Finding 2022-008 Program Affected :66.818 Brownfields Assessment and Cleanup Cooperative Agreements U.S. Environmental Protection Agency Contract year: 2022 Federal Award Identification Number (FAIN): 00A00664 / 00A00676 / 00A00909 Criteria: 2 CFR ?200.434(c) specifies that "services donated or volunteered to the non-Federal entity ... may not be charged to the Federal award either as a direct or indirect cost." Condition and Context: In determining the population of payroll costs to test under the agreement, we determined the Organization charged $47,480 to the federal award related to unpaid volunteer time. The Organization imputed rates ranging from $35 to $50 per hour to volunteer labor and included this as reimbursable costs in billings to the federal agency. In our nonstatistical sample of 18 payroll transactions, we observed that 12 of them related to unpaid volunteers. Cause and Effect: The Organization does not have internal processes to properly identify costs related to the major federal program. The Organization does not have experience related to expending federal awards and did not properly obtain an understanding of what costs are allowable under the federal award. As a result, the Organization charged unallowable costs to the program. Questioned Costs: $47,480 Identification of Repeat Findings: N/A Recommendation: We recommend the Organization implement a tracking system to identify and report all expenditures of federal awards in compliance with the requirements of the Uniform Guidance. We recommend the Organization obtain training for employees and volunteers in order to gain an understanding of what costs are allowable under federal awards. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. See attached Planned Corrective Actions.
Finding 2022-009 Program Affected: 66.818 Brownfields Assessment and Cleanup Cooperative Agreements U.S. Environmental Protection Agency Contract year: 2022 FAIN: 00A00664 / 00A00676 / 00A00909 Criteria: 2 CFR ?200.318(c) specifies that "the non-Federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts." Condition and Context: During the test of the Organization's procurement, suspension, and debarment requirements, the Organization was not able to provide a written procurement policy. The Organization did not maintain a written policy related to procurement of goods and services related to the federal program which prohibits conflicts of interest and governs the actions of the Organization's employees engaged in the selection, award, and administration of contracts. The Organization did not maintain a written policy providing for disciplinary actions to be applied for related violations. The Organization does not maintain a written policy that requires that procurements incorporate a clear and accurate description of the procurement and identifies all requirements which the offerors must fulfill and other factors to be used in evaluating bids/proposals, and requires the Organization to ensure all prequalified lists are current and include enough qualified sources to ensure open and free competition. Cause and Effect: The Organization does not comply with the requirements of the Uniform Guidance related to written policies. However, we did not identify actual noncompliance with the procurement processes required by the Uniform Guidance. Questioned Costs: N/A Identification of Repeat Findings: N/A Recommendation: We recommend the Organization implement written policies in accordance with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. See attached Planned Corrective Actions.
Finding 2022-010 Program Affected: 66.818 Brownfields Assessment and Cleanup Cooperative Agreements U.S. Environmental Protection Agency Contract year: 2022 FAIN: 00A00664 / 00A00676 / 00A00909 Criteria: 2 CFR ?200.430(i) specifies that "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated..." Condition and Context: The Organization did not maintain documentation of what program the employee or the paid consultant expended time and effort on, and therefore was charging an estimated amount of time to the federal program that is not directly supported by a timecard or invoices. Additionally, the rate charged was not directly calculated based on the rate that the employee and the consultant were paid, but rather the Organization billed the federal program for an estimate which approximated the rate they were paid. During our nonstatistical sampling of costs, we noted 6 of 6 transactions tested were not properly supported. Cause and Effect: The Organization does not have internal processes to properly document and retain records which would appropriately support the amounts charged to the federal grant. The Organization does not have processes in place to properly document and retain the review of the calculation of billings charged to the federal grant. As a result, the Organization would not be able to properly identify unallowable costs charged to the major federal program. Questioned Costs :N/A Identification of Repeat Findings N/A Recommendation : We recommend the Organization bill the major federal program based on actual hours and rates charged by employees and contractors. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. See attached Planned Corrective Actions.
