Criteria – 2 CFR §200.430(g) – Standards for Documentation of Personnel Expenses require that charges
to federal awards for salaries and wages must be based on records that accurately reflect the work
performed and are supported by a system of internal control which provides reasonable assurance that
charges are accurate, allowable, and properly allocated. Estimates determined before services are
performed do not qualify as support.
Condition/context – A sample of 9 payroll expenditures was selected for testing. The total population of
payroll expenditures charged to the food distribution cluster grants was $1,396,059. For all 9 selections,
the Organization was unable to provide evidence of actual time spent on each grant. The Organization
allocates personnel expenses to federal awards using estimates, not records that accurately reflect the
work performed. The Organization estimates how much time each employee spends on activities
allowable for each grant, but these estimates are not supported by records that reflect the work
performed. The Organization has an electronic timekeeping system, but the system does not track the
activities an employee performs. Employees are not required to complete certifications or Personnel
Activity Reports (PARs) to support the hours worked on allowable activities.
Our sample was not, and was not intended to be, statistically valid.
Questioned costs – ALN 10.565 - $8,192, ALN 10.568 - $1,323,021, ALN 10.182 - $64,846
Total questioned costs for all programs – $1,396,059, which is the total payroll expenditures charged to
the food distribution cluster grants.
Cause/effect – The Organization has not developed a system of internal control which provides
reasonable assurance that charges are accurate, allowable, and properly allocated. Personnel expenses
charged to federal awards are not supported by records that reflect the work performed.
Repeat finding – No.
Recommendation – We recommend the Organization establish a system of time and effort reporting that
meets the standards for documentation of personnel expenses, and a system of internal control that
provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Criteria – 2 CFR §200.430(g) – Standards for Documentation of Personnel Expenses require that charges
to federal awards for salaries and wages must be based on records that accurately reflect the work
performed and are supported by a system of internal control which provides reasonable assurance that
charges are accurate, allowable, and properly allocated. Estimates determined before services are
performed do not qualify as support.
Condition/context – A sample of 9 payroll expenditures was selected for testing. The total population of
payroll expenditures charged to the food distribution cluster grants was $1,396,059. For all 9 selections,
the Organization was unable to provide evidence of actual time spent on each grant. The Organization
allocates personnel expenses to federal awards using estimates, not records that accurately reflect the
work performed. The Organization estimates how much time each employee spends on activities
allowable for each grant, but these estimates are not supported by records that reflect the work
performed. The Organization has an electronic timekeeping system, but the system does not track the
activities an employee performs. Employees are not required to complete certifications or Personnel
Activity Reports (PARs) to support the hours worked on allowable activities.
Our sample was not, and was not intended to be, statistically valid.
Questioned costs – ALN 10.565 - $8,192, ALN 10.568 - $1,323,021, ALN 10.182 - $64,846
Total questioned costs for all programs – $1,396,059, which is the total payroll expenditures charged to
the food distribution cluster grants.
Cause/effect – The Organization has not developed a system of internal control which provides
reasonable assurance that charges are accurate, allowable, and properly allocated. Personnel expenses
charged to federal awards are not supported by records that reflect the work performed.
Repeat finding – No.
Recommendation – We recommend the Organization establish a system of time and effort reporting that
meets the standards for documentation of personnel expenses, and a system of internal control that
provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Criteria – 2 CFR §200.430(g) – Standards for Documentation of Personnel Expenses require that charges
to federal awards for salaries and wages must be based on records that accurately reflect the work
performed and are supported by a system of internal control which provides reasonable assurance that
charges are accurate, allowable, and properly allocated. Estimates determined before services are
performed do not qualify as support.
Condition/context – A sample of 9 payroll expenditures was selected for testing. The total population of
payroll expenditures charged to the food distribution cluster grants was $1,396,059. For all 9 selections,
the Organization was unable to provide evidence of actual time spent on each grant. The Organization
allocates personnel expenses to federal awards using estimates, not records that accurately reflect the
work performed. The Organization estimates how much time each employee spends on activities
allowable for each grant, but these estimates are not supported by records that reflect the work
performed. The Organization has an electronic timekeeping system, but the system does not track the
activities an employee performs. Employees are not required to complete certifications or Personnel
Activity Reports (PARs) to support the hours worked on allowable activities.
Our sample was not, and was not intended to be, statistically valid.
