2024-002 Indirect Costs
Federal Agency: Department of Labor
Federal Programs: 17.258/17.259/17.278 Workforce Innovation Opportunity Act (WIOA) Cluster
(Passed through MassHire Department of Career Services (MDCS))
Condition:
The Organization over billed grant awards under the WIOA Cluster $37,790 for indirect costs.
Criteria:
2 CFR 200.414(f) of the Uniform Guidance allows entities that do not have a current negotiated indirect cost rate to charge federal awards a de minimus rate of 10% of modified total direct costs. The Uniform Guidance defines modified total direct costs as all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $25,000 of each subaward.
Cause:
The Organization did not properly calculate its modified total direct costs for each federal award under the WIOA cluster resulting in the calculated indirect costs being overstated.
Effect:
The Organization has over billed grant awards under the WIOA cluster.
Context:
Modified total direct costs under the WIOA Cluster grant awards were $781,730 for the year ended June 30, 2024. The WIOA Cluster grants were billed for $115,963 in indirect costs for the year ended June 30, 2024.
Questioned Costs:
$37,790
Recommendation:
We recommend that management return the over billed costs to the grantor and review its policies and procedures to ensure indirect costs are properly calculated and billed under the Uniform Guidance.
Management Response:
Management agrees with the finding. See management’s attached corrective action plan.
2024-002 Indirect Costs
Federal Agency: Department of Labor
Federal Programs: 17.258/17.259/17.278 Workforce Innovation Opportunity Act (WIOA) Cluster
(Passed through MassHire Department of Career Services (MDCS))
Condition:
The Organization over billed grant awards under the WIOA Cluster $37,790 for indirect costs.
Criteria:
2 CFR 200.414(f) of the Uniform Guidance allows entities that do not have a current negotiated indirect cost rate to charge federal awards a de minimus rate of 10% of modified total direct costs. The Uniform Guidance defines modified total direct costs as all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $25,000 of each subaward.
Cause:
The Organization did not properly calculate its modified total direct costs for each federal award under the WIOA cluster resulting in the calculated indirect costs being overstated.
Effect:
The Organization has over billed grant awards under the WIOA cluster.
Context:
Modified total direct costs under the WIOA Cluster grant awards were $781,730 for the year ended June 30, 2024. The WIOA Cluster grants were billed for $115,963 in indirect costs for the year ended June 30, 2024.
Questioned Costs:
$37,790
Recommendation:
We recommend that management return the over billed costs to the grantor and review its policies and procedures to ensure indirect costs are properly calculated and billed under the Uniform Guidance.
Management Response:
Management agrees with the finding. See management’s attached corrective action plan.
2024-002 Indirect Costs
Federal Agency: Department of Labor
Federal Programs: 17.258/17.259/17.278 Workforce Innovation Opportunity Act (WIOA) Cluster
(Passed through MassHire Department of Career Services (MDCS))
Condition:
The Organization over billed grant awards under the WIOA Cluster $37,790 for indirect costs.
Criteria:
2 CFR 200.414(f) of the Uniform Guidance allows entities that do not have a current negotiated indirect cost rate to charge federal awards a de minimus rate of 10% of modified total direct costs. The Uniform Guidance defines modified total direct costs as all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $25,000 of each subaward.
Cause:
The Organization did not properly calculate its modified total direct costs for each federal award under the WIOA cluster resulting in the calculated indirect costs being overstated.
Effect:
The Organization has over billed grant awards under the WIOA cluster.
Context:
Modified total direct costs under the WIOA Cluster grant awards were $781,730 for the year ended June 30, 2024. The WIOA Cluster grants were billed for $115,963 in indirect costs for the year ended June 30, 2024.
Questioned Costs:
$37,790
Recommendation:
We recommend that management return the over billed costs to the grantor and review its policies and procedures to ensure indirect costs are properly calculated and billed under the Uniform Guidance.
Management Response:
Management agrees with the finding. See management’s attached corrective action plan.
