to allocate costs to grants.
ABS Institute does not have documented policies regarding the process and
controls in place surrounding documenting title, job description and pay rate for
employees.
ABS Institute does not have documented policies regarding the process and
controls in place surrounding the review and approval of credit card purchases
and any other purchases/payments made outside of bill.com system.
ABS Institute does not have documented policies regarding the process and
controls in place surrounding the review and approval of accrued expenses
included in the Schedule of Expenditures of Federal Awards.
ABS Institute does not have documented policies regarding the process and
controls in place surrounding subrecipient monitoring.
Cause: ABS Institute was recently formed, so documentation and implementation of
processes is still in process.
Effect or potential
effect:
Possibility of unallowable costs allocated to grants.
Possibility of grant funds drawn down without documentation to support costs
incurred.
Possibility of subrecipient expending federal funds for unallowable costs. Identification as a
repeat finding:
This is a repeat finding from the immediate previous audits, 2021-003 and 2020-
001.
Recommendation: We recommend that ABS Institute document policies regarding the process and
controls in place related to the areas as noted above.
Views of responsible
official:
ABS Institute is in the process of putting in place the appropriate documentation
with a proposed completion
Finding number: 2022-004: Allowable Costs/Cost Principles, Research & Development
Cluster
Criteria: Per Part 3 of the Compliance Supplement, charges to Federal awards for salaries
and wages must be based on records that accurately reflect the work performed.
These records must: (i) Be supported by a system of internal control which
provides reasonable assurance that the charges are accurate, allowable, and
properly allocated (ii) Be incorporated into the official records of the non-Federal
entity.
Condition: ABS Institute was unable to provide support documenting title, job description
and pay rate for multiple employees.
Cause: Documentation of title, job description and pay rate was not maintained.
Effect or potential
effect:
Possibility of unallowable costs allocated to grants.
Identification as a
repeat finding:
This is a repeat finding from the immediate previous audits, 2021-004 and 2020-
003.
Recommendation: We recommend that ABS Institute retain documentation to support employee’s
title, job description and pay rate.
Views of responsible
official:
ABS Institute has made the following changes in response to this finding:
In connection with pay increases that were completed in January 2023, we put in
place written documentation for each employee related to their title and pay rate.
In addition, all employees hired in 2022 and 2023 have an executed offer letter
Finding number: 2022-005: Allowable Costs/Cost Principles, Research & Development
Cluster
Criteria: Per Part 3 of the Compliance Supplement, for costs that are being allocated, costs
must be allocated uniformly across all programs.
Condition: ABS Institute utilizes cost allocation memorandums to allocate costs to the grant.
Several months of non-payroll costs were not allocated to programs in line with
ABS Institute's cost allocation memorandums. Cause: ABS Institute does not have a formal review process in place to ensure all
allocations are appropriately applied.
Effect or potential
effect:
Possibility of unallowable costs allocated to grants.
Identification as a
repeat finding:
This is a repeat finding from the immediate previous audit, 2021-005.
Recommendation: We recommend that ABS Institute implement a formal review policy to ensure
that non-payroll costs are allocated in line with cost allocation memorandums.
Views of responsible
official:
ABS Institute has made the following changes in response to this finding:
On a monthly basis, the allocations are provided to ABS Institute from our 3rd
party bookkeeper. The allocation process does not change from month-to-month.
On an adhoc basis, a review of the monthly allocations was completed in 2023.