Questioned costs – ALN 10.565 - $8,192, ALN 10.568 - $1,323,021, ALN 10.182 - $64,846
Total questioned costs for all programs – $1,396,059, which is the total payroll expenditures charged to
the food distribution cluster grants.
Cause/effect – The Organization has not developed a system of internal control which provides
reasonable assurance that charges are accurate, allowable, and properly allocated. Personnel expenses
charged to federal awards are not supported by records that reflect the work performed.
Repeat finding – No.
Recommendation – We recommend the Organization establish a system of time and effort reporting that
meets the standards for documentation of personnel expenses, and a system of internal control that
provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Criteria – 2 CFR §200.414 Indirect Costs – Entities must maintain accurate records and apply indirect
costs consistently across all federal awards. They must also ensure that subrecipient indirect costs are
managed in accordance with federal regulations.
Condition/context – Indirect costs are not being requested, applied, billed, or reported consistently by the
Organization. Indirect costs are not being applied to subrecipients consistently.
We observed numerous errors in the application of indirect costs by the Organization, including: not
requesting indirect costs in grant applications, negotiating non-de minimis rates with passthrough
agencies after electing a de minimis rate, billing indirect costs in excess of indirect costs awarded in the
grant agreement, erroneously including passthrough awards greater than $25,000 per subrecipient in the
modified total direct cost base, approving indirect cost rates for subrecipients that did not match the
subrecipient's elected de minimis rate, and including subrecipient indirect costs in the section of SF-425
reports reserved for reporting its own indirect costs.
Questioned costs – $27,467
Cause/effect – The Organization has decentralized grant controls which are not designed to ensure
compliance over indirect costs and consistency of application across all federal awards. Indirect costs in
excess of allowable indirect costs were billed to federal awards.
Repeat finding – No.
Recommendation – The Organization should develop procedures and internal controls to ensure indirect
cost rates are requested, applied, billed, and reported consistently across all federal awards using the
same rate. The Organization should develop similar procedures to ensure it is awarding and reporting
subrecipient indirect costs accurately. The Organization should ensure individuals responsible for these
controls are adequately trained.
Criteria – 2 CFR §200.414 Indirect Costs – Entities must maintain accurate records and apply indirect
costs consistently across all federal awards. They must also ensure that subrecipient indirect costs are
managed in accordance with federal regulations.
Condition/context – Indirect costs are not being requested, applied, billed, or reported consistently by the
Organization. Indirect costs are not being applied to subrecipients consistently.
We observed numerous errors in the application of indirect costs by the Organization, including: not
requesting indirect costs in grant applications, negotiating non-de minimis rates with passthrough
agencies after electing a de minimis rate, billing indirect costs in excess of indirect costs awarded in the
grant agreement, erroneously including passthrough awards greater than $25,000 per subrecipient in the
modified total direct cost base, approving indirect cost rates for subrecipients that did not match the
subrecipient's elected de minimis rate, and including subrecipient indirect costs in the section of SF-425
reports reserved for reporting its own indirect costs.
Questioned costs – $27,467
Cause/effect – The Organization has decentralized grant controls which are not designed to ensure
compliance over indirect costs and consistency of application across all federal awards. Indirect costs in
excess of allowable indirect costs were billed to federal awards.
Repeat finding – No.
Recommendation – The Organization should develop procedures and internal controls to ensure indirect
cost rates are requested, applied, billed, and reported consistently across all federal awards using the
same rate. The Organization should develop similar procedures to ensure it is awarding and reporting
subrecipient indirect costs accurately. The Organization should ensure individuals responsible for these
controls are adequately trained.
Criteria – 2 CFR §200.414 Indirect Costs – Entities must maintain accurate records and apply indirect
costs consistently across all federal awards. They must also ensure that subrecipient indirect costs are
managed in accordance with federal regulations.
Condition/context – Indirect costs are not being requested, applied, billed, or reported consistently by the
Organization. Indirect costs are not being applied to subrecipients consistently.
We observed numerous errors in the application of indirect costs by the Organization, including: not
requesting indirect costs in grant applications, negotiating non-de minimis rates with passthrough
agencies after electing a de minimis rate, billing indirect costs in excess of indirect costs awarded in the
grant agreement, erroneously including passthrough awards greater than $25,000 per subrecipient in the
modified total direct cost base, approving indirect cost rates for subrecipients that did not match the
subrecipient's elected de minimis rate, and including subrecipient indirect costs in the section of SF-425
reports reserved for reporting its own indirect costs.