Finding 2022-011 Program Affected: 66.818 Brownfields Assessment and Cleanup Cooperative Agreements U.S. Environmental Protection Agency Contract year: 2022 FAIN: 00A00664 / 00A00676 / 00A00909 Criteria: The federal compliance supplement allows a de minimis indirect cost rate of 10% which may be applied by organizations which do not have a negotiated indirect cost rate. However, the contract for the major federal program specifies that the Organization may only use "5% of the amount of federal funding for this cooperative agreement for administrative costs, including indirect costs." Condition and Context: During the test of the allowable costs, indirect costs were compared to the amount allowed under the contracts. The Organization did not apply either the indirect cost rate allowed under the contract, nor did it apply the indirect cost rate to the appropriate cost basis when calculating indirect costs to charge to the federal program. Cause and Effect: The Organization does not have internal processes to properly identify costs related to the program. However, we did not identify indirect costs charged in excess of the allowable amount as specified in the contract as a result of our testing. The indirect cost charged to the federal grant by the Organization was determined to be less than was allowable under the contract. Questioned Costs: N/A Identification of Repeat Findings: N/A Recommendation: We recommend the Organization update its policies to calculate indirect costs based on the contractually allowed basis and using rates as specified in its federal contracts. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. See attached Planned Corrective Actions. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. See attached Planned Corrective Actions.
Finding 2022-012 Program Affected: 66.818 Brownfields Assessment and Cleanup Cooperative Agreements U.S. Environmental Protection Agency Contract year: 2022 FAIN: 00A00664 / 00A00676 / 00A00909 Criteria: 2 CFR ?180.300 mandates that when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. Condition and Context: The Organization did perform a verification that its vendors were not included on the Excluded Parties List System maintained by the General Services Administration. During our nonstatistical sampling of vendors, we noted 2 of 2 vendors tested were not verified against the Excluded Parties List System. Cause and Effect: The Organization does not have internal processes to properly identify excluded parties not eligible to receive federal funds. However, our sample did not identify unallowable costs charged to the grant related to excluded parties. Questioned Costs: N/A Identification of Repeat Findings: N/A Recommendation: We recommend the Organization update its policies and procedures to require confirmation that all vendors are eligible to receive federal funds. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. See attached Planned Corrective Actions.
Finding 2022-013 Program Affected: 66.818 Brownfields Assessment and Cleanup Cooperative Agreements U.S. Environmental Protection Agency Contract year: 2022 FAIN: 00A00664 / 00A00676 / 00A00909 Criteria: According to 2 CFR ?200.303, the Organization must "establish and maintain effective internal control over the Federal award . . ." Condition and Context: During the test of allowable costs, it was determined that invoices were not approved. See Finding 2022-004 for additional information. Cause and Effect: See Finding 2022-004 Questioned Costs: N/A Identification of Repeat Findings: N/A Recommendation: See Finding 2022-004 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. See attached Planned Corrective Actions.
Finding 2022-008 Program Affected :66.818 Brownfields Assessment and Cleanup Cooperative Agreements U.S. Environmental Protection Agency Contract year: 2022 Federal Award Identification Number (FAIN): 00A00664 / 00A00676 / 00A00909 Criteria: 2 CFR ?200.434(c) specifies that "services donated or volunteered to the non-Federal entity ... may not be charged to the Federal award either as a direct or indirect cost." Condition and Context: In determining the population of payroll costs to test under the agreement, we determined the Organization charged $47,480 to the federal award related to unpaid volunteer time. The Organization imputed rates ranging from $35 to $50 per hour to volunteer labor and included this as reimbursable costs in billings to the federal agency. In our nonstatistical sample of 18 payroll transactions, we observed that 12 of them related to unpaid volunteers. Cause and Effect: The Organization does not have internal processes to properly identify costs related to the major federal program. The Organization does not have experience related to expending federal awards and did not properly obtain an understanding of what costs are allowable under the federal award. As a result, the Organization charged unallowable costs to the program. Questioned Costs: $47,480 Identification of Repeat Findings: N/A Recommendation: We recommend the Organization implement a tracking system to identify and report all expenditures of federal awards in compliance with the requirements of the Uniform Guidance. We recommend the Organization obtain training for employees and volunteers in order to gain an understanding of what costs are allowable under federal awards. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. See attached Planned Corrective Actions.
Finding 2022-009 Program Affected: 66.818 Brownfields Assessment and Cleanup Cooperative Agreements U.S. Environmental Protection Agency Contract year: 2022 FAIN: 00A00664 / 00A00676 / 00A00909 Criteria: 2 CFR ?200.318(c) specifies that "the non-Federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts." Condition and Context: During the test of the Organization's procurement, suspension, and debarment requirements, the Organization was not able to provide a written procurement policy. The Organization did not maintain a written policy related to procurement of goods and services related to the federal program which prohibits conflicts of interest and governs the actions of the Organization's employees engaged in the selection, award, and administration of contracts. The Organization did not maintain a written policy providing for disciplinary actions to be applied for related violations. The Organization does not maintain a written policy that requires that procurements incorporate a clear and accurate description of the procurement and identifies all requirements which the offerors must fulfill and other factors to be used in evaluating bids/proposals, and requires the Organization to ensure all prequalified lists are current and include enough qualified sources to ensure open and free competition. Cause and Effect: The Organization does not comply with the requirements of the Uniform Guidance related to written policies. However, we did not identify actual noncompliance with the procurement processes required by the Uniform Guidance. Questioned Costs: N/A Identification of Repeat Findings: N/A Recommendation: We recommend the Organization implement written policies in accordance with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. See attached Planned Corrective Actions.