2024-003 Subrecipient Monitoring
Federal Agency: Department of Labor
Federal Programs: 17.258/17.259/17.278 Workforce Innovation Opportunity Act (WIOA) Cluster
(Passed through MassHire Department of Career Services (MDCS))
Condition:
The Organization did not perform any monitoring of its subrecipient in fiscal year 2024.
Criteria:
2 CFR 200.332 of the Uniform Guidance requires pass-through entities to:
• Identify the award and applicable requirements of the funding source to its subrecipients.
• Evaluate each subrecipient’s risk of noncompliance with the regulations of the federal funds.
• 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.
Cause:
Although the Organization has policies and procedures in place surrounding the subrecipient monitoring requirements, there were delays in the subrecipient providing financial and other records needed for the Organization to complete its annual monitoring requirements.
Effect:
The Organization cannot ensure the costs of goods and services charged to the federal program are allowable and charged in accordance with the applicable regulations.
Context:
Total expenditures for the WIOA Cluster were $1,223,337 for the year ended June 30, 2024, which included $373,352 of expenditures to subrecipients.
Questioned Costs:
Unknown
Recommendation:
We recommend that management review its policies and procedures to ensure subrecipients are monitored for program compliance at least annually.
Management Response:
Management agrees with the finding. See management’s attached corrective action plan.
2024-003 Subrecipient Monitoring
Federal Agency: Department of Labor
Federal Programs: 17.258/17.259/17.278 Workforce Innovation Opportunity Act (WIOA) Cluster
(Passed through MassHire Department of Career Services (MDCS))
Condition:
The Organization did not perform any monitoring of its subrecipient in fiscal year 2024.
Criteria:
2 CFR 200.332 of the Uniform Guidance requires pass-through entities to:
• Identify the award and applicable requirements of the funding source to its subrecipients.
• Evaluate each subrecipient’s risk of noncompliance with the regulations of the federal funds.
• 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.
Cause:
Although the Organization has policies and procedures in place surrounding the subrecipient monitoring requirements, there were delays in the subrecipient providing financial and other records needed for the Organization to complete its annual monitoring requirements.
Effect:
The Organization cannot ensure the costs of goods and services charged to the federal program are allowable and charged in accordance with the applicable regulations.
Context:
Total expenditures for the WIOA Cluster were $1,223,337 for the year ended June 30, 2024, which included $373,352 of expenditures to subrecipients.
Questioned Costs:
Unknown
Recommendation:
We recommend that management review its policies and procedures to ensure subrecipients are monitored for program compliance at least annually.
Management Response:
Management agrees with the finding. See management’s attached corrective action plan.
2024-003 Subrecipient Monitoring
Federal Agency: Department of Labor
Federal Programs: 17.258/17.259/17.278 Workforce Innovation Opportunity Act (WIOA) Cluster
(Passed through MassHire Department of Career Services (MDCS))
Condition:
The Organization did not perform any monitoring of its subrecipient in fiscal year 2024.
Criteria:
2 CFR 200.332 of the Uniform Guidance requires pass-through entities to:
• Identify the award and applicable requirements of the funding source to its subrecipients.
• Evaluate each subrecipient’s risk of noncompliance with the regulations of the federal funds.
• 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.
Cause:
Although the Organization has policies and procedures in place surrounding the subrecipient monitoring requirements, there were delays in the subrecipient providing financial and other records needed for the Organization to complete its annual monitoring requirements.
Effect:
The Organization cannot ensure the costs of goods and services charged to the federal program are allowable and charged in accordance with the applicable regulations.
Context:
Total expenditures for the WIOA Cluster were $1,223,337 for the year ended June 30, 2024, which included $373,352 of expenditures to subrecipients.
Questioned Costs:
Unknown
Recommendation:
We recommend that management review its policies and procedures to ensure subrecipients are monitored for program compliance at least annually.
Management Response:
Management agrees with the finding. See management’s attached corrective action plan.