Questioned costs – $27,467
Cause/effect – The Organization has decentralized grant controls which are not designed to ensure
compliance over indirect costs and consistency of application across all federal awards. Indirect costs in
excess of allowable indirect costs were billed to federal awards.
Repeat finding – No.
Recommendation – The Organization should develop procedures and internal controls to ensure indirect
cost rates are requested, applied, billed, and reported consistently across all federal awards using the
same rate. The Organization should develop similar procedures to ensure it is awarding and reporting
subrecipient indirect costs accurately. The Organization should ensure individuals responsible for these
controls are adequately trained.
Criteria – 2 CFR §200.414 Indirect Costs – Entities must maintain accurate records and apply indirect
costs consistently across all federal awards. They must also ensure that subrecipient indirect costs are
managed in accordance with federal regulations.
Condition/context – Indirect costs are not being requested, applied, billed, or reported consistently by the
Organization. Indirect costs are not being applied to subrecipients consistently.
We observed numerous errors in the application of indirect costs by the Organization, including: not
requesting indirect costs in grant applications, negotiating non-de minimis rates with passthrough
agencies after electing a de minimis rate, billing indirect costs in excess of indirect costs awarded in the
grant agreement, erroneously including passthrough awards greater than $25,000 per subrecipient in the
modified total direct cost base, approving indirect cost rates for subrecipients that did not match the
subrecipient's elected de minimis rate, and including subrecipient indirect costs in the section of SF-425
reports reserved for reporting its own indirect costs.
Questioned costs – $27,467
Cause/effect – The Organization has decentralized grant controls which are not designed to ensure
compliance over indirect costs and consistency of application across all federal awards. Indirect costs in
excess of allowable indirect costs were billed to federal awards.
Repeat finding – No.
Recommendation – The Organization should develop procedures and internal controls to ensure indirect
cost rates are requested, applied, billed, and reported consistently across all federal awards using the
same rate. The Organization should develop similar procedures to ensure it is awarding and reporting
subrecipient indirect costs accurately. The Organization should ensure individuals responsible for these
controls are adequately trained.
Criteria – 2 CFR §200.414 Indirect Costs – Entities must maintain accurate records and apply indirect
costs consistently across all federal awards. They must also ensure that subrecipient indirect costs are
managed in accordance with federal regulations.
Condition/context – Indirect costs are not being requested, applied, billed, or reported consistently by the
Organization. Indirect costs are not being applied to subrecipients consistently.
We observed numerous errors in the application of indirect costs by the Organization, including: not
requesting indirect costs in grant applications, negotiating non-de minimis rates with passthrough
agencies after electing a de minimis rate, billing indirect costs in excess of indirect costs awarded in the
grant agreement, erroneously including passthrough awards greater than $25,000 per subrecipient in the
modified total direct cost base, approving indirect cost rates for subrecipients that did not match the
subrecipient's elected de minimis rate, and including subrecipient indirect costs in the section of SF-425
reports reserved for reporting its own indirect costs.
Questioned costs – $27,467
Cause/effect – The Organization has decentralized grant controls which are not designed to ensure
compliance over indirect costs and consistency of application across all federal awards. Indirect costs in
excess of allowable indirect costs were billed to federal awards.
Repeat finding – No.
Recommendation – The Organization should develop procedures and internal controls to ensure indirect
cost rates are requested, applied, billed, and reported consistently across all federal awards using the
same rate. The Organization should develop similar procedures to ensure it is awarding and reporting
subrecipient indirect costs accurately. The Organization should ensure individuals responsible for these
controls are adequately trained.
Criteria – 2 CFR §200.317 to 327 – Procurement Standards. The recipient or subrecipient must maintain
and use documented procedures for procurement transactions under a Federal award or subaward,
including for acquisition of property or services. These documented procurement procedures must be
consistent with State, local, and tribal laws and regulations and the standards identified in §200.317
through §200.327.
Condition/context – The Organization did not have a procurement policy that complied with Federal
regulations and did not retain documentation as to the significant history of procurements that would show
compliance with the policy.
We observed that the organization awarded contracts to vendors but did not have a procurement policy
that matched Federal procurement standards.
Questioned costs – None reported.
Cause/effect – The Organization did not have policies or controls to ensure compliance with Federal
regulations regarding procurements. Documentation as to the significant history of procurements,
including from vendors, was not available to show compliance with procurement standards.
Repeat finding – Yes, prior year finding 2023-001.
