2023-002 - Allowable Costs/Cost Principles
Criteria: According to federal regulations, expenditures charged to federal grants must follow the allowable cost principles found in 2 CFR Part 200, subpart E.
Additionally, 2 CFR.200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition: During our testing of federal expenditures, we noted that certain expenses were submitted twice for reimbursement.
Cause: Internal controls surrounding the review and submission of reimbursement requests are not properly implemented to detect and correct errors.
Effect: The Organization submitted duplicate expenditures in two instances.
Questioned Costs: $83,718
Statistical Sampling: Statistical sampling was not used in making sample selections.
Recommendation: We recommend that management of the Organization review internal controls and ensure they are properly designed and implemented to ensure that expenditures are allowable under federal regulations.
Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
2023-003: Allowable Costs/Cost Principles
Criteria: According to federal regulations, expenditures charged to federal grants must follow the allowable cost principles found in 2 CFR Part 200, subpart E.
Additionally, 2 CFR.200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition: During our testing, we noted that expenses submitted on forms for reimbursement were allocated to the wrong budget category line items and did not agree to the underlying accounting records.
Cause: Internal controls surrounding the review and submission of reimbursement requests are not properly implemented to detect and correct errors.
Effect: The costs submitted and reimbursed by the grantors did not agree to the budget categories set forth in the grant agreement, therefore the underlying accounting records were not consistent with what was being reported to the grantors.
Questioned Costs: N/A
Statistical Sampling: Statistical sampling was not used in making sample selections.
Recommendation: We recommend that management of the Organization review internal controls and ensure they are properly designed and implemented to ensure that expenditures are allowable under federal regulations.
Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
2023-004: Subrecipient Monitoring
Criteria: The Code of Federal Regulations 2 CFR 200.332 states that all pass-through entities (PTE) must:
Identify the Award and Applicable Requirements - Clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); (2)all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)).
Evaluate Risk - Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
Monitor - Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: (1) Reviewing financial and programmatic (performance and special reports) required by the PTE. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Condition: The Organization did not clearly communicate the required federal award information and applicable requirements to the subrecipients. The Organization did not evaluate the risk of
non-compliance of the subrecipients in order to identify the appropriate monitoring procedures. Statistical sampling was not used in making sample selections.
Cause: The Organization has not implemented policies or procedures, to the degree necessary, to ensure that federal award monitoring compliance requirements are being met.
Effect: The Organization did not perform adequate monitoring procedures on the subrecipients. Without communication of required information, subrecipients may overspend award amounts or incur unallowable expenses towards the grant.
Questioned Costs: N/A
Statistical Sampling: Statistical sampling was not used in making sample selections.
Recommendation: We recommend that management of the Organization implement policies, procedures, and internal controls to evaluate the subrecipient risk of noncompliance to ensure subrecipients are being appropriately monitored in compliance with federal regulations.
Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
2023-002 - Allowable Costs/Cost Principles
Criteria: According to federal regulations, expenditures charged to federal grants must follow the allowable cost principles found in 2 CFR Part 200, subpart E.
Additionally, 2 CFR.200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition: During our testing of federal expenditures, we noted that certain expenses were submitted twice for reimbursement.
Cause: Internal controls surrounding the review and submission of reimbursement requests are not properly implemented to detect and correct errors.
Effect: The Organization submitted duplicate expenditures in two instances.
Questioned Costs: $83,718
Statistical Sampling: Statistical sampling was not used in making sample selections.
Recommendation: We recommend that management of the Organization review internal controls and ensure they are properly designed and implemented to ensure that expenditures are allowable under federal regulations.
Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
2023-003: Allowable Costs/Cost Principles
Criteria: According to federal regulations, expenditures charged to federal grants must follow the allowable cost principles found in 2 CFR Part 200, subpart E.
Additionally, 2 CFR.200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition: During our testing, we noted that expenses submitted on forms for reimbursement were allocated to the wrong budget category line items and did not agree to the underlying accounting records.
Cause: Internal controls surrounding the review and submission of reimbursement requests are not properly implemented to detect and correct errors.
Effect: The costs submitted and reimbursed by the grantors did not agree to the budget categories set forth in the grant agreement, therefore the underlying accounting records were not consistent with what was being reported to the grantors.
Questioned Costs: N/A
Statistical Sampling: Statistical sampling was not used in making sample selections.
Recommendation: We recommend that management of the Organization review internal controls and ensure they are properly designed and implemented to ensure that expenditures are allowable under federal regulations.
Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
2023-002 - Allowable Costs/Cost Principles
Criteria: According to federal regulations, expenditures charged to federal grants must follow the allowable cost principles found in 2 CFR Part 200, subpart E.
Additionally, 2 CFR.200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition: During our testing of federal expenditures, we noted that certain expenses were submitted twice for reimbursement.
Cause: Internal controls surrounding the review and submission of reimbursement requests are not properly implemented to detect and correct errors.
Effect: The Organization submitted duplicate expenditures in two instances.
Questioned Costs: $83,718
Statistical Sampling: Statistical sampling was not used in making sample selections.
Recommendation: We recommend that management of the Organization review internal controls and ensure they are properly designed and implemented to ensure that expenditures are allowable under federal regulations.
Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
2023-003: Allowable Costs/Cost Principles
Criteria: According to federal regulations, expenditures charged to federal grants must follow the allowable cost principles found in 2 CFR Part 200, subpart E.
Additionally, 2 CFR.200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition: During our testing, we noted that expenses submitted on forms for reimbursement were allocated to the wrong budget category line items and did not agree to the underlying accounting records.
Cause: Internal controls surrounding the review and submission of reimbursement requests are not properly implemented to detect and correct errors.
Effect: The costs submitted and reimbursed by the grantors did not agree to the budget categories set forth in the grant agreement, therefore the underlying accounting records were not consistent with what was being reported to the grantors.
Questioned Costs: N/A
Statistical Sampling: Statistical sampling was not used in making sample selections.
Recommendation: We recommend that management of the Organization review internal controls and ensure they are properly designed and implemented to ensure that expenditures are allowable under federal regulations.
Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
2023-004: Subrecipient Monitoring
Criteria: The Code of Federal Regulations 2 CFR 200.332 states that all pass-through entities (PTE) must:
Identify the Award and Applicable Requirements - Clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); (2)all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)).
Evaluate Risk - Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)).
Monitor - Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: (1) Reviewing financial and programmatic (performance and special reports) required by the PTE. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.
Condition: The Organization did not clearly communicate the required federal award information and applicable requirements to the subrecipients. The Organization did not evaluate the risk of
non-compliance of the subrecipients in order to identify the appropriate monitoring procedures. Statistical sampling was not used in making sample selections.
Cause: The Organization has not implemented policies or procedures, to the degree necessary, to ensure that federal award monitoring compliance requirements are being met.
Effect: The Organization did not perform adequate monitoring procedures on the subrecipients. Without communication of required information, subrecipients may overspend award amounts or incur unallowable expenses towards the grant.
Questioned Costs: N/A
Statistical Sampling: Statistical sampling was not used in making sample selections.
Recommendation: We recommend that management of the Organization implement policies, procedures, and internal controls to evaluate the subrecipient risk of noncompliance to ensure subrecipients are being appropriately monitored in compliance with federal regulations.
Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
2023-002 - Allowable Costs/Cost Principles
Criteria: According to federal regulations, expenditures charged to federal grants must follow the allowable cost principles found in 2 CFR Part 200, subpart E.
Additionally, 2 CFR.200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition: During our testing of federal expenditures, we noted that certain expenses were submitted twice for reimbursement.
Cause: Internal controls surrounding the review and submission of reimbursement requests are not properly implemented to detect and correct errors.
Effect: The Organization submitted duplicate expenditures in two instances.
Questioned Costs: $83,718
Statistical Sampling: Statistical sampling was not used in making sample selections.
Recommendation: We recommend that management of the Organization review internal controls and ensure they are properly designed and implemented to ensure that expenditures are allowable under federal regulations.
Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
2023-003: Allowable Costs/Cost Principles
Criteria: According to federal regulations, expenditures charged to federal grants must follow the allowable cost principles found in 2 CFR Part 200, subpart E.
Additionally, 2 CFR.200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition: During our testing, we noted that expenses submitted on forms for reimbursement were allocated to the wrong budget category line items and did not agree to the underlying accounting records.
Cause: Internal controls surrounding the review and submission of reimbursement requests are not properly implemented to detect and correct errors.
Effect: The costs submitted and reimbursed by the grantors did not agree to the budget categories set forth in the grant agreement, therefore the underlying accounting records were not consistent with what was being reported to the grantors.
Questioned Costs: N/A
Statistical Sampling: Statistical sampling was not used in making sample selections.
Recommendation: We recommend that management of the Organization review internal controls and ensure they are properly designed and implemented to ensure that expenditures are allowable under federal regulations.
Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.