2024-002 Indirect Costs
Federal Agency: Department of Labor
Federal Programs: 17.258/17.259/17.278 Workforce Innovation Opportunity Act (WIOA) Cluster
(Passed through MassHire Department of Career Services (MDCS))
Condition:
The Organization over billed grant awards under the WIOA Cluster $37,790 for indirect costs.
Criteria:
2 CFR 200.414(f) of the Uniform Guidance allows entities that do not have a current negotiated indirect cost rate to charge federal awards a de minimus rate of 10% of modified total direct costs. The Uniform Guidance defines modified total direct costs as all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $25,000 of each subaward.
Cause:
The Organization did not properly calculate its modified total direct costs for each federal award under the WIOA cluster resulting in the calculated indirect costs being overstated.
Effect:
The Organization has over billed grant awards under the WIOA cluster.
Context:
Modified total direct costs under the WIOA Cluster grant awards were $781,730 for the year ended June 30, 2024. The WIOA Cluster grants were billed for $115,963 in indirect costs for the year ended June 30, 2024.
Questioned Costs:
$37,790
Recommendation:
We recommend that management return the over billed costs to the grantor and review its policies and procedures to ensure indirect costs are properly calculated and billed under the Uniform Guidance.
Management Response:
Management agrees with the finding. See management’s attached corrective action plan.
2024-002 Indirect Costs
Federal Agency: Department of Labor
Federal Programs: 17.258/17.259/17.278 Workforce Innovation Opportunity Act (WIOA) Cluster
(Passed through MassHire Department of Career Services (MDCS))
Condition:
The Organization over billed grant awards under the WIOA Cluster $37,790 for indirect costs.
Criteria:
2 CFR 200.414(f) of the Uniform Guidance allows entities that do not have a current negotiated indirect cost rate to charge federal awards a de minimus rate of 10% of modified total direct costs. The Uniform Guidance defines modified total direct costs as all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $25,000 of each subaward.
Cause:
The Organization did not properly calculate its modified total direct costs for each federal award under the WIOA cluster resulting in the calculated indirect costs being overstated.
Effect:
The Organization has over billed grant awards under the WIOA cluster.
Context:
Modified total direct costs under the WIOA Cluster grant awards were $781,730 for the year ended June 30, 2024. The WIOA Cluster grants were billed for $115,963 in indirect costs for the year ended June 30, 2024.
Questioned Costs:
$37,790
Recommendation:
We recommend that management return the over billed costs to the grantor and review its policies and procedures to ensure indirect costs are properly calculated and billed under the Uniform Guidance.
Management Response:
Management agrees with the finding. See management’s attached corrective action plan.
2024-002 Indirect Costs
Federal Agency: Department of Labor
Federal Programs: 17.258/17.259/17.278 Workforce Innovation Opportunity Act (WIOA) Cluster
(Passed through MassHire Department of Career Services (MDCS))
Condition:
The Organization over billed grant awards under the WIOA Cluster $37,790 for indirect costs.
Criteria:
2 CFR 200.414(f) of the Uniform Guidance allows entities that do not have a current negotiated indirect cost rate to charge federal awards a de minimus rate of 10% of modified total direct costs. The Uniform Guidance defines modified total direct costs as all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $25,000 of each subaward.
Cause:
The Organization did not properly calculate its modified total direct costs for each federal award under the WIOA cluster resulting in the calculated indirect costs being overstated.
Effect:
The Organization has over billed grant awards under the WIOA cluster.
Context:
Modified total direct costs under the WIOA Cluster grant awards were $781,730 for the year ended June 30, 2024. The WIOA Cluster grants were billed for $115,963 in indirect costs for the year ended June 30, 2024.
Questioned Costs:
$37,790
Recommendation:
We recommend that management return the over billed costs to the grantor and review its policies and procedures to ensure indirect costs are properly calculated and billed under the Uniform Guidance.
Management Response:
Management agrees with the finding. See management’s attached corrective action plan.