Recommendation – The Organization should develop a procurement policy that matches Federal
procurement standards and internal controls to ensure the policy is followed. The Organization should
also retain documentation as to the significant history of procurements to show that the procurement
policy was followed.
Criteria – 2 CFR §200.317 to 327 – Procurement Standards. The recipient or subrecipient must maintain
and use documented procedures for procurement transactions under a Federal award or subaward,
including for acquisition of property or services. These documented procurement procedures must be
consistent with State, local, and tribal laws and regulations and the standards identified in §200.317
through §200.327.
Condition/context – The Organization did not have a procurement policy that complied with Federal
regulations and did not retain documentation as to the significant history of procurements that would show
compliance with the policy.
We observed that the organization awarded contracts to vendors but did not have a procurement policy
that matched Federal procurement standards.
Questioned costs – None reported.
Cause/effect – The Organization did not have policies or controls to ensure compliance with Federal
regulations regarding procurements. Documentation as to the significant history of procurements,
including from vendors, was not available to show compliance with procurement standards.
Repeat finding – Yes, prior year finding 2023-001.
Recommendation – The Organization should develop a procurement policy that matches Federal
procurement standards and internal controls to ensure the policy is followed. The Organization should
also retain documentation as to the significant history of procurements to show that the procurement
policy was followed.
Criteria – 2 CFR §200.317 to 327 – Procurement Standards. The recipient or subrecipient must maintain
and use documented procedures for procurement transactions under a Federal award or subaward,
including for acquisition of property or services. These documented procurement procedures must be
consistent with State, local, and tribal laws and regulations and the standards identified in §200.317
through §200.327.
Condition/context – The Organization did not have a procurement policy that complied with Federal
regulations and did not retain documentation as to the significant history of procurements that would show
compliance with the policy.
We observed that the organization awarded contracts to vendors but did not have a procurement policy
that matched Federal procurement standards.
Questioned costs – None reported.
Cause/effect – The Organization did not have policies or controls to ensure compliance with Federal
regulations regarding procurements. Documentation as to the significant history of procurements,
including from vendors, was not available to show compliance with procurement standards.
Repeat finding – Yes, prior year finding 2023-001.
Recommendation – The Organization should develop a procurement policy that matches Federal
procurement standards and internal controls to ensure the policy is followed. The Organization should
also retain documentation as to the significant history of procurements to show that the procurement
policy was followed.
Criteria – 2 CFR §200.317 to 327 – Procurement Standards. The recipient or subrecipient must maintain
and use documented procedures for procurement transactions under a Federal award or subaward,
including for acquisition of property or services. These documented procurement procedures must be
consistent with State, local, and tribal laws and regulations and the standards identified in §200.317
through §200.327.
Condition/context – The Organization did not have a procurement policy that complied with Federal
regulations and did not retain documentation as to the significant history of procurements that would show
compliance with the policy.
We observed that the organization awarded contracts to vendors but did not have a procurement policy
that matched Federal procurement standards.
Questioned costs – None reported.
Cause/effect – The Organization did not have policies or controls to ensure compliance with Federal
regulations regarding procurements. Documentation as to the significant history of procurements,
including from vendors, was not available to show compliance with procurement standards.
Repeat finding – Yes, prior year finding 2023-001.
Recommendation – The Organization should develop a procurement policy that matches Federal
procurement standards and internal controls to ensure the policy is followed. The Organization should
also retain documentation as to the significant history of procurements to show that the procurement
policy was followed.
Criteria – 2 CFR §200.317 to 327 – Procurement Standards. The recipient or subrecipient must maintain
and use documented procedures for procurement transactions under a Federal award or subaward,
including for acquisition of property or services. These documented procurement procedures must be
consistent with State, local, and tribal laws and regulations and the standards identified in §200.317
through §200.327.
Condition/context – The Organization did not have a procurement policy that complied with Federal
regulations and did not retain documentation as to the significant history of procurements that would show
compliance with the policy.
We observed that the organization awarded contracts to vendors but did not have a procurement policy
that matched Federal procurement standards.
Questioned costs – None reported.
Cause/effect – The Organization did not have policies or controls to ensure compliance with Federal
regulations regarding procurements. Documentation as to the significant history of procurements,
including from vendors, was not available to show compliance with procurement standards.
Repeat finding – Yes, prior year finding 2023-001.
Recommendation – The Organization should develop a procurement policy that matches Federal
procurement standards and internal controls to ensure the policy is followed. The Organization should
also retain documentation as to the significant history of procurements to show that the procurement
policy was followed.