Finding 2022-010 Program Affected: 66.818 Brownfields Assessment and Cleanup Cooperative Agreements U.S. Environmental Protection Agency Contract year: 2022 FAIN: 00A00664 / 00A00676 / 00A00909 Criteria: 2 CFR ?200.430(i) specifies that "Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated..." Condition and Context: The Organization did not maintain documentation of what program the employee or the paid consultant expended time and effort on, and therefore was charging an estimated amount of time to the federal program that is not directly supported by a timecard or invoices. Additionally, the rate charged was not directly calculated based on the rate that the employee and the consultant were paid, but rather the Organization billed the federal program for an estimate which approximated the rate they were paid. During our nonstatistical sampling of costs, we noted 6 of 6 transactions tested were not properly supported. Cause and Effect: The Organization does not have internal processes to properly document and retain records which would appropriately support the amounts charged to the federal grant. The Organization does not have processes in place to properly document and retain the review of the calculation of billings charged to the federal grant. As a result, the Organization would not be able to properly identify unallowable costs charged to the major federal program. Questioned Costs :N/A Identification of Repeat Findings N/A Recommendation : We recommend the Organization bill the major federal program based on actual hours and rates charged by employees and contractors. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. See attached Planned Corrective Actions.
Finding 2022-011 Program Affected: 66.818 Brownfields Assessment and Cleanup Cooperative Agreements U.S. Environmental Protection Agency Contract year: 2022 FAIN: 00A00664 / 00A00676 / 00A00909 Criteria: The federal compliance supplement allows a de minimis indirect cost rate of 10% which may be applied by organizations which do not have a negotiated indirect cost rate. However, the contract for the major federal program specifies that the Organization may only use "5% of the amount of federal funding for this cooperative agreement for administrative costs, including indirect costs." Condition and Context: During the test of the allowable costs, indirect costs were compared to the amount allowed under the contracts. The Organization did not apply either the indirect cost rate allowed under the contract, nor did it apply the indirect cost rate to the appropriate cost basis when calculating indirect costs to charge to the federal program. Cause and Effect: The Organization does not have internal processes to properly identify costs related to the program. However, we did not identify indirect costs charged in excess of the allowable amount as specified in the contract as a result of our testing. The indirect cost charged to the federal grant by the Organization was determined to be less than was allowable under the contract. Questioned Costs: N/A Identification of Repeat Findings: N/A Recommendation: We recommend the Organization update its policies to calculate indirect costs based on the contractually allowed basis and using rates as specified in its federal contracts. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. See attached Planned Corrective Actions. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. See attached Planned Corrective Actions.
Finding 2022-012 Program Affected: 66.818 Brownfields Assessment and Cleanup Cooperative Agreements U.S. Environmental Protection Agency Contract year: 2022 FAIN: 00A00664 / 00A00676 / 00A00909 Criteria: 2 CFR ?180.300 mandates that when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. Condition and Context: The Organization did perform a verification that its vendors were not included on the Excluded Parties List System maintained by the General Services Administration. During our nonstatistical sampling of vendors, we noted 2 of 2 vendors tested were not verified against the Excluded Parties List System. Cause and Effect: The Organization does not have internal processes to properly identify excluded parties not eligible to receive federal funds. However, our sample did not identify unallowable costs charged to the grant related to excluded parties. Questioned Costs: N/A Identification of Repeat Findings: N/A Recommendation: We recommend the Organization update its policies and procedures to require confirmation that all vendors are eligible to receive federal funds. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. See attached Planned Corrective Actions.
Finding 2022-013 Program Affected: 66.818 Brownfields Assessment and Cleanup Cooperative Agreements U.S. Environmental Protection Agency Contract year: 2022 FAIN: 00A00664 / 00A00676 / 00A00909 Criteria: According to 2 CFR ?200.303, the Organization must "establish and maintain effective internal control over the Federal award . . ." Condition and Context: During the test of allowable costs, it was determined that invoices were not approved. See Finding 2022-004 for additional information. Cause and Effect: See Finding 2022-004 Questioned Costs: N/A Identification of Repeat Findings: N/A Recommendation: See Finding 2022-004 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. See attached Planned Corrective Actions.