2024-003 Subrecipient Monitoring
Federal Agency: Department of Labor
Federal Programs: 17.258/17.259/17.278 Workforce Innovation Opportunity Act (WIOA) Cluster
(Passed through MassHire Department of Career Services (MDCS))
Condition:
The Organization did not perform any monitoring of its subrecipient in fiscal year 2024.
Criteria:
2 CFR 200.332 of the Uniform Guidance requires pass-through entities to:
• Identify the award and applicable requirements of the funding source to its subrecipients.
• Evaluate each subrecipient’s risk of noncompliance with the regulations of the federal funds.
• 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.
Cause:
Although the Organization has policies and procedures in place surrounding the subrecipient monitoring requirements, there were delays in the subrecipient providing financial and other records needed for the Organization to complete its annual monitoring requirements.
Effect:
The Organization cannot ensure the costs of goods and services charged to the federal program are allowable and charged in accordance with the applicable regulations.
Context:
Total expenditures for the WIOA Cluster were $1,223,337 for the year ended June 30, 2024, which included $373,352 of expenditures to subrecipients.
Questioned Costs:
Unknown
Recommendation:
We recommend that management review its policies and procedures to ensure subrecipients are monitored for program compliance at least annually.
Management Response:
Management agrees with the finding. See management’s attached corrective action plan.
2024-003 Subrecipient Monitoring
Federal Agency: Department of Labor
Federal Programs: 17.258/17.259/17.278 Workforce Innovation Opportunity Act (WIOA) Cluster
(Passed through MassHire Department of Career Services (MDCS))
Condition:
The Organization did not perform any monitoring of its subrecipient in fiscal year 2024.
Criteria:
2 CFR 200.332 of the Uniform Guidance requires pass-through entities to:
• Identify the award and applicable requirements of the funding source to its subrecipients.
• Evaluate each subrecipient’s risk of noncompliance with the regulations of the federal funds.
• 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.
Cause:
Although the Organization has policies and procedures in place surrounding the subrecipient monitoring requirements, there were delays in the subrecipient providing financial and other records needed for the Organization to complete its annual monitoring requirements.
Effect:
The Organization cannot ensure the costs of goods and services charged to the federal program are allowable and charged in accordance with the applicable regulations.
Context:
Total expenditures for the WIOA Cluster were $1,223,337 for the year ended June 30, 2024, which included $373,352 of expenditures to subrecipients.
Questioned Costs:
Unknown
Recommendation:
We recommend that management review its policies and procedures to ensure subrecipients are monitored for program compliance at least annually.
Management Response:
Management agrees with the finding. See management’s attached corrective action plan.
2024-003 Subrecipient Monitoring
Federal Agency: Department of Labor
Federal Programs: 17.258/17.259/17.278 Workforce Innovation Opportunity Act (WIOA) Cluster
(Passed through MassHire Department of Career Services (MDCS))
Condition:
The Organization did not perform any monitoring of its subrecipient in fiscal year 2024.
Criteria:
2 CFR 200.332 of the Uniform Guidance requires pass-through entities to:
• Identify the award and applicable requirements of the funding source to its subrecipients.
• Evaluate each subrecipient’s risk of noncompliance with the regulations of the federal funds.
• 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.
Cause:
Although the Organization has policies and procedures in place surrounding the subrecipient monitoring requirements, there were delays in the subrecipient providing financial and other records needed for the Organization to complete its annual monitoring requirements.
Effect:
The Organization cannot ensure the costs of goods and services charged to the federal program are allowable and charged in accordance with the applicable regulations.
Context:
Total expenditures for the WIOA Cluster were $1,223,337 for the year ended June 30, 2024, which included $373,352 of expenditures to subrecipients.
Questioned Costs:
Unknown
Recommendation:
We recommend that management review its policies and procedures to ensure subrecipients are monitored for program compliance at least annually.
Management Response:
Management agrees with the finding. See management’s attached corrective action plan.