Criteria – 2 CFR §200.430(g) – Standards for Documentation of Personnel Expenses require that charges
to federal awards for salaries and wages must be based on records that accurately reflect the work
performed and are supported by a system of internal control which provides reasonable assurance that
charges are accurate, allowable, and properly allocated. Estimates determined before services are
performed do not qualify as support.
Condition/context – A sample of 9 payroll expenditures was selected for testing. The total population of
payroll expenditures charged to the food distribution cluster grants was $1,396,059. For all 9 selections,
the Organization was unable to provide evidence of actual time spent on each grant. The Organization
allocates personnel expenses to federal awards using estimates, not records that accurately reflect the
work performed. The Organization estimates how much time each employee spends on activities
allowable for each grant, but these estimates are not supported by records that reflect the work
performed. The Organization has an electronic timekeeping system, but the system does not track the
activities an employee performs. Employees are not required to complete certifications or Personnel
Activity Reports (PARs) to support the hours worked on allowable activities.
Our sample was not, and was not intended to be, statistically valid.
Questioned costs – ALN 10.565 - $8,192, ALN 10.568 - $1,323,021, ALN 10.182 - $64,846
Total questioned costs for all programs – $1,396,059, which is the total payroll expenditures charged to
the food distribution cluster grants.
Cause/effect – The Organization has not developed a system of internal control which provides
reasonable assurance that charges are accurate, allowable, and properly allocated. Personnel expenses
charged to federal awards are not supported by records that reflect the work performed.
Repeat finding – No.
Recommendation – We recommend the Organization establish a system of time and effort reporting that
meets the standards for documentation of personnel expenses, and a system of internal control that
provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Criteria – 2 CFR §200.430(g) – Standards for Documentation of Personnel Expenses require that charges
to federal awards for salaries and wages must be based on records that accurately reflect the work
performed and are supported by a system of internal control which provides reasonable assurance that
charges are accurate, allowable, and properly allocated. Estimates determined before services are
performed do not qualify as support.
Condition/context – A sample of 9 payroll expenditures was selected for testing. The total population of
payroll expenditures charged to the food distribution cluster grants was $1,396,059. For all 9 selections,
the Organization was unable to provide evidence of actual time spent on each grant. The Organization
allocates personnel expenses to federal awards using estimates, not records that accurately reflect the
work performed. The Organization estimates how much time each employee spends on activities
allowable for each grant, but these estimates are not supported by records that reflect the work
performed. The Organization has an electronic timekeeping system, but the system does not track the
activities an employee performs. Employees are not required to complete certifications or Personnel
Activity Reports (PARs) to support the hours worked on allowable activities.
Our sample was not, and was not intended to be, statistically valid.
Questioned costs – ALN 10.565 - $8,192, ALN 10.568 - $1,323,021, ALN 10.182 - $64,846
Total questioned costs for all programs – $1,396,059, which is the total payroll expenditures charged to
the food distribution cluster grants.
Cause/effect – The Organization has not developed a system of internal control which provides
reasonable assurance that charges are accurate, allowable, and properly allocated. Personnel expenses
charged to federal awards are not supported by records that reflect the work performed.
Repeat finding – No.
Recommendation – We recommend the Organization establish a system of time and effort reporting that
meets the standards for documentation of personnel expenses, and a system of internal control that
provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Criteria – 2 CFR §200.430(g) – Standards for Documentation of Personnel Expenses require that charges
to federal awards for salaries and wages must be based on records that accurately reflect the work
performed and are supported by a system of internal control which provides reasonable assurance that
charges are accurate, allowable, and properly allocated. Estimates determined before services are
performed do not qualify as support.
Condition/context – A sample of 9 payroll expenditures was selected for testing. The total population of
payroll expenditures charged to the food distribution cluster grants was $1,396,059. For all 9 selections,
the Organization was unable to provide evidence of actual time spent on each grant. The Organization
allocates personnel expenses to federal awards using estimates, not records that accurately reflect the
work performed. The Organization estimates how much time each employee spends on activities
allowable for each grant, but these estimates are not supported by records that reflect the work
performed. The Organization has an electronic timekeeping system, but the system does not track the
activities an employee performs. Employees are not required to complete certifications or Personnel
Activity Reports (PARs) to support the hours worked on allowable activities.
Our sample was not, and was not intended to be, statistically valid.
Questioned costs – ALN 10.565 - $8,192, ALN 10.568 - $1,323,021, ALN 10.182 - $64,846
Total questioned costs for all programs – $1,396,059, which is the total payroll expenditures charged to
the food distribution cluster grants.
Cause/effect – The Organization has not developed a system of internal control which provides
reasonable assurance that charges are accurate, allowable, and properly allocated. Personnel expenses
charged to federal awards are not supported by records that reflect the work performed.
Repeat finding – No.
Recommendation – We recommend the Organization establish a system of time and effort reporting that
meets the standards for documentation of personnel expenses, and a system of internal control that
provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Criteria – 2 CFR §200.414 Indirect Costs – Entities must maintain accurate records and apply indirect
costs consistently across all federal awards. They must also ensure that subrecipient indirect costs are
managed in accordance with federal regulations.
Condition/context – Indirect costs are not being requested, applied, billed, or reported consistently by the
Organization. Indirect costs are not being applied to subrecipients consistently.
We observed numerous errors in the application of indirect costs by the Organization, including: not
requesting indirect costs in grant applications, negotiating non-de minimis rates with passthrough
agencies after electing a de minimis rate, billing indirect costs in excess of indirect costs awarded in the
grant agreement, erroneously including passthrough awards greater than $25,000 per subrecipient in the
modified total direct cost base, approving indirect cost rates for subrecipients that did not match the
subrecipient's elected de minimis rate, and including subrecipient indirect costs in the section of SF-425
reports reserved for reporting its own indirect costs.
Questioned costs – $27,467
Cause/effect – The Organization has decentralized grant controls which are not designed to ensure
compliance over indirect costs and consistency of application across all federal awards. Indirect costs in
excess of allowable indirect costs were billed to federal awards.
Repeat finding – No.
Recommendation – The Organization should develop procedures and internal controls to ensure indirect
cost rates are requested, applied, billed, and reported consistently across all federal awards using the
same rate. The Organization should develop similar procedures to ensure it is awarding and reporting
subrecipient indirect costs accurately. The Organization should ensure individuals responsible for these
controls are adequately trained.
Criteria – 2 CFR §200.414 Indirect Costs – Entities must maintain accurate records and apply indirect
costs consistently across all federal awards. They must also ensure that subrecipient indirect costs are
managed in accordance with federal regulations.
Condition/context – Indirect costs are not being requested, applied, billed, or reported consistently by the
Organization. Indirect costs are not being applied to subrecipients consistently.
We observed numerous errors in the application of indirect costs by the Organization, including: not
requesting indirect costs in grant applications, negotiating non-de minimis rates with passthrough
agencies after electing a de minimis rate, billing indirect costs in excess of indirect costs awarded in the
grant agreement, erroneously including passthrough awards greater than $25,000 per subrecipient in the
modified total direct cost base, approving indirect cost rates for subrecipients that did not match the
subrecipient's elected de minimis rate, and including subrecipient indirect costs in the section of SF-425
reports reserved for reporting its own indirect costs.
Questioned costs – $27,467
Cause/effect – The Organization has decentralized grant controls which are not designed to ensure
compliance over indirect costs and consistency of application across all federal awards. Indirect costs in
excess of allowable indirect costs were billed to federal awards.
Repeat finding – No.
Recommendation – The Organization should develop procedures and internal controls to ensure indirect
cost rates are requested, applied, billed, and reported consistently across all federal awards using the
same rate. The Organization should develop similar procedures to ensure it is awarding and reporting
subrecipient indirect costs accurately. The Organization should ensure individuals responsible for these
controls are adequately trained.
Criteria – 2 CFR §200.414 Indirect Costs – Entities must maintain accurate records and apply indirect
costs consistently across all federal awards. They must also ensure that subrecipient indirect costs are
managed in accordance with federal regulations.
Condition/context – Indirect costs are not being requested, applied, billed, or reported consistently by the
Organization. Indirect costs are not being applied to subrecipients consistently.
We observed numerous errors in the application of indirect costs by the Organization, including: not
requesting indirect costs in grant applications, negotiating non-de minimis rates with passthrough
agencies after electing a de minimis rate, billing indirect costs in excess of indirect costs awarded in the
grant agreement, erroneously including passthrough awards greater than $25,000 per subrecipient in the
modified total direct cost base, approving indirect cost rates for subrecipients that did not match the
subrecipient's elected de minimis rate, and including subrecipient indirect costs in the section of SF-425
reports reserved for reporting its own indirect costs.
Questioned costs – $27,467
Cause/effect – The Organization has decentralized grant controls which are not designed to ensure
compliance over indirect costs and consistency of application across all federal awards. Indirect costs in
excess of allowable indirect costs were billed to federal awards.
Repeat finding – No.
Recommendation – The Organization should develop procedures and internal controls to ensure indirect
cost rates are requested, applied, billed, and reported consistently across all federal awards using the
same rate. The Organization should develop similar procedures to ensure it is awarding and reporting
subrecipient indirect costs accurately. The Organization should ensure individuals responsible for these
controls are adequately trained.
Criteria – 2 CFR §200.414 Indirect Costs – Entities must maintain accurate records and apply indirect
costs consistently across all federal awards. They must also ensure that subrecipient indirect costs are
managed in accordance with federal regulations.
Condition/context – Indirect costs are not being requested, applied, billed, or reported consistently by the
Organization. Indirect costs are not being applied to subrecipients consistently.
We observed numerous errors in the application of indirect costs by the Organization, including: not
requesting indirect costs in grant applications, negotiating non-de minimis rates with passthrough
agencies after electing a de minimis rate, billing indirect costs in excess of indirect costs awarded in the
grant agreement, erroneously including passthrough awards greater than $25,000 per subrecipient in the
modified total direct cost base, approving indirect cost rates for subrecipients that did not match the
subrecipient's elected de minimis rate, and including subrecipient indirect costs in the section of SF-425
reports reserved for reporting its own indirect costs.
Questioned costs – $27,467
Cause/effect – The Organization has decentralized grant controls which are not designed to ensure
compliance over indirect costs and consistency of application across all federal awards. Indirect costs in
excess of allowable indirect costs were billed to federal awards.
Repeat finding – No.
Recommendation – The Organization should develop procedures and internal controls to ensure indirect
cost rates are requested, applied, billed, and reported consistently across all federal awards using the
same rate. The Organization should develop similar procedures to ensure it is awarding and reporting
subrecipient indirect costs accurately. The Organization should ensure individuals responsible for these
controls are adequately trained.
Criteria – 2 CFR §200.414 Indirect Costs – Entities must maintain accurate records and apply indirect
costs consistently across all federal awards. They must also ensure that subrecipient indirect costs are
managed in accordance with federal regulations.
Condition/context – Indirect costs are not being requested, applied, billed, or reported consistently by the
Organization. Indirect costs are not being applied to subrecipients consistently.
We observed numerous errors in the application of indirect costs by the Organization, including: not
requesting indirect costs in grant applications, negotiating non-de minimis rates with passthrough
agencies after electing a de minimis rate, billing indirect costs in excess of indirect costs awarded in the
grant agreement, erroneously including passthrough awards greater than $25,000 per subrecipient in the
modified total direct cost base, approving indirect cost rates for subrecipients that did not match the
subrecipient's elected de minimis rate, and including subrecipient indirect costs in the section of SF-425
reports reserved for reporting its own indirect costs.
Questioned costs – $27,467
Cause/effect – The Organization has decentralized grant controls which are not designed to ensure
compliance over indirect costs and consistency of application across all federal awards. Indirect costs in
excess of allowable indirect costs were billed to federal awards.
Repeat finding – No.
Recommendation – The Organization should develop procedures and internal controls to ensure indirect
cost rates are requested, applied, billed, and reported consistently across all federal awards using the
same rate. The Organization should develop similar procedures to ensure it is awarding and reporting
subrecipient indirect costs accurately. The Organization should ensure individuals responsible for these
controls are adequately trained.
Criteria – 2 CFR §200.317 to 327 – Procurement Standards. The recipient or subrecipient must maintain
and use documented procedures for procurement transactions under a Federal award or subaward,
including for acquisition of property or services. These documented procurement procedures must be
consistent with State, local, and tribal laws and regulations and the standards identified in §200.317
through §200.327.
Condition/context – The Organization did not have a procurement policy that complied with Federal
regulations and did not retain documentation as to the significant history of procurements that would show
compliance with the policy.
We observed that the organization awarded contracts to vendors but did not have a procurement policy
that matched Federal procurement standards.
Questioned costs – None reported.
Cause/effect – The Organization did not have policies or controls to ensure compliance with Federal
regulations regarding procurements. Documentation as to the significant history of procurements,
including from vendors, was not available to show compliance with procurement standards.
Repeat finding – Yes, prior year finding 2023-001.
Recommendation – The Organization should develop a procurement policy that matches Federal
procurement standards and internal controls to ensure the policy is followed. The Organization should
also retain documentation as to the significant history of procurements to show that the procurement
policy was followed.
Criteria – 2 CFR §200.317 to 327 – Procurement Standards. The recipient or subrecipient must maintain
and use documented procedures for procurement transactions under a Federal award or subaward,
including for acquisition of property or services. These documented procurement procedures must be
consistent with State, local, and tribal laws and regulations and the standards identified in §200.317
through §200.327.
Condition/context – The Organization did not have a procurement policy that complied with Federal
regulations and did not retain documentation as to the significant history of procurements that would show
compliance with the policy.
We observed that the organization awarded contracts to vendors but did not have a procurement policy
that matched Federal procurement standards.
Questioned costs – None reported.
Cause/effect – The Organization did not have policies or controls to ensure compliance with Federal
regulations regarding procurements. Documentation as to the significant history of procurements,
including from vendors, was not available to show compliance with procurement standards.
Repeat finding – Yes, prior year finding 2023-001.
Recommendation – The Organization should develop a procurement policy that matches Federal
procurement standards and internal controls to ensure the policy is followed. The Organization should
also retain documentation as to the significant history of procurements to show that the procurement
policy was followed.
Criteria – 2 CFR §200.317 to 327 – Procurement Standards. The recipient or subrecipient must maintain
and use documented procedures for procurement transactions under a Federal award or subaward,
including for acquisition of property or services. These documented procurement procedures must be
consistent with State, local, and tribal laws and regulations and the standards identified in §200.317
through §200.327.
Condition/context – The Organization did not have a procurement policy that complied with Federal
regulations and did not retain documentation as to the significant history of procurements that would show
compliance with the policy.
We observed that the organization awarded contracts to vendors but did not have a procurement policy
that matched Federal procurement standards.
Questioned costs – None reported.
Cause/effect – The Organization did not have policies or controls to ensure compliance with Federal
regulations regarding procurements. Documentation as to the significant history of procurements,
including from vendors, was not available to show compliance with procurement standards.
Repeat finding – Yes, prior year finding 2023-001.
Recommendation – The Organization should develop a procurement policy that matches Federal
procurement standards and internal controls to ensure the policy is followed. The Organization should
also retain documentation as to the significant history of procurements to show that the procurement
policy was followed.
Criteria – 2 CFR §200.317 to 327 – Procurement Standards. The recipient or subrecipient must maintain
and use documented procedures for procurement transactions under a Federal award or subaward,
including for acquisition of property or services. These documented procurement procedures must be
consistent with State, local, and tribal laws and regulations and the standards identified in §200.317
through §200.327.
Condition/context – The Organization did not have a procurement policy that complied with Federal
regulations and did not retain documentation as to the significant history of procurements that would show
compliance with the policy.
We observed that the organization awarded contracts to vendors but did not have a procurement policy
that matched Federal procurement standards.
Questioned costs – None reported.
Cause/effect – The Organization did not have policies or controls to ensure compliance with Federal
regulations regarding procurements. Documentation as to the significant history of procurements,
including from vendors, was not available to show compliance with procurement standards.
Repeat finding – Yes, prior year finding 2023-001.
Recommendation – The Organization should develop a procurement policy that matches Federal
procurement standards and internal controls to ensure the policy is followed. The Organization should
also retain documentation as to the significant history of procurements to show that the procurement
policy was followed.
Criteria – 2 CFR §200.317 to 327 – Procurement Standards. The recipient or subrecipient must maintain
and use documented procedures for procurement transactions under a Federal award or subaward,
including for acquisition of property or services. These documented procurement procedures must be
consistent with State, local, and tribal laws and regulations and the standards identified in §200.317
through §200.327.
Condition/context – The Organization did not have a procurement policy that complied with Federal
regulations and did not retain documentation as to the significant history of procurements that would show
compliance with the policy.
We observed that the organization awarded contracts to vendors but did not have a procurement policy
that matched Federal procurement standards.
Questioned costs – None reported.
Cause/effect – The Organization did not have policies or controls to ensure compliance with Federal
regulations regarding procurements. Documentation as to the significant history of procurements,
including from vendors, was not available to show compliance with procurement standards.
Repeat finding – Yes, prior year finding 2023-001.
Recommendation – The Organization should develop a procurement policy that matches Federal
procurement standards and internal controls to ensure the policy is followed. The Organization should
also retain documentation as to the significant history of procurements to show that the procurement
policy